Coast 2 Coast Aerial Imaging

Owner: Matthew Peterson 2207 Camryn’s Xing Panama City, FL 32405 Ref: Exemption Request Section 333 of the FAA Reform Act Dear Sir or Madam: Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 CFR Part 11, Coast 2 Coast Aerila Imaging (Matthew Peterson), Owner of an Unmanned Aircraft System (UAS), Hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow Coast 2 Coast Aerial Imaging to legally operate its DJI Phantom 3 UAS, so long 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 proposed exemption would allow Coast 2 Coast Aerial Imaging to operate a small UAS under controlled conditions in FAA regulated airspace that is 1) limited 2) predetermined 3) controlled, for purposes of unmanned aerial photography and videography. If the exemption is granted, Coast 2 Coast Aerial Imaging will conduct commerc ial UAS flights following all conditions set forth by the FAA Section 333 with emphasis on safety and operational requirements. Proposed Operations of Coast 2 Coast Aerial Imaging UAS

• Real Estate Photography

• Golf Course Photography

• Commercial Property Construction

• Aerial Inspection



### • Special Events Coast 2 Coast Aerial Imaging will follow all FAA UAS Safety Operating Guidelines including but not limited to the following. ● The UAS will operate no more than 200 feet above ground level and within a radius of 1000 feet of Pilot in Command (PIC) and will not exceed 35mph. ● Operations will only occur during daytime conditions abiding by Visual Flight Rules (VFR) within Visual lin e of sight (VLOS) of the UAS pilots at all times. ● Obtain permission from the owner or representative of the owner to conduct operations ○ If operations occur within 500 feet of any vessel, vehicle, or structure, a safety assessment will be conducted

. ● Flight times will be limited to 10

- 15 minutes per flight. Allowing 25% of total battery battery to be used to safely land the UAS. This exceeds the manufacturer's recommended minimum battery levelparameters for “return to home” function. ● DJI Phantom 3 utilizes Global Positioning System (GPS), which will automatically land (return to home) the UAS in any cases where Communication between PIC and craft is lost or the battery levels reach a critical level. ● DJI Phantom 3 also has “return to home” button on controller. ● Contact Airports if operations are within a 5 mile radius. Advise Airports of all pertinent information including but not limited to: time of flight, flight duration, elevation of flight. ● Only operate UAS in s afe weather conditions. Unsafe conditions include, but are not limited to high wind, poor visibility, low clouds or any conditions that may cause the pilot to lose VLOS or control of the UAS. This will be achieved by:

○ Obtaining and reviewing weather reports prior to flight ○ Procedures for a mid

-flight abort in cases where weather or other factors cause conditions to become unsafe or dangerous. ● Only operate in controlled environment ○ W ill have procedures in place to identify and avoid any hazardous areas such as power lines, street lights, trees, airports, densely populated areas (yellow areas on VFR charts) o Wi ll have procedures in place to abort flights that have safety breaches or dangerous issues. ○ Wi ll always operate UAS with 2 p eople, with a designated “visual observer (VO)” who will also keep constant Visual Contact with UAS along with PIC. ○ Wi ll have policies that will clear the operational flight area of any non - essential personnel. ● Wewill conduct extensive prefl ight inspections on the UAS, utilizing procedures that will check integrity of all operational parts including but not limited to: propellers, aircraft antenna, aircraft LED lights, remote buttons, control sticks, signal strength between craft and remote, signal strength of GPS, battery strength. ● Wewill follow guidelines of 14 CFR 61.51(b) along with our own safety operation procedures.

○ The PIC will have a minimum of 6 hours logged operating the craft before commercial use, along with over 10 hours operating UAS quadcopters in various conditions and environments. ○ Wi th emphasis on safety, we will have training procedures that include emergency landing, evasive maneuvers and other possible dangerous scenarios such as yielding the right away to any airplane or helicopter that comes within 5 miles of the operating UAS. 

