April 2 8 , 2015

DronEye Imaging, LLC 5127 S 200 W Trafalgar, IN 46181 Cell ( 317 ) 443

- 7013 Cell ( 317 ) 748

- 8696 Email: bpfaeh@gmail.com meb2461@gmail.com U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 2059 RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1
. Phantom 2 Vision Plus (Quick Start Guide) 2
. Ph antom pilot training guide V1.1 3
. I nspire 1 Quick Start Guide V1.2 References: 1. FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU 2. FAA Exemption No. 11136, Regulatory Docket No. FAA
–2014
–0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3. FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

-0355 in the matter of the petition of FLYING CAM INC
Dear Sir or Madam, In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, DronEye, LLC, referred to hereafter as the petitioner, request s exemption from the following sections of Title 14, Code of Federal Regulations §§ **61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91. 405(a); 91.407(a)(1); 91.409**  **(a)(1); 91.409(a)(2); 91.417(a) & (b);**In order to operate small unmanned aircraft systems (UAS ’s ) commercially in airspace regulated

by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, mapping, crop surveying, inspections and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manne d aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So lon g as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1

- 3. **The Federal Aviation Regulations (FARs)**  The petitioner seeks exempti on from the above mentioned FARs for the following reasons; **Section 61.113**  **(a); 61.113**  **(b)** Th e petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions. **Section 91.119(c)**  As referenced in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner re quests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. **Section 91.121**  As referenced in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altim eter and instead utilizes electronic GPS with a barometric sensor for altitude information. **Section 91.151(a)**  As referenc ed in Exe mption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for man ned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption numbers 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 2 0 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initi ate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of thoseproposed operations, the FAA found that a reduced minimum power reserve for flight in

daytime VFR conditions wa s reasonable. **Section 91.405(a); 91.407(a)**  **(1); 91.409 (a)**  **(1), 91.409(a)(2); 91.417(a); 91.417 (b)**  As referenc ed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherenc e to the petitioner’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and record keeping, were s ufficient to ensure that safety would not be adversely affected. **UAS ’s** **; DJI Phantom**  **2 Vision Plus or**  **DJI Inspire** The requested exemption would permit commercial operation of DronEye, LLC’s UAS's, which weigh b etween 5 and 15 lbs. and perform precision services that consist of high quality still photographs and videography taken by onboard cameras. UAS’s for aerial services reduce the need to utilize conventional manned aircraft s for the same purpose a t a fraction of the cost; additionally, UAS’s services can provide an increase in efficiency and productivity for the affected activities and a decrease in fuel emissions providing environmental benefits. Operations under the exemption will be subject to strict operating requirements and conditions to ensure , at minimum, an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333. The UAS's will be operated under controlled conditions at low altitu de in airspace that is limited in scope, as described herein; it will have automated control features, as described in the attached manuals. The UAS’s also will be operated by an individual who possesses an FAA Private Pilot Certificate and valid US Driver’s License. Finally, the airspace in which the UAS will operate will be Class G airspace or airspace approved by the FAA in advance. Approval of these exemptions would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administ rator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.” The petitioner has re viewed FAA exemptions reference s 1

- 3 Conditions and Limitations section and agree s that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UAS’s airworthiness will be verified prior to each launch. The petitioner request that in a manner similar as described in reference 3, he be allowed to operate within 5 mi les of an airport provided that:

“ The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and th e operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request .”Operations within 5 miles of an airport are not anticipat ed to be routine but the petitioner is

requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder

. **Public interest** Use of the UAS’s in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft s . Additionally, use of the UAS’s in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displa yed through ground level photography or videography. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an inde pendent contractor; a visual observer will be utilized. Liability insurance will be ob tained commensurate with the granting of this request for exemption. D ata may be submitted to FAA by traditional means, e.g. COA Monthly Reports, or other means as required or requested

. **Conclusion** The petitioner is requesting this exemption for the purpo ses of “aerial photography, cinematography, videography, mapping, crop surveying, inspections and other flight operations”. The petitioner's business model is of the idea of offering ad hoc small UAS’s services to individuals or business entities who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. C urrently, many other UAS operators are conducting business in exactly as described above without FAA authorization. The petitioner has refrained from engaging in commercial use of the UAS’s . The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. The petitioner possesses a Private Pilot Ce rtificate and has over 20 years of experien ce in the RC hobby and aviation.

Respectfully submitted ,
DronEye, LLC Brian A. Pfaehler (Private Pilot Certificate #311026853) Mark E. Bentley