January 11,2016



### ••• Robert Voigt The Voigt Group, LLC 11414-CKingston Pike Knoxville, TN 37934 

## u.s. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200New Jersey Avenue, SE Washington, DC 20590 To Whom It 

### May Concern: In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under Section 333ofthe FAA Modernization and Reform Act of2012,I, Robert Voigt, Member of The Voigt Group, LLC,referred to as the Petitioner, kindly request exemption from the following sections ofTitle 14, Code ofFederal Regulations §§
14 CFR21 14 CFR45.23(b) 14CFR 61.113 (a) and (b) 14CFR 91.7 (a) 14CFR 91.119 14CFR 91.121 14 CFR 91.151.151 (a) 14 CFR 91.405 (a) 14CFR 91.407 (a) (1) 14CFR 91
.409 (a) (1) and (2) 14CFR 91.417 (a) and (b) The LLC will be operating a DJI Phantom 3 Professional Quadcopter. This exemption will allow The Voigt Group, LLC to operate an unmanned aerial vehicle commercially for the purposes of conducting aerial video and still photography in the Tourism, Real Estate, and Hospitality markets ofEast Tennessee. These still images and videos will provide both commercial and ROB@THEVOIGTGROUP,COM • (865) 560-6088 • WWW.THEVOIGTGROUP.COM

1 1414-C KINGSTON PIKE. KNOXVILLE, TN • 37934v • ' 

### ••• community awareness and understanding of aerial imaging systems. The Voigt Group, LLC is a real estate brokerage operating out ofKnoxville, TN; we additionally provide photography and videography for other real estate clients (both residential and commercial) and for peer businesses in our area. The Voigt Group, LLC will be using a DJIPhantom 3Professional Quadcopter (Model #W323)to commercially capture video stills and film while working on private and public properties for the purpose ofaerial photography and videography. The Voigt Group, LLC will employ both an experienced operator and utilize a visual observer to maintain a visualline-of-sight between the quadcopter and the SUAV operator. 

### THEDJIPHANTOM 3PROFESSIONAL QUADCOPTER The DJIPhantom 3 Professional Quadcopter is an electric powered quadcopter weighing less than three pounds; it is operated via ahandheld remote that features "Return to Home" and "Follow Me" commands. The Return to Home feature can be triggered manually and the UAV unit works offof a 2.4GHz downlink for remote control. The video function works on 5
.8 GHz frequency video. The default altitude setting for the DJIPhantom 3 Professional Quadcopter is 400feet AGL. The camera system is also operated from the handheld remote control. Both units are powered by a single battery, allowing for approximately 20minutes offlight time. 

### BASISFORPETITION The Voigt Group, LLC,pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. SS 11.61)and the F.A.A
. Modernization and Reformed Act of2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to operate the DJIPhantom 3Professional Quadcopter within the National Airspace System. We request exemption from the requirements of 14CFR SS61.113 (a) and (b), 91.7 (a), 91.119,91.121,91.151 (a), 91.405 (a), 91.407 (a) (1),91.409 (a) (1) and (2),91.417 (a) and (b)
. 

### NAMEAND ADDRESS OFTHEPETITIONER The Voigt Group, LLC Attn: Robert Voigt or Brittany Voigt 11414-C Kingston Pike Knoxville, TN 37934 

### THEVOIGT GROUP,LLCREQUESTSRELIEFFROM Section 21 That As Section 21, subpart H, Airworthiness Certification

This section details need for airworthiness certificate. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, an exemption from this section is warranted and

RobertVoigt • 2Section 45.23

That As

Section 61.113 That

As v • ' 

## ••• meets the requirements for an equivalent level of safety under 14 CFRpart 11 and Section 333ofP.L. 112-95 (Section 333). Marking of the Aircraft Applicable Codes ofFederal Regulation require aircraft to be marked according to certain specifications. The SVA is,by definition, unmanned. It does not have a cabin, cockpit, or pilot station on which to mark words or phrases. Two-inch lettering is difficult to place on such a small aircraft. Regardless, it will be marked in as large a lettering as possible as "EXPERIMENTAL" on its fuselage as required by 14 CFR45.29(f) so that the operator or any other member ofthe team may see the markings. The FAA has previously issued exemptions to this regulation through Exemption Nos. 8738, 10167, 10167 A and 10700. Entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) and (b). Regarding section 61.113 (a) and (b)Private pilot privileges and limitations: Pilot in Command, Subsections (a) and (b)prescribed the following, in part: (a)No person who holds aprivate pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b)A private pilot may, for compensation or hire, act as PIC 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 SVA will be operated by a trained operator that is versed in proper flight procedure and safety. The vehicle will be flown under favorable conditions and will not be flown near an airport or anywhere near any other aircrafts. We request a 120day temporary airman certificate to allow the FAA time to establish minimum VAS airman certification standards for these unmanned aircraft. The aircraft will carry no persons and will in fact carry nothing but a camera. The Petitioner will abide by VAS Operating Parameters, including • VAS will be operated below 300feet and within a radius distance of 1000feet from the controller to both aid in direct line of sight visual observation • VAS will be operated for 3-7minutes per flight • VAS will be landed prior to the manufacturer's recommended minimum level ofbattery power