### REGULAT IONS FROM WHICH AN EXEMPTION IS REQUESTED: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14CFR 45.29; 14 CFR 61.113(a) and(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91 .103; 14 CFR 91.109; 14

CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) an d (2); 14 CFR 91.417(a) and (b) **14 C.F.R. Part 21, Subpart H: A irw**  **orthiness Certificates 14 C.F.R . 91.203 (a)**  **(1) Subpart H, entitled A irw**  **orthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as**  **required by**

**FA R 91.203 (a) (1 ).**  Given the size and limited operating area associated UAS, an exempt ion from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 333 of the Reform Act. Federal Aviation Act (49 U.S.C.4470 1 (f)) and 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated wit hout an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restricti ons and conditions of proposed UAS operations. The UAS to be operated by Coast 2 Coast Aerial Imaging is less than 55lbs. Fully loaded, carries neither pilot, nor passengers, carries no explosive or flammable materials including combustible fuels, and ope rates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be controlled and monitored by both the pilot (PIC) and “visual observer(VO)” as a secondary monitor for safety issues, and a technician, which assis ts in matters related to maintaining the UAS and also monitors for safety concerns. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no intrinsic credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to car ry a substantial external load. **14 CFR 45.23(b) Display of marks; general and 45.29 Size of marks**  These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit , or pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be placed. W e propose an equivalent level of safety by including the word "EXPERIMENTAL" on the top and bottom of the aircraft, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. W e will display at the ground station a high contrast flagor banner that contains the words "Unmanned Aircraft Ground Statio n" in letters

4 inches high or greater. The banner will be visible to anyone that observes the aircraft and chooses to i nvestigate its point of origin. **14 CFR 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command** Coast 2 Coast Aerial Imagin g requests an exemption from the private pilot privileges and limitations of 61.113 (a) & (b): Private Pilot Privileges and Limitations: The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. The UAS aircraft cannot carry passengers or property, th erefore an exemption is needed. **14 CFR 91.7(a) Civil A ircraft Worthiness**  Coast 2 Coast Aerial Imaging requests an exemption from 91.7(a) which p rohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, t his regulation is inapplicable. **14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.** Coast 2 Coast Aerial Imaging requests an exemption from 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. Webeli eve an equivalent level of safety will be achieved by maintaining a safety/flight manu al with the UAS ground station. **14 CFR 91.103 PIC to become familiar with specific information before each flight**  Coast 2 Coast Aerial Imaging requests an exemption fro m 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA approved Flight Manual on board the aircraft. As an FAA approved flight manual will not be provided for the UAS, an exemption will be needed. The equivalent Level of Safety will be achieved by following the DJI manufactures aircraft manual with comprehensive preflight checklist. Other comprehensive preflight information gathering and interpreting will be done by the PIC utilizing weather reports, web based mapping (Google earth) battery requirements, determining safe takeoff and landing areas. All pertinent information will be gathered and interpreted by PIC before any flights. **14 CFR 91.109 Flight Instruction** Coast 2 Coast Aerial Imaging requests an exemption from the 14 CFR 91.109(a) which provides that person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully UAS and remotely piloted ai rcraft, by their design do not have fully functional dualcontrols. The control box communicates with the UAS through radio

communications. Equal levels of safety will be achieved based on the size and speed of UAS an equal level of safe training can be a chieved without the “dual controls”because the UAS is unmanned and all essential personnel will be a safe distance away in the event of difficulties during the flight. **14 CFR 91.119 Minimum safe altitudes** Coast 2 Coast Aerial Imaging requests an exemptio n from the minimum safe altitude requirements of 14 CFR 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

- congested areas. See 14 CFR 91.119(c). Section 91.119(d)(1) allows for a hazard to persons helicopter complies with any routes or altitudes specific ally prescribed for helicopters. **14 CFR 91.121 Maintain cruising altitude or flight level by reference to an altimeter**  Coast 2 Coast Aerial Imaging requests an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the UAS does not have a barometric altimeter, but the Phantom 3 software has a GPS altitude meter display. PIC will use display to constantly monitor altitude during the flight. **14 CFR 91.151(a) F uel requirements for flight in VFR conditions**  Coast 2 Coast Aerial Imaging requests an exemption from 14 CFR 91.151(a) fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VFR conditio ns 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 the 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 powering the Phantom 3 UAS provides approximately 20 minutes of powered flight. An exemption from the 30 minute reserve requirement in 14 CFR 91.151 is therefore required. Equal levels of safety can be achieved by limiting flight times to approximately 10

- 15 minutes or until 25% of battery life remains , whichever comes first. This is more than enough battery p ower to achieve a safe landing. **14 CFR 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a)&(b) Maintenance an d**  **inspection standards in reference to 14 C.F.R. Part 43.** Coast 2 Coast Aerial Imaging requests exemptions from these regulations because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the UAS will not have. Coa st 2 Coast Aerial Imaging will achieve an equivalent level of safety because maintenance and inspections will be performed in accordance with the DJI Phantom 3 Aircraft Operations Manual.The operator will ensure that the UAS is in working order prior to i nitiating flight,

perform all required maintenance, and keep a comprehensive log of any maintenance performed on UAS. The UAS small size, carrying capacity, and the fact that flight operations will only take place in controlled areas for limited periods of time, create less risk than the same factors associated with conventional fixed

-win g aircraft and rotorcraft performing the same operation. 

