James	M	Crotty

Manager,	Aircraft	and	Airport	Rules	Division 800	Independence	Ave	S.W. Washington	DC	20591

Re: Public	Docket	FAA

- 2015

- 0827

– Exemption	/	rulemaking	request Your	name	and	mailing	address. You	may	include	other	contact	information	such	as	a	fax number,	telephone	number,	or	email	address; Robert	Wise ImageWise	Video	LLC 18150	NW	Clarno	Ct. Portland	OR	97229 503	724	5460 Rob@imagewisevideo.com **The	extent	of	relief	you	seek	and	the	reason	you	seek	the	relief;**
14	C.F.R.	Part	21 14	C.F.R.	45.23(b) 14	C.F.R.	61.113(a)	&	(b) ; 14	C.F.R.	61.133(a) ; 14	C.F.R.	91.7(a) ; 14	C.F.R.	91.9(b)(2)	&	(c) 14	C.F.R.	91.103; 14	C.F.R.	91.109(a) ; 14	C.F.R.	91.119;14 C.F.R.	91.151(a) ; 14	C.F.R.	91.203(a)	&	(b) ; 14	C.F.R.	91.405(a) ; 14	C.F.R.	91.407(a)(1) ; 14	C.F.R.	91.409(a)(2) ;	14	C.F .R.	91.417(a). Sec	333	prohibits	the	use	of	a	sUAS for	commercial	purposes	on	private	property.	I	am	the owner	of	a	video	production	company	that	providing	video	services	for	private	and corporate	special	events,	and	corporate	information	and	recording	service.	I	am petitioning	for	an	exemption	to	provide a	commercial	service	to	private	and	public	land owners	and	companies	who	wish	to	obtain	and	capture	aerial	photos	and	videos	of	said property or	events, for	purposes	including	real	estate	listings,	insurance	property	claims, search	and	rescue,	building	an d	property	inspections	and	review, land	surveying	or for use	as	a	marketing	tool	for	businesses. Additional	use	may	be	for	video/film	production. I	would	like	to	be	able	to	accept	payment	for	these	services	therefore	making this	a commercial	use	of	a	sUAS.**How	your	request	would	benefit	the	public	as	a	whole;**

My	request	benefits	the	public	as	a	whole	by	providing	an	opportunity	for	small	business owners, real	estate	agents,	and	other	business	owners who	wish	to	document	their	land , property,		product or	company, to	take	advantage	of	the lower	cost	and technology	that now	exists	in	the	form	of	sUAS’s	and	allows	them	to	do	so	us ing	an	experienced	and RC Pilot	in	Command	that	understands	how	to	safely	operate	such	technology.
**Reasons	why	the	exemption would	not	adversely	affect	safety,	or	how	the**  **exemption	would	provide	a	level	of	safety	at	least	equal	to	the	existing	rule;** As	a	qualified	and	commercial	videographer	and	member	of	the	Drone	Pilots	Association,	I currently	exercise	many	safety	programs, including	SAFE	technology	and	GPS	navigating. When	flying	for	this	commercial	purpose	I	would	be	flying	at	a	maximum	altitude	of	200 Feet	and	flying	mostly	vertically	for	the	purposes	of	taking	photos,	decreasing	the	risk	of any	interference.	My	general	kn owledge	of	the	aviation	safety	systems	implemented	by the	FAA	would	be	used	to	ensure	that	safety	would	not	be	affected	by	my	operations.	I	will not	be	flying	near	high	traffic	areas	including	airports,	and	I	pay	attention	to	NOTAMS	by following	current	al erts	at	twitter.com/amagov	or	refer	to	pilotweb.nas.faa.gov/PilotWeb/ **I intend to follow these suggested safety regulations**

 Alway s keep aircraft in line of sight and under control.

 Accompan yi ng me will be a second person to moni tor the aircraft along with me.

 Alway s keep ing people and pets at least 35 feet (10 meters) away when the battery

is connected.

 Keep children out of the vicinity of this product at all times.

 Alway s use full y charged batteries and do not fl y when batteri es are 25% or less power remaining.

 Utilize auto return home prior to batteries remaining power at 25% or less.

 Not fly

within 5 miles of any

airport or fly

in other no fly

zones.
 I have installed the dji Inspire 1 propeller l ocks which were sent out by DJI, which ensure an added safet y la yer of propellers.

