### Cody Porche Porche Aerial Imagery 5853 East Kayleigh Lane Lake Charles, LA 70605 (337) 540-8522 codyporche@gmail.com



### May 22nd, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE



### IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

## Porche Aerial Imagery FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

PORCHE AERIAL IMAGERY 1Dear Sir or Madam:

In accordance with Section 333 of the FAA Modernization and Reform act of 2012 (the Reform Act) and 14 CFR Part 11, Porche Aerial Imagery hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial use of its Small Unmanned Aircraft Systems (SUAS ), 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.

An exemption is being requested because (1) existing regulations will burden Porche Aerial Imagery (2) Porche Aerial Imagery can and will provide and maintain an utmost level of safety equal or greater to those provided by existing rules, and (3) the request is in the public interest. The FAA’s authority to issue exemptions from operating rules, and the Secretary’s authority granted by Section 333 of P.L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain SUAS operations in the National Airspace System (NAS) prior to implementation of the SUAS rule. This incremental step will allow Porche Aerial Imagery to legally and safely enter into the NAS.

As described in detail below, the requested exemption would permit Porche Aerial Imagery to operate SUAS under controlled conditions in airspace that is (1) limited (2) predetermined (3) controlled as to access and (4) would provide safety enhancements to the already safe operations of those aircraft of similar size, weight, speed, and operating capability that have been granted entry into the NAS via the rules in Academy of Model Aeronautics (AMA) National Aircraft Safety Code. Approval of this exemption would thereby greatly enhance safety and fulfill the Secretary of Transportation’s (the Secretary) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system” per Section 333 (c) of the Reform Act.

**Porche Aerial Imagery is requesting exemption from the following regulations:**  14 CFR Part 21, Subpart H 14 CFR 61.23 (a) 14 CFR 61.113 (a) and (b)

PORCHE AERIAL IMAGERY 214 CFR 91.109 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(1) 14 CFR 91.409 (a)(2) 14 CFR 91.417 (a) and (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS, to the public, or pose a threat to national security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned aircraft system, as a result of its size, weight, speed, operating capability, proximity to airports and populated areas, and operation within visual line of sight (VLOS) does not create a hazard to users of the NAS or the public or pose a threat to national security, and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 49 USC 44704 is required for the operation of civil (non-governmental) UASs. Therefore, if the Secretary determines that such 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".

**LIMITED LIABILITY CORPORATION OVEVIEW** Porche Aerial Imagery’s SUAS are quadcopters (or quadrotors, multirotors), weighing 6.5 or fewer lbs. (including payload). The SUAS possess simultaneous capability to hover and move in both the vertical and horizontal planes. They will operate only in visual line of sight (VLOS) and will operate only in tightly controlled and limited airspace. They are capable of operating at

PORCHE AERIAL IMAGERY 3speeds of up to 43 knots, but will be routinely operated at speeds no greater than 20 knots. They will routinely be operated below 200 feet above ground level (AGL), and **never above 400 feet AGL** 

. This AGL limitation is pertinent to the operation of normal business and is not only required to be monitored by the pilot in command but is also limited via the DJI Pilot App described in a future section of this document.

Porche Aerial Imagery’s exemption request would permit its commercial operation of SUAS for aerial photography and videography in tightly controlled and limited airspace. Aerial photography and videography services will be offered to large or small corporations, small public events, private events, commercial and personal realtors, contractors, or property inspectors for use in, but not limited to, general aerial imagery requested by said “customers”. All operations will be conducted on private property and with the written and/or oral permission of the property owner(s). Operations will always be conducted in areas that are clear of people, except the pilot in command (PIC) and the PIC's helper(s). Such operations will ensure that the SUAS will "not create a hazard to users of the national airspace system or the public”

. 1

**AIRCRAFT** Porche Aerial Imagery operates a DJI Inspire 1. The Inspire 1 is a SUAS manufactured by DJI, a well-known leader in quadcopter technology. DJI strives to bring new, innovative and safe technology to the aerial imagery industry and to assist companies worldwide in achieving said aerial imagery. They have an unparalleled commitment to research and development, an innovative culture, and a focus on transforming quadcopter technology into easy-to-use devices.

The standard Inspire 1 quadcopter package includes the Inspire 1 itself, camera, gimbal, propulsion system, flight control system, 5.8 GHz remote controller, and 2.4 GHz communication system. The remote uses a 5.8 GHz frequency to prevent interference with the video/telemetry channel. This second channel allows for a constant connection with the Inspire 1 to monitor it via a tablet (specifically, iPad Air 2) that is attached to the remote controller.

Reform Act Section 333 (b) 1

PORCHE AERIAL IMAGERY 4The Inspire 1 is approximately 17.2 inches x 17.7 in. x 11.9 in. in size. It has a maximum ascent speed of 16.4 feet per second, a maximum descent speed of 13.1 feet per second, and a maximum flight speed of 43 knots. While operating within VLOS, the remote control has a range of approximately 2,600 feet. The total weight (including the payload) is 6.4 lbs.

The Inspire 1 is equipped with a flight control system that provides incredible ease of use and stability. Pilots can control the Inspire l's movements in many directions including pitch (forward and backward), roll (left and right), elevator (up and down), and yaw (turn left and right). The flight control system can also provide intelligent orientation control (IOC), failsafe, battery level monitoring/battery warnings, and show the aircraft's current heading, direction, and exact distance from home on the onscreen radar. The built-in GPS system aids in stabilizing the aircraft and automatically and safely returns it back to its home point in any case where communication between the remote control and quadcopter are lost.

