July 7, 2015

Jon C. Bolton II 4389 Dolly Court Oviedo, FL 32765

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act Pursuant to section 333 of the FAA Modernization and Reform act of 2012 (The Ref orm Act), and 14 C.F.R. Part 11

The name and address of the applicant is: Orlando Drone Aerial Photography ATTN Jon
Bolton II , 4389 Dolly Court, Oviedo, FL 32765, jon@inspectagator .com

. Orlando Drone Aerial Photography (ODAP) , herby seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to allo w ODAP to operate Small Unmanned Aircraft Systems (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) under the conditions and limitations set forth in this petition. The requested exemption would permit Orlando Drone Aer ial Photography to operate small, unmanned aircraft system (sUAS) for the purpose of providing an aerial photography and video service to private consumers. The intended areas of use will include both photo and video in the home inspection industry, real estate ind ustry, construction industry and profit and non

profit events . The sUAS will be operated in airspace that is 1) limited 2) predetermined 3) would provide safety enhancements to the already safe operations in the industry pres ently using conventional aircraft. Approval of this exemption would thereby enhance safety and
fulfill t he Secretary of Transportations responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace sy stem”

Regulations from which the exemption is requested (detailed in Appendix I) 14CFR Part 21

14CFR 45. 23 (b) 14CFR 61.113 (a) & (b) 14 CFR 61.3 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203(a) & (b) 14 CFR 91.205 14 CFR 91.215 14 CFR 91.405 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This petition for exemption is submitted to fulfill Congress’ goal under section 333(a) through (c) of the reform act directing the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in t he national airspace system (NAS) before completion of the rulemaking required under section 332 of the reform act. In making this determination the Secretary of Transportation is required to determine which types of UASs 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: 1) The UASs size, weight, speed, and operational capability 2) Operation of the UASs in close proximity to airports and populated areas; and 3) Operation of the UASs wi thin visual line of sight of the operator

. Reform Act Section 333 (a) If the Secretary of Transportation determines that such operation of 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 section 333 (c) The Federal Aviation Act expressly grants the FAA the authority to grant exemption from it regulatory requirements for civil aircraft, as the term is defined under section 4010 1 of the federal Aviation Act which includes sUASs. The Secretary of Transportation and/or TheAdministrator of the Federal Aviation Administration (acting on behalf of the Secretary of

transportation) may grant an exemption from a requirement of a regulat ion prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of the Federal Aviation Act if the Administrator finds the exemption in the public interest. 49 USC section 44701 (f) see also 49 USC section 44711 (a); 49 USC 44704; 49 14 CFR 91.203 (a) (1).

Orlando Drone Aerial Photography is a new company owned by Jon C. Bolton II

. Our goal is

to provide a long term sustainable career opportunity with the use of sUASs for controlled commercial aerial photography and video while enha ncing and supporting multiple other
industries whereas this opportunity was previously unavailable or economically not feasible
for s mall businesses

. The sUAS will also be utilized in home and building inspections to access roofs that are either unsafe or exceed the capability of a standard 17’ ladder. In

some case s we are unable to fulfill our inspection obligation because of these limiting factors. The sUAS will enable the inspector to do that. We typically never exceed 75’.

The vehicle to be used will be the DJI Phanton 2 Vision+ (operation and flight training manual attached). While vehicles may be upgraded as new t echnological and safety
advances occur , the bar for operation and safety will be set by DJI Phantom 2 Vision + and any new vehicles or versions will exceed the current safety and operational stand ards . No vehicle operated by ODAP will be modified from the manufacturers design unless specifically directed by the same manufacturer. Operational and safety guidelines: The sUASs will operate below 400 feet above ground level (AGL) and have a built in capability t o restrict altitude. The distance the sUAS flies from the ground operator and restriction of flights in class B, C, and D airspace, including no fly zones shall be included in the software and
hardware features and company policy . The sUAS has a built in f ailsafe to return to it point
of launch should connection be disabled between the control and sUAS. The sUAS will return to its point of launch should the battery level fall below a safe level of 25% . The sUAS will go into hover mode holding at a stationar y point in space should the operator become incapacitated or unable to use the controls at any time during the flight, eventually safely returning to its point of launch and landing safely. The sUAS will only be operated in line of sight from the operator

. Safety i s also enhanced by using a 7 ” tablet for greater clarity and view during flight and shade hoods for reduced glare

. The approximate and maximum flight
time of the sUAV will be 15

- 25 minutes

. The sUAS will not exceed 55 lbs. nor will it exceed a maximum speed of 30 knots

