U.S. Department of Transportation August 10, 2015

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, James Powers, seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for (1) DJI Inspire 1 q uadcopter manufactured by DJI Innovations. The requested exemption would support an application for a commercial Certificate of Authorization to use the system to support aerial photography and videography. The DJI Inspire 1 (6.5lb) consist of a battery operated aircraft, a tablet
- based ground control station and/ a RC Controller, and associated communications equipment. The aircraft carries an onboard geo
- referenced gimbaled camera that allows it to obtain photography and videography. The Unmanned Aircraft System will be op erated in the field with a PIC in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS". James Powers respectfully requests the grant of exemption allowing to operate lightweight, remote controlled UAS's lawfully and safely. James Powers also respectfully requ ests Exemption Request Section 333 from (but not limited to) the Specific Sect ions of Title 14 of the Code of Federal Regulations and part ll of the Federa l Aviation. Regulations listed below. 14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121~ 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b) The extent of relief James Powers seeks and the reason why: James Powe rs is seeking relief from an y applicable FARs operating to prevent James Powers from conducting a erial photography of real estate and other possible legal flight operations including cinematography, videography, mapping, surveying, inspections and other fl ight 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 manned aircraft . T he weight of the UAS meets the definition of ''small unmanned aircraft” fo und in section 331 "The Reform Act”. James Powers seeks to operate le gally as a small business that cater mostly to real estate agents. Realtors are not allowed to use UAS's or hire unless they or the person they hire, is allowed by the FAA to fly a UAS. James Powers would satisfy the need for safe and affordable aerial shots.At less than 7 pounds, James Powers uses UAS that is considerably less than 55 pounds including the

camera tha t is attached. The UAS will be used at speeds under 35 mph because of the nature of the business and the limited physical capabilities of the UAS. It is designed to hover and take pictures. The UAS will be in accordance with flying well below 400ft. The UAS in which James Powers would be using only utilizes battery power for its operations. There are no com bustible fuels used in the UAS that James Powers uses. The maximum flight time for our particular UAS is 20 minutes battery life. It will fly n o more than 15 minutes maximum at one ti me at one location. The amount of ti me the UAS will be in the air, less than 400ft, is very minimal. A Safety system in place for James Powers UAS includes a GPS mode that allows the UAS to return home if commu nication is lost. Further, the GPS onboard allows the UAS to return back to its launched position if the battery life of the UAS is low. THE GROUND STATION PART OF THE SYSTEM: A Pilot in Command (PIC) in operational cont rol of a flight operation from beginning to end and who controls the UAS w hil e in the air. Additionally, the line of site of the UAS will not leave the sight of the PIC. A 2.4GHz radio transmitter/controller operated by the PIC to control the U.AS while in flight; A radio receiver receiving live video, and flight data from the on
- board camera and computer. It projects it all in one screen to the Pilot in Command . The UAS, weighing less than 7lbs fully loade d, is powered by batteries and operates with no people on board which lowers the likelihood of death or serious bodily injury. With a small payload consisting of harmless electronics such as a camera and GPS, the UASs only purpose is to be used as a tool to take pictures and videos. Low level aerial photos and video from several angles are far more effective than ground based ph otos. Low l evel aerial video and pictures show the layout of properties with the a dvantage of seeing more in one photo or short video. Current applicants have used helicopters and small planes for this purpose but the cost of fuel, time, and emissions of such aircraft is not efficient enough for most customers to afford. The benefits of reduced cost and improve d efficiency of the UAS allows future customers to afford this service with a faster turnaround time at a lesser cost. Additionally, I respectfull y request that JAMES POWERS be allowed to use the UAS to benefit possible first responders our local area for actions that could benefit the public. Such as, fires and search and rescue. James Powers will not operate a UAS ne ar airports and generally does not fly over crowds. Situational awareness is most important. The areas where James Powers conducts aeria l photography is predetermined which allows for a controlled environment to operate safely.With allowing James Powers to conduct business with a lig ht weight UAS, it could very well help the

econo my and benefit people in first response situations. Further, James Powers UAS is considerably lighter than the alternative which is a helicopter or small plane. Currently, James Powers has 1 UAS which only op erates off 20 minutes of battery power. Therefore, the UAS used by James Powers would only have a flight time of 5
- 15 minutes at one time. The likelihoo d of injury or even death with such a small unmanned aircraft, compared to an aircraft flown by a pers on loaded with combustible fuel, is considerably low . SUMMARY: James Powers is more than willing to follo w the safety guidelines of the FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS'1 with the appropriate exemptions for flying a small UAS. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenanc e logs to record time on failure prone components. A- No flight will be made with a UA Gross weight exceeding 55lbs B - All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of not more than 25 knots and no further t han 3/4 NM from the Pilot In Charge while always maintaining a Visual Line of Sight (VLOS). C- Operations will be restricted to flights over private property with the permission of the property owner D - All required permits will be obtained from state a nd local government prior to operation E - The UAS will not be operated over densely populated areas F - The UAS will not be operated at air shows G - The UAS will not be operated over any open
- air assembly of people H -The UAS will not be operated over he avily trafficked roads I -The UAS w ill not be operated within 5 NM of an airport or heliport The petitioner request that he be allowed to operate within 5 miles of an airport provided that; “The UA may not operate in Class B, C, or D airspace without wr itten approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non
-towered airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the 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 a nticipated 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 tra nsponder.J - Operations will be restricted to d ay only and weather conditions equivalent to VFR

K- The PIC will notify property owner about the operation and risk before the first flight at each new location; L- No flight may be made without a Pre
- Fligh t Inspection by the PIC before each operation to ascertain that the UAS is in a condition safe for flight . The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, videography, mapping, crop surveying, inspectio ns and other flight operations”. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on o pportunities as they ma y arise in the future without the long turnaround time associated with additional exemptions . My operations above are the bare minimum s afety guidelines James Powers will follow. James Powers is also m ore than willing to follow any additional safety requi rements if not listed above. James Powers believes flying its UAS as a smal l business within the safety parameters of the FAA, can help people and promote the economy. The name and contact information of the applicant is: James Powers 1825 NW 12 th ST Boca Raton, FL 33486 Phone: 954- 868 -4662 Email: jamespowers04@gmail.com James Powers respectfully requests th at the FAA grant its exemption request without delay. I very much look forward working together wit h you . Thank you for your time. Respectfully,

James Powers 954- 868 -4662