April 26, 2015

From: Kyle Ferreira , Bergen County Aerial Media 286 Werimus Road Woodcliff Lake, NJ 07677 .3 Kyle.Ferreira@yahoo.com

Re: Exemption Request under Section 333 of the FAA Reform Act

To Whom It M ay Concern,

I would like to begin my petition by introducing myself to you so that you understand my background and concerns with safety and operation of a UAS. I have been involved with remote controlled aircraft s for over 10 years, and in that time have operated various types from fixed wing to single and multi

- rotor platforms. As a hobbyist, I have flown in a variety of locations, and with the integration of first

- person -view (FPV) cameras, I have come to love the breathtaking views that it provide s. The moment that I printed out my first aerial panoramic picture of my house, I knew that this would be a service that millions would want, and I would love to provide that service . The ability to view areas and properties from the perspective of a bird is simply awe

- inspiring. I have been involved in public service for over 12 years and am currently a full

- time police
officer, as well as a volunteer fire

-fighter/ EMT . The sole existence of my career has been to help people and to ensure their safety. I have taken this concept into my personal life, especially when I operate any UAS. Prior to the NPRMs regarding commercial UAS operat ions, I had already completed FAA

- approved ground schooling for my Private Pilot’s License, and passed the Airmen K nowle dge Test. Although I understand the classes do not improve your remote controlled operational skills regarding the flight of the UAS, I wanted to become extremely knowledgeable regarding Nationa l Air Space and FAA regulations so that I was able to operate in safe manner, away from any manned aircraft or other safety
concerns. Currently, I own the DJI Inspire 1 quadcopter. With this platform, I have logged over 500 hours of flight as a hobbyist. I feel that this is a great machine, and allows me to feel com fortable operating it due to its multiple safety features including a failsafe return to home, vision positioning system, and preprogrammed “no

-fly zones” . The technolo gy that the Inspire possesses would be a great tool to the public as I can provide them with a multitude of services including videography and still photography that the average resident may not be able to afford

. My petition is modeled after the Douglas Trudeau exemption (Docket #:2014

- FAA

-0481 Exemption #:11138) which has proposed many of the same uses and safety measures that I address. My petition is also the same m odel UAS and has the same potential uses as e xemption numbers: 11418,11314, 11359, 11342, 11323, 11336, 11398, 11416, 11384, and 11385

. At this time , I would like to begin

my formal petition for exemption to operate a UAS.

To the Federal Aviation Administration,

I, Kyle Ferreira , the owner of Bergen County Aerial Media, hereby request exemption from the following subsections of Title 14 of the Code of Federal Regulations (1 4 CFR):

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 14 CFR 61.113 (b) 14 CFR 91.7 (a)
14 CFR 91. 9 (b) 2
14 CFR 91.103
14 CFR 91.109
14 CFR 91.121 14 CFR 91.151 (a)
14 CFR 91.203 (a) 14 CFR 91.203 (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) 1 14 CFR 91.409 (a) 2 14 CFR 91.417 (a) 14 CFR 91.417 (a)

I support my request with the following information: My intention is to operate the DJI Inspire 1 quadcopter. The Inspire 1 is comprised of a multirotor unmanned aircraft and a portable ground stati on. The Inspire 1 is a quadcopter that does not exceed 55lbs (including payload). It is equipped with four model “DJI 3510” motors, powered by a six celllithium

- ion battery that has a maximum airspeed of 22 m/s. The Inspire 1 has a high definition camera

that is capable of producing high definition videos and still pictures. My inten tions are to use this camera to photograph aerial views that cannot normally be achieved without an aircraft. I plan to then provide these pictures to various clients including : real estate agents, private home owners, and commercial businesses. As stated before, my primary concern is the safety of any individual , structure, or craft on the ground, or anywhere in National Air Space. I plan on adhering to all of the operational
recommendations of the manufacturer, as well as enhancing them by the following set of Operational Guidelines: 1.) The UAS will weigh less than 55 lbs. (including payload) 2.) F lights will be operated within v isual line of sight of the Pilot in Command (PIC) and/ o r the visual observer (VO). 3.) The PIC and VO will be in constant communication by voice, or by radio. 4.) The PIC will hold either an airline transport, commercial, private, recreation, or s port Pilot s license, with either a FAA second class Airman medical certi ficate or higher; or a valid U.S. driver’s license issued by the State or Federal Government. 5.) The PIC must have a minimum of 20 hours of flight time operating the UAS. 6.) Maxim um flight time will not exceed 20 minutes in duration. Flights will be terminated w hen the battery reaches a 30% level, or 20 minutes in duration, whichever comes first. 7.) Flights will be operated at an altitude of no more than 4 00 feet above ground level (AGL). 8.) The PIC will utilize the UAS’s global positioning system (GPS) flight safety feature so if communications are lost between the radio and UAS, the craft will slowly hover, return to a predetermined location, and safely land autonomously

. 9.) The PIC will contact the respective airport if operations will be within a 5 miles radius, and w ill provide them contact information as well as flight times, durations, elevations, and other pertinent information. 10.) The PIC will o perat e the UAS in reasonably safe environmen ts that are strictly controlled and where prior authorization has been granted. 11.) The PIC will o perate in areas where a thorough preflight size up has been conducted to identify power lines, elevated lights, airports, actively populated areas, or any other potential hazard

. 12.) The PIC will o perate only after conducting an extensive preflight checklist, where the UAS and ground station have been inspected following the strict set of protocols, during which safety is a primary concern. 13.) The PIC will h ave an emergency procedure in place to abort flights in the event of an unsafe condition or potential danger.