. All operators will be required to fully know and understand the regulations for flight as set forth in th is petition and the FAA’s regulations. All operators will be required to know and understand that ODAP will in no way use its sUASs to conduct surveillance, spy, or in any way violate the expectation of privacy of anyone. All operators will undergo training on software use, pre flight inspection, start up, take off, landing, safe navigation and emergency operation. All operators will be required to provide a written
descri ption in a provided log of each flight to include detailed preflight check list of sUAS components including battery charge, weather conditions, purpose of flight, area hazards prior to take off, and flight time. No sUAS will take flight with any mechanica l, electrical, or software deficiency. The sUAS operator will have the flight and operation manual provided by the manufacturer in his possession during all flights. The sUAS will have navigational lighting to be visible by the operator at all times to det ermine location and orientation. The sUAS will at no time create a hazard to the National Airspace System or to the public. The sUAS shall be immediately grounded and yield right of way should any manned aircraft come within an unsafe proximity of the sUAS

.The proposed operations satisfy the criteria provided in section 333 of the Reform Act

relating to size, weight, operating capabilities, proximity to airports and populated areas, privacy, operation within visual line of sight, and national security. Th is provides adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUASs in aerial photography /videography for aerial data collection

. This request is substantially similar to other d ata collection petitions previously approved, and should be considered under the expedited summary grant procedure.

### Appendix I

14 CFR Part 21 regarding aircraft certification requirements and proc edures is designed for
manned aircraft and is not suitable for off the shelf sUASs.

14 CFR 45.23 (b) requiring aircraft to be marked in 2” to 6” lettering is impossible, there is not sufficient space on the sUAS.

14 CFR 61.113 (a) & (b) limiting pilots t o non

- commercial operations, referring to the PIC. The sUASs will not carry a pilot, a passenger, or cargo for compensation or hire. The operators training from the manufacturers manual creates a higher level of safety for the public as a Commercial Pilot’ s certificate in no way provides specific safe operational training of a remote controlled sUAS tethered to the operator on the ground.

14 CFR 61.3 requiring a pilot certification. Pilot certification is designed for manned aircraft, The operators trainin g from the manufacturers manual creates a higher level of safety for the public as a Pilot’s certificate in no way provides specific safe operational training of a remote controlled sUAS tethered to the operator on the ground.

14 CFR 91.7 (a) Civil Aircra ft Airworthiness requirements. No airworthiness certificate is available for this aircraft. The sUASs will not be modified and will be inspected prior to any flight as outlined in this petition.

14 CFR 91.9 (b) (2) requires that the flight manual be avail able in the aircraft. Given the size and the fact that the aircraft is unmanned this rule cannot apply in its current language. However, as outline in this petition, the flight manual will be in the possession of the operator during any flight.

14 CFR 91. 103 preflight action requirements for crew on board aircraft. While this is important to the safe flying of the sUAS it does not apply given its current language. We have included a similar, more comprehensive solution in our operational and safety guideli nes, “All operators will be required to provide a written description in a provided log of each flight to include detailed preflight check list of sUAV components including battery charge, weather conditions, purpose of flight, area hazards prior to take o ff, and flight
time.”

14 CFR 91.109 requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has fully functioning dual controls. SUASs and Remote controlled aircraft by design do not have dual controls, to do so on a radio controlled aircraft would lower the ability to safely operate the sUAS. This section cannot reasonably apply.

14 CFR 91.119 designating minimum safe altitudes. The sUASs operated by Orlando Drone Aerial Photography will not exceed an altitude o f 400 feet AGL. This is below the altitude designated in this section. Also given the size, weight, and speed of the sUAS, the line of sight rule when operating, and the overall safeguards and restrictions in flight outlined in this petition maintain a hig her level of safety to the public.

14 CFR 91.121 regarding altimeter settings. A barometric altimeter is not provided on any

sUAS . However a GPS altitude indicator is displayed to the operator at all times during flight. While an exemption to this regulation is requested a modification to meet the current technology of the sUASs would be acceptable.14 CFR 91.151 (a) Fuel requireme nts for flight. The maximum flight time under ideal

conditions is 25 minutes with the current manufacturers battery pack. The proposed rule under the Operation and Safety guidelines in this petition requiring the sUAS to return to its point of launch if it s battery reaches less than 25% provides a higher standard of safety when applied to sUASs.

14 CFR 91.203(a) & (b) requiring that a civil aircraft certificate and registration be displayed at the cockpit entrance cannot apply to sUASs, there is no cockpit and the size limitations prevent this.

14 CFR 91.205 refers to cockpit instruments and cannot reasonably apply to sUASs as there is no cockpit.

14 CFR 91.215 requiring a transponder cannot reasonably apply to sUAVs operated by
Orlando Drone Aerial Photo graphy because they will be operated below ATC radar capabilities as outlined in this exemption request.

14 CFR 91.405, 14 CFR 407 (a) (1) (2), 14 CFR 409 (a) (2), 14 CFR 417 (a) & (b) referring to maintenance, preventive maintenance, and alterations to t he sUAV. The operator will provide minor maintenance and inspection to the sUAV, documented as outlined in the operational and safety guidelines. Given the size and simplicity of the sUAV combined with the operational and safety guidelines outlined in this petition the operator can maintain or exceed the required level of safety.