Petition for exemption/rulemaking October 5 th , 2015 Ronald Mochinski rm p hotography , LLC 10139 Spring Lake Terrace Fairfax, VA 22030 703

- 850

- 0317 http://www.rmochinski.com/ rmochinski@gmail.com

Subj: Petition for e xempti on to o perate a small Unmanned Aircraft System ( sUAS ) for the p urpose of r eal e state and general photography/video.

I am requesting exemption of the Federal Aviation Administration for certain FAA Regulations so that I may use a sUAS in conducting the bus iness of providing aerial photography/video in the real estate market.

The sUAS that will be used is the DJI Phantom 3 (Advanced) , developed by DJI Technology Co., Ltd.

Request for exemptions pursuant to section 333 include:

• 14 CFR

- Part 21 Subpart H

- A irworthiness Certificate, Certification Procedures.

• 14 CFR

- Part 3

- Noise Regulations.

• 14 CFR

- 45.23

- Display Markings.

• 14 CFR

- Part 61.113(a)&(b)

- Certifications for Instructors and Pilots.

• 14 CFR

- 91.9

- Flight Manuals and Marking Requirements.

• 14 CFR

- 91. 1 09

- Flight Instruction.

• 14 CFR

- 91.119

- Minimum Safe Altitudes.

• 14 CFR

- 91.121

- Altimeter Settings.

• 14 CFR

- 91.151

- VFR Requirements for Fuel.

• 14 CFR

- 91.203

- Certificates Required for Civil Aircraft.

• 14 CFR

- 91.205(b)

- Instrument and equipment requirem ents.• 14 CFR

- 91.215

- ATC transponder and altitude reporting equipment.

• 14 CFR

- 91.405(a) , 91.407(a)(1), 91.409(a)(2) and 1.417(a) and (b)

- Maintenance Required.

**Operating Conditions** When conducting operation s, the unit will stay at or below 300' ceiling , operate only within VLOS by the PIC and the VO

. Return

- to

- home will

commence when battery capacity reaches 25% as recommended by the manufacturer . Additionally the PIC will not operate the sUAS in crowded

areas , near or around powerlines, near or around trees or other obstacles which may cause harm to human or the aircraft itself . Before deploy ing the sUAS any nearby residences will be communicated with that aerial photography will be taking place for a predetermined amount of time

. Current w eather condi tions and forecast will have a determining factor before each flight.

**Pilot**

**- in** 

**- Command**  I will be acting as PIC. I have a current private pilot license to operate single engine land airplanes (certificate no. 3633190)

. I have previous flight experience wit h D JI products

. The sUAS will be flown only during VFR daylight hours and only under VLOS rules. My goal is to provide a safe environment while adhering to all FAA rules for safe flight.

**Prior to Take**

**- off**  Preflight inspection of the sUAS will be conducted as outlined in the DJI operation manual and user guide by the PIC

. Visual inspection of all rotor blades, electrical connections, battery conditions and levels, and testing of the link between the sUAS and the RC controller will be done before each flight . In addition, compass calibration and GPS lock will be confirmed prior to take

- off.

For safety purposes I will abide by the following additional operating conditions:• operate the s UAS at or below 300 feet and within a radius distance of 5 00 feet from th e controller and VO ;

• operate the s UAS for only 75% of it’s battery life per flight;

• land the s UAS prior to the manufacturer’s recommended minimum level of battery power (25%) ;

• operate the s UAS only within visual line of sight (VLOS);

• use the s UAS’ global p ositioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control is lost;

• communicate with local residents when aerial operations are taking place

.

**No**

**- Fly Zones**  In addition to these steps, the DJI products come pre

- equipped with firmware that will not allow fight with in a no

- fly zone. DJI developed a flight limitation system to prohibit the s UA S from flying into the air space surrounding an airport. As of January 2015 t he DJI firmware will also not allow flight within 15 mile zone of the Washington DC area:

Figure 1 : Source: DJI website: http://www.dji.com/fly

- safe/category

- mcAs a pilot in the Washington DC area I am aware of the highly sensitive nature of the surro unding area. I have also completed the certificate of achievement from the **Aviation Learning Center Online Course** for the Washington DC Special Flight Rules Area :

I am prepared to modify or amend any part of this request to satisfy the need for an equi valent level of safety. Please contact me at any time if you require additional information or clarification.

Ronald M. Mochinski Photographer/ **V** ideographer rm p hotography, LLC