In regards to 14 CFR Part 21 subpart H (Airworthiness Certificates ) this subsection establishes the procedural requirements for the issuance of airwort hiness certificates as required by FAR §91.203 (a) (1) . Given the DJI Inspire 1’s size, weight, maximum air speed, and limited operating area where the aircraft will be utilized, an exemption meets the requirements for level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333). I request an exemption 14 CFR 45.23

- Marking of aircraft, due to the fact that the UAS does not have an entrance to the cabin, cockpit or pilot station on which the word “experimental” can be placed.Also, due to the size of the UAS, two inch lettering would be impossible. Regardless, I will place the word

“experimental” on its fuselage as required by § 45.29 (f) so that the PIC or anyone assisting him as a VO or spotter will see the markings. 14 CFR 91.405 (a ), 14 CFR 91.407 (a)1, 14 CFR 91.409 (a) 2, 14 CFR 91.417 (a), and 14 CFR 91.417 (b) state that maintenance inspections may be required for civil aircraft. This exemption should be granted since they only apply to an aircraft with an airworthiness certifica te. In order to ensure that the UAS is constantly airworthy and safe, I will perform a thorough preflight checklist/ inspection of the UAS as outlined in my operational documents. I will also follow all recommendations of the manufacturer’s maintenance man ual. 14 CFR 61.113 (a) and 14 CFR 61.113 (b) state s that no persons who holds a private pilot’s certificate may act as Pilot in Command of an aircraft carrying passengers or property for compensation or hire. I am seeking an exemption to this since my UAS does not carry any pilots or passengers. Although helpful, a pilot’s license will not ensure remote control piloting skills. The risks associated with the operation of my UAS is extremely less than the risk levels associated with commercial activities out lined in 14 CFR 61. 14 CFR 91.7(a) is a regulation that requires that no person operate a civil craft unless it is in airworthy condition. Due to there not being an airworthiness certificate issued to my UAS, this would not be possible. The size of the ai rcraft, as well as the strict safety checklist and inspection that must be performed before each flight will ensure that the UAS is the equivalent level of safety. 14 CFR 91.9 (b) 2 requires that No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any comb ination thereof. Given the small size of my UAS, it has not place to store such a flight manual on the aircraft. The equivalent safety/ flight manual will be stored with the PIC on the ground in case of an emergency. 14 CFR 91.103 requires that each PIC t akes certain actions prior to each flight, to ensure the safety of the flight. I am requesting an exemption and will require that the PIC take all the necessary preflight actions, including but not limited to: reviewing the weather patterns, reviewing battery requirements, ensuring a safe take off/ landing zone, and completing a thorough preflight checklist prior to each flight. 14 CFR 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight i nstruction unless that aircraft has fully functioning dual controls. The UAS by design only has one set of controls to operate. The equivalent level of safety is provided by the fact that of UAS’s size and speed, as well as not be carrying any pilots or pa ssengers. 14 CFR 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” The DJI Inspire 1 does not have an altimeter, but instead a GPS altitude reading that is calibrated to the point of takeoff. An equivalent level of safety will be achieved by the PIC by confirming the altitude at the point of takeoff

.14 CFR 91.151 (a) prohib its an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– ( 1) During th e day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery of the DJI Inspire 1 provides approximately 25 minutes of powered flight thus making it impossible to meet the 30 minute reserve requ irement in 14 CFR 91.151 . Given the limitations of the UAS proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Maximum flight tim e will not exceed 20 minutes in duration. Flights will be terminated when the battery reaches a 30% level, or 20 minutes in duration, whichever comes first.

In a world that is pushed forward by technology, UAS’s are becoming more prevalent in today’s society whether they are used for hobbyist or commercial purposes. Everyone from realtors to commercial businesses are interested in the views from the air, but to small businesses, the expense of hiring a private airplane or helicopter is cost prohibitive . Granting an exception to me will allow this service to be provided to these interested parties at a much lower cost, and will have a greater impact on the society around me. I feel that not only will my photos and video have a positive effect on the clie nts I do business with, but also the community at large when they learn of the safety procedures that I have implemented.

Your consideration in this matter is greatly appreciated.

Respectfully Submitted,

Kyle Ferreira Bergen County Aerial Media