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. § 91.121 
14 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 read 
14 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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