### Public Interest & Safety The enhanced safety of small unmanned UAS eliminates the greater risk alternatives when u sing larger manned aircraft, carrying fuels at low altitudes. In addition this relatively new technology provides clients access to photographic and videography services and information that were previously not financially cost effective. Conducting aerial acquisitions with a UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power an d electric motors, our UAS will produce no air pollution, and is the most viable environmentally conscious alternative to the internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 3 0 gallons per hour of leaded aviation fuel. Our UAS, while reducing the carbon footprint during flights, will also eliminate noise pollution, as the UAS is propelled by a battery powered electric motor, rather than an internal combustion engine. The FAA, by granting the Coast 2 Coast Aerial Imaging’s exemption request, will serve to stimulate development of viable commercial UAS operations while guiding the public's understanding of how UAS can be legally and beneficially integrated into the National Air S pace, NAS. 

### UAS Overview Coast 2 Coast Aerial Imaging will operate the DJI Phantom 3 Professional ● Dimensions ○ Size

-40.36cm x 40.36cm x 19.05 x or 16inch x 16inch x 7.5inch ○ W eight

- 1280g total or 2lbs 13oz total ● Speed ○ Under still air maximum speed is no more than 16m/s or 35mph with a cruising speed of 11m/s or 25mph ● Motors ○ 4 motors total ○ Motor model DJI 3510 ● Power ○ 4480mAh 4s LiPo Lithium Polymer Battery ● Propellers ○ Model DJI 1345 ● Remote Controller○ DJI issu ed C3 remoter controller ○ Operating frequency

- 2.400GHz

- 2.483GHz ○ Live Video frequency

- 2.4GHz ISM (max range

- 1.2 miles) ● Operation Parameters ○ Coast 2 Coast Aerial Imaging will operate the UAS with visual line of sight within a closed off pre - determined area; W ith authorization of the property owner or representative. 

### DJI Phantom 3 GENERAL FEATURES

● Ready to fly ● Precision flight and stable hovering ● GPS/GLONASS positioning and auto return home ● FAA no

-fly zones lo cked out via DJI installed software ● Onscreen real

-time flight parameters ○ High Definition 4k camera ○ 3 Axis camera stabilization ○ Adobe lens profile support ○ Album synchronization ○ DJI VISION APP

- System requirement of Mo bile Device: iOS version 6.0 or above/ Android system version 4.0 or above ● CAMERA ○ Operating Environment Temperature

- 0 degrees C to 40 degrees C ○ FOV

- 94 degrees/85degrees ○ Sensor Size

- 1/ 2.3” ○ Max Resolution

-4096x2162p @24/25 fps ● TRANSMITTER ○ Communication Distance (open area)

– CE: 2000m; FCC: 2000m○ Transmitter Power

- CE: 16dBm; FCC: 20dBm ○ Operating Frequency

- 2.400 GHz

- 2.483 GHz ○ Receiver Sensitivity (1%PER) :

- 101dBm +/

- 2dBm ○ Battery

- 6000 mAh LiPo 2s ○ W orking Voltage

- 1.2A @ 7.4V 

### Conclusion Coast 2 Coast Aerial Imaging is confident that with the strict safety standards set by Coast 2 Coast Aerial Imaging , the FAA, and the physical safety properties of the UAS, all proposed operations will meet or exceed the Reform Act’s safety requirements . Granting the present Petition will further the public interest by allowing Coast 2 Coast Aerial Imaging to safely, efficiently, and economically perform aerial video and photograph y of client sites, events, and landscape over certain areas of the United States. Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Coast 2 Coast Ae rial Imaging’s proposedoperation of the UAS will be realized without implicating any privacy issues.

Manuals and Specifications:

- DJI Phantom 3 Professional User Manual

- http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professio nal_User_Man ual_v1.2_en.pdf Please see attached document (Pre

- Flight Safety Checklist) I would like to thank you for your consideration in granting the exemptions mentioned in this document. If additional information is required or if you have any ques tions please contact Matthew Peterson , 805

- 204

- 1239 owner of Coast 2 Coast Aerial Imaging. Thank you, Matthew Peterson Caost 2 Coast Aerial Imaging Matt@c2caerialimaging.com