16 September 2015

Hon. Michael Huerta Administrator Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs. Dear Administrator Huerta: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Troy A. Balding (or the "Petitioner"), hereby applies for a summary exemption from the listed Federal Aviation Regulations ("FARs") to allow him to operate small Unmanned Aircraft Systems ("sUAS") for aerial data collection, under the conditions and limitations set forth in this Petition. The requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would provide safety enhancements to the already safe news gathering operations presently using manned helicopters and airplanes. Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator's responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. 

### The name and address of the applicant and his Counsel: Troy A. Balding 9558 Beauclerc Cove Road Jacksonville, FL 32257 386-216-8407 satroyb@gmail.com 

### Regulations from which the exemption is reguested: 14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.3 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C. F. R. § 91.103 14 C. F. R. § 91.109 14 C. F. R. § 91.119 14 C.F.R. § 91.12114 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 3 The Appendix describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption. The Petition is submitted to fulfill Congress' goal under Section 333(a) through (c) of the Reform Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Administrator must determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: • The sUAS's size, weight, speed, and operational capability; • Operation of the sUAS in close proximity to airports and populated areas; and • Operation of the sUAS within visual line of sight of the operator. Reform Act § 333 (a). If the Administrator determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. § 333(c) (emphasis added). The Secretary has delegated his aviation authority to the Administrator of the FAA. The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1). 

### Summary of Repuest: As a(ong time radio control pilot, I am requesting an exception, and permission to use my sUAS, DJI Phantom 2 Vision (further in this report are the detailed specifications of the sUAS), for the purpose of taking aerial photos and videos for commercial interests in providing services to clients using a small advanced sUAS in the following areas: Real Estate, Marketing, Land Management/Surveying, and Special Events. AII sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the sUAS' radius during filming and photography applications.Why the exemption would not adversely affect safety:

This can be done very safely in a controlled environment, on private property, with limited airtime required, extremely low noise, in uncongested areas. The sUAS will always be operated in a Visual Line of Sight (VLOS) environment, with an observer, and always under 400 feet. Prior to flight, I go through a"pre-flight" checklist: 1. verifypropellers are properly secured and not damaged. 2. ensure all batteries are fully charged a. sUAS battery b. Transmitter/controller battery c. Wi-Fi range extender battery 3. turn on transmitter &range extender 4. turn on sUAS battery S. initiate a"calibration" procedure for the Compass 6. place sUAS in a safe position on the ground for takeoff 7. turn motors on 8. verify there are 6 or more satellites acquired 9. initiate takeoff 10. hover at 10-15 feetand verify all controls are operating properly 11. initiate flight plan, as required 12. upon completion of flight plan, ensure a safe environment exists for a safe landing, and inspect sUAS prior to another flight for air worthiness Description of sUAS: The DJI Phantom 2Vision (sUAS) operates on 5.8 GHz, and weighs 2.7 pounds. Serial # PH645426151. It has a very sophisticated flight control system (DJI NAZA—M V2), and includes a Gyro, Compass, GPS, and camera that is on a single axis gimbal. The flight system includes a"Failsafe" function, where if signal is lost, or interference occurs with the controller, or it fly's out of range, the sUAS will automatically return to its "home" position. It also provides altitude & radius flight adjustment settings, for maximum height and distance. It will also "altitude hold- auto hover" if radio control sticks are released. And, in order to increase flight safety and prevent accidental flights in restricted areas, the new firmware for the Phantom 2 series includes a"No Fly Zone" feature. These zones have been divided into two categories: A- large international airports and, B- small local airports. http://wvti''v'v.dji.corn/fiy-sa-e/cG;e-cr•

. Exceeding the control range of the remote control will trigger'Return-to-Home', meaning the Phantom 2 Vision will automatically fly back to its takeoff point and land safely. Using Wi-Fi and a Wi-Fi Range Extender, the camera transmits live video to my Apple iPhone 6 Plus or Samsung Galaxy S3, all of which comply with FCC requirements. The DJI Vision App shows, altitude, direction of flight, distance from home, speed, location, number of satellites acquired, and battery level.

### Pilot in Command (PIC) Backpround and experience:

I have approximately 5 years experience in flying radio control and wire controlled sUAS aircraft. My current inventory totals 3 electric aircraft. Furthermore, I have over 6 years active duty as a Naval Flight Officer flying on the P-3C Orion, so I am thoroughly familiar with flight rules, regulations, and the importance of checklists. I am still active duty, have over 1,350 flight hours, and still in a flying status. I have always been intrigued with any new technology, and generally have always been an early adopter. I would like to take advantage of my hobby skills, in a commercial way, and help generate interest within the general public in the safe application of sUAV's. I have been into video and photography, as a hobby, my entire life. This new technology ties together, both of my long time hobbies. I am currently in process of getting my Sport Pilot Certificate, and I hold a valid driver's license from the State of Florida. 

### Whv the public would be served by arantinp this exemption: I believe this is a technology that can benefit realtors and commercial businesses, in a huge way. The industry is anxious to have this technology enhance their ability to market properties from a totally new perspective, because the aerial perspective is very impressive. By increasing their marketing potential it can increase home sales, benefiting Realtor, buyer and seller. For the commercial business owner, that new aerial perspective can increase market awareness and growth, with greater recognition of business message, physical presence, inventory (in the case of an auto dealer) and location. The Petition to use a sUAS for aerial data collection and its proposed limitations are similar in all material respects to those approved by the FAA in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213 to Aeryon Labs, lnc. (see Docket No. FAA-2014-0642) and 11310 to Colin Hinkle (see Docket No. FAA-2014-0608). In those grants the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the Petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the sUAS operation enabled by this exemption is in the public interest. The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, and 11310 also apply to the situation presented by this Petition. Very respectfully,
roy A. Balding

### APPENDIX

FAR section 14 CFR § 45.23(b)

14 CFR Part 21

14 CFR § 61.3

14 CFR § 91.7 (a)
14 CFR § 91.9 (b) (2)
14 CFR § 91.103(b)
14CFR§91.109 Subiect Requirement to display registration number on vehicle Aircraft certification requirements and procedures Requirement for pilot Certificate

Airworthiness requirement
Requirement for manual to be available in the cockpit Requirement for crew members to be onboard Requirement for dual controls during flight instruction Justification Insufficient space on vehicle
Designed for manned aircraft; not suitable for off the-shelf sUAS Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for sUAS operator Designed for manned aircraft; not suitable for off the-shelf sUAS No one aboard to read manual Unmanned vehicle
No one aboard to operate controls
14 CFR § 91.119
14 CFR § 91.121
14 CFR § 91.151(a) 14 CFR § 91.203 (a) & (b) Minimum altitudes for safe Flight Altimeter settings
Fuel requirements Requirement for registration and airworthiness certificates to be onboard Safety requires operation below these altitudes No one aboard to read altimeter Vehicle does not use fuel No one aboard to read certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; not suitable for off the-shelf sUAS 14 CFR § 91.407(a) (1) Inspection approva) Designed for manned Requirements aircraft; not suitable for off the-shelf sUAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for off the-shelf sUAS 14 CFR § 91.417 (a) &(b) Maintenance records Designed for Requirements manned aircraft; not suitable for off the-shelf sUAS

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