 The auto	home	point	return	feature,	which	returns	the	aircraft	to	either	when	the controller	is	or	where	the	Dji	Ins p ire	1 initially takes	off	from. This	can	be	used	when low	battery	level	customizable	thresholds	are	enabled,	or	if	the	aircraft	drifts,	for simple	recovery	and	automated	return	of	the	aircraft. **Additional	safety	features	I	will	be	using	to	ensure	a	safe	and	responsible	flight	path ,**  **inc luding	the	following.** 
**VISION	POSITIONING	SYSTEM** DJI’s	new	Optical	Flow	technology	uses	a	specially	designed	camera	as	well	as	sonic	waves to	bring	simplicity	and	safety	when	taking	off	and	landing. These	sensors	read	the	ground distance	and	ensure	a	smooth	take	off,	landing	or	use	in	doors	if	applicable. Thistechnology	allows	the	Inspire	to	hold	its	position,	stop	when	the	controls	are	released,	and

respond	to	your	commands	even	when	GPS	is	unavail able.
**INTELLIGENT	POWER	MANAGEMENT	SYSTEM** A	fully	integrated	intelligent	battery	powers	the	Inspire	1	and	virtually	manages	itself. When	in	flight, my	remaining	battery	power	is	shown	live,	letting me	know	know	how long	I	can continue	to	fly in	minutes

. Advanced	algorithms	calculate	the	distance	of	your aircraft	and	estimated	time	to	return	home,	letting	you	know	when	it’s	time	to	fly	back. The	battery	tracks	the	voltage	of	each	cell,	the	total	lifetime	charges	and	discharges,	and the	overall	health	and	b attery	status.
**SAFE FLIGHT** When GPS is available, the Home Point (the location you are standing) automatically refreshes, so the Inspire 1 always knows where you are even if you move around. When you tell it to come back, or in case of an emergency, it knows exactly where to go and land safely. **FULL -**  **FEATURED APP** In addition to line of site, I simultaneously have access to the camera and flight system with a comprehensive mobile app. Everything from manual camera controls to flight telemetry, auto takeoff and landing are accessible on the controller and the app alike.

 **Position Hold**

– The DJI Inspire 1 uses GPS to hold a given location when this function is activated. If GPS is enabled and has a solid lock, the aircraft will hold its position when elevator or aileron inputs DJI Inspire 1 are at neutral.

 **Throttle provides proportional thrus t** 
– The throttle responds directly to the throttle input, giving the pilot direct control over hovering as well as ascent and descent rates. **A summary we can publish in the Federal Register**

**—** I, Robert Wise am seeking an exemption of the FAA’s Sec 333 rules that does not allow the use of a small Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safet y. I am simply petitioning for an exemption to provide a commercial service to private and public land owners and compani es who wish to obtain and capture a erial photos and videos of said property , private or public events, real estate listings, insurance propert y claims, inspections and review, marketing tool for business. As a member of the Drone Pilots Associations Iunde rstanding the importance of different uses and safety concerns regarding FAA regulated airspace, I would be a good candidate for exemption of Sec 333 while not putting Air Safet y in an y accelerated risk. The specific sUAS ( DJI Inspire 1 whose Operating Manual is included in my petition) I am seeking exemption with is one with many safet y programs, including SAFE technology and GPS navigating. When fl yi ng for this commercial purpose I would be flying at a maximum altitude, not to exceed 500 feet and flying m ostly verticall y for the purposes of taking photos, decreasing the risk of an y interference. M y general knowledge of the aviation safet y s ys tems implemented by the FAA would be used to ensure that safet y would not be affected b y m y operations. I would not be fl yi ng near disaster areas sporting events, (unless specificall y hired to do so by the organizing management) or hightraffic areas including airports, and I would monitor and pay attention to NOTAMS. I appreciate the FAA’s consideration of this petitio n for exemption. **Any additional information, views, or arguments available to support your request;**
I am fully aware of the preflight safet y checks and procedures implicated in the operation manual for the DJI Inspire 1 and intend to implement preflight safety checks and utilize the safet y technology provided with this unit. I intend to only

fl y in non

- populated, residential or rural areas and stay

clear of all utility

lines etc. I intend to be fully aware of my

surroundings at all times and to only

fl y the unmanned aircraft within a visual line of sight and only in Visual Flight Conditions and with a spotter. I understand and will comply with all the health and safet y regulations for PI C’s and will be the only operator under this exemption. **FCC Complia nce**  This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) This device must accept any interference received, including interference that may cau se undesired operation. Changes or modifications not expressly approved b y the party

responsible for compliance could void the user's authorit y to operate the equipment **General Safety Precautions and Warnings I intend to follow** :

 Follow FAA guidelines for safe usage of sUAS flight.
 Maintain ing flight log data.
 Update the weather, wind and other factors prior to takeoff.
 I u se extreme caution if operating around buildings, people or othe r personal or business propert y, keeping the a ircraft at safe distances away

. **If you want to exercise the privileges of your exemption outside the United States, you must state the reason.**  Although I have no intention of using this exemption outside the United States at this time , there may be a time in the future for limited or periodic use of the aircraft, outside the United States . This could be for relocation , destination videos for personal or commercial use. If used outside the United States, Iw ill comply with that government’s law s, exemptions and other applicable regulations. I have attached a cop y of the Dji Inspire 1 operating manual and providing you with the link to the manufacturer’s website where you can obtain more insight. http://www.dji.com/product/inspire

- 1/feature Please contact me if I can follow up with any thing else regarding my

requested exemption. Thank you for your consideration for approval.Sincerel y,

Robert Wise rob@imagewisevideo.com