Robert Voigt • 3Section 91.7

That As

Section 91.119 That

As

Section 91.121 That As Section 91.151 That As LI • ' 

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• VAS will be operated only within visual line ofsight (VLOS) • VAS's global positioning system (GPS)flight safety feature will be utilized, whereby ithovers and then slowly lands if communication with the remote control pilot islost • VAS operations will be conducted under flight safety protocols (including posting a warning sign reading: /IAttention Aerial Photography in Progress - Remain Back 150feet"). Petitioner will actively analyze flight data and other sources ofinformation to constantly update and enhance safety protocols • Respective airports will be contacted ifoperations will be within 5 miles to advise ofestimated flight time, flight duration, elevation offlight and other pertinent information • Necessary permissions will always be obtained prior to operation • Procedures will be set inplace to abort flights in the event of safety breaches or potential danger. Entitled Civil airworthiness subsection (a). Regarding prohibition ofoperating an aircraft without an airworthiness certificate This regulation isinapplicable to our operations, being no current certificate is applicable to this situation. Irequest the FAA allow me to deem my aircraft as airworthy, as additionally evidenced by the manufacturer's testament. Entitled Minimum Safe Altitudes, General. The FAAprescribes safe altitudes for the operation ofcivil aircraft, but that helicopters are allowed to be operated at lower altitudes in certain conditions. The aircraft will be operated at altitudes not to exceed 400feet AGL,over private property without permission, or at a distance at or greater than five nautical miles from the nearest airport as depicted on current aeronautical charts
. Entitled Altimeter Settings. The FAAprescribes guidelines for altimeter settings This section is inapplicable, asthe SUAdoes not have an altimeter and instead utilizes electronic GPSwith abarometric sensor. Entitled Fuel requirements for flight in VFR conditions. The FAA sets rules for fuel in VFRconditions. The aircraft will only be operated up to apoint that there isenough power

RobertVoigt• 4V L' 

### ••• to fly at normal cruising speed to the landing point and land the vehicle with 25%battery power remaining. Note: a low battery alarm on the operating consoles for the aircraft is equipped with a shaker mechanism to warn the operator of a low battery condition. Section 91.405 Entitled Maintenance required. Section 91.407(a)(1) Entitled Operation after maintenance, preventative maintenance,
.

rebuilding, or alteration. Entitled Inspections. Section 91.409 AND Section 91.417 That As Entitled Maintenance Records.

These sections are all associated with an airworthiness certificate
. There are currently no airworthiness certificates for small UAVs
. BENEFITS GAINED VIA RELIEF The Voigt Group, LLC will derive numerous benefits from exemption from the above stated Federal Regulations. • The use ofthe small UAVwill allow for quicker and timelier aerial video and aerial photography ofproperties as contracted for. • The use ofthe small UAVwill allow for more cost effective aerial video and aerial photography as the cost to operate a small UAV is fractional compared to the cost of operating a full size aircraft for aerial photography. • Use ofthe small UAV will lessen the use offull size aircraft for some aerial photography missions and therefore give a somewhat greater safety ratio for the use of aerial photography. • The public will benefit both in economic and safety terms. The use ofthe SUSwill allow our group to capture images that will drive both business and residents to our county. The UAV is safer, less costly, and easier to use than flying a regular aircraft to capture these images. We additionally perform some work pro bono, as it relates to economic growth and business development in our area. REASONS WHY SAFETY WILL NOT BEAFFECTED BYGRANTING THESE REQUESTED EXEMPTIONS: • Standard operating procedures prior to launch will include apreflight checklist ofthe vehicle and a visual inspection ofarea to be surveyed at ground level will be performed
. • Flight operations will be conducted by a two man crew consisting ofthe Operator and the Visual Observer. All operations will be conducted with a clear line ofsight between the UAV and the team. Robert Voigt • 5v •. 

### •••

• The Voigt Group, LLC will only operate the UAV over private or public property with the permission ofthe property owner or the governing body and will maintain a safe distance from any structures, people or vehicles. This petition isbeing made pursuant to the FAA Modernization and Reform Act of2012, Section 333,which directs the Secretary ofTransportation to determine ifany UAS may safely operate in the National Airspace
. The Voigt Group, LLC will operate the aircraft granted for use by the exemption as directed by the operating manual provided by the manufacturer. IN CONCLUSION As set forth previously, The Voigt Group, LLC seeks exemption pursuant to 14 CFR: 11.61and Section 333ofthe FAA Modernization and Reform Act of2012,which will permit safe operation ofDJIPhantom 3 Professional Quadcopter commercially within the tourism, real estate and hospitality markets. The Administrator will be assisting small business and local tourism organizations by granting this petition. In accordance with the FAA Modernization and Reform Act of2012,The Voigt Group, LLC respectfully requests that the FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 21 subpart H, 45.23(b), 61.113 (a) and (b);91.7 (a);91
.119 (c); 91.121;91.151 (a);91
.405 (a);91
.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b). Regards,

~~ Robert Voigt President The Voigt Group, LLC

Robert Voigt • 6