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter that measures both attitude (ATII) and altitude. The IMU incorporates both a 6-axis gyroscope and an accelerometer to monitor minuscule changes in tilt and movement. This allows the aircraft to compensate and adjust immediately, holding its position at all times.

The Inspire 1's compass reads geomagnetic information and assist the Global Positioning System (GPS) to accurately calculate the position and height of the aircraft. The Inspire 1 also has a built in Visual Positioning System (VPS) that allows takeoff and landing at the press of a button and keeps the Inspire 1 steady when GPS satellites cannot be required.

The Inspire 1 has LED flight indicators beneath each of its four rotor arms. The LED s on the arms as well as one on the battery, illuminate to indicate the status of the flight control system and alert the PIC of any possible issues. Such highly advanced capabilities will ensure that the SUAS can be safely operated and "not create a hazard to users of the national airspace system or the public.” 2

Reform Act Section 333 (b) 2

PORCHE AERIAL IMAGERY 5**SAFETY** In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the world and to minimize the risk to the NAS or to persons and property on the ground, Porche Aerial Imagery agrees to be bound by the following limitations and conditions when conducting commercial operations under an FAA issued exemption: **A. For the purposes of ensuring SUASs will be operated within the standards that**  **the FAA has allowed in the AMA National Model Aircraft Safety Code:**  1. SUASs will not be flown: 1.1. In a careless or reckless manner

. 1.2. At a location where SUAS activities are prohibite d. 2. SUAS pilots will 2.1. Yield the right of way to all human-carrying aircraft

. 2.2. See and avoid all aircraft and a spotter must be used when appropriate

. 2.3. Not fly higher than 400 feet AGL or within three (3) miles of an airport without notifying the airport operator

. 2.4. Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement

. 2.5. Not exceed a takeoff weight of 55 pounds (including payload)

. 2.6. Ensure the aircraft is identified by affixing the owner's contact information to the outside of the SUAS

. 2.7. Not operate SUAS’s while under the influence of alcohol or while using any drug that could adversely affect the PIC's ability to safely control the model

. 2.8. Not operate SUAS's carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property

. 3. SUASs will not be flown unless: 3.1. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event

. 3.2. An inexperienced pilot is assisted by an experienced pilot

. 4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others

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PORCHE AERIAL IMAGERY 65. A successful radio equipment ground-range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model aircraf t. 6. SUASs must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC)

. 7. SUASs will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. 8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to any individual, except for PIC and the PIC's helper(s) located at the takeoff site

. 9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still under power, except to divert it from striking an individual

. 10. The PIC of the SUAS shall: 10.1. Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilo t. 10.2. Fly using the assistance of a camera or First-Person (FPV) only in accordance with the procedures outlined in AMA Document #550

. 10.3. Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560

. 11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown closer than 50 feet to any above-ground electric utility lines

. 12. The flying area must be clear before the engine is started, except for PIC and the PIC helper(s)

.

**B. In addition to the above rules outlined by the AMA National Model Aircraft**  **Safety Code and in an effort to enhance the safety offered by the already safe operations mentioned above, Porche Aerial Imagery also agrees to be bound by**  **the following limitations and conditions:** 1. Flights will be operated within VLOS of the PIC

. 2. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 30% battery power reserve should that occur prior to the 25 minute limit

. 3. The SUAS will only operate in tightly controlled and limited airspac e.

PORCHE AERIAL IMAGERY 74. A pre-flight discussion will be conducted in regard to the planned SUAS operations prior to each flight. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this meeting. 5. The PIC and the PIC's helper(s) will have been trained in operation of SUAS and received up-to-date information on the particular SUAS to be operated

. 6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice

. 7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to return to a pre-determined location within the security perimeter and safely land based off of the initial home point determined prior to take off. 8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies

. 9. All flights will be conducted no private property and with the written and/or oral permission of the property owner(s)

. 10. Flights will **always** be conducted in areas that are clear of people, except for the PIC and the PIC's helper(s)

. 11. Flights will not be conducted outdoors in visual meteorological conditions (VMC) and never during severe weather conditions

. 12. Flights will not occur in weather conditions that prevent the PIC from operating within visual line-of-sight (VLOS) at all times or in weather conditions that dramatically affect the UAS's flight (e.g. rain, high winds)

. 13. If an operation occurs in an area where people could inadvertently enter the area, an operational border will be established with traffic cones. If it is not feasible to use traffic cones due to interference with the photography/videography, the PIC's helper(s) will be responsible for keeping a safe perimeter around the operation. The operation will cease immediately and be rescheduled if it's impossible to establish a safe perimeter around the operation. 14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative maintenance plan can be followed, as described in the “Preventative Maintenance" section below. 15. The SUAS will **not** be routinely operated in the proximity of any airports. In any cases where SUAS must be operated within three (3) miles of an airport, the airport operator will be notified before the operation commences

.

PORCHE AERIAL IMAGERY 8The operation of SUASs, weighing less than 7 lbs., conducted in the strict conditions as outlined above, will provide an equivalent level of safety supporting the grant of exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled environment. As a result, they offer a much safer way to capture aerial photography and videography. Furthermore, the proposed operations represent a safety enhancement to the already safe operations that have been granted by the FAA for the establishment of the AMA National Model Aircraft Safety Code.

**PRE-FLIGHT PLAN** The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a condition for safe flight. This plan will be improved as needed in order to ensure all known safety precautions and/or safety precautions suggested by the manufacturer are being accounted for.

**A. Pre-flight Inspection**  1. Check that the remote control, Inspire 1 batteries, and tablet are all fully charged (Under no circumstances will flight be permitted if all devices do not have a minimum of 50% battery) 2. Inspect the Inspire 1 battery for signs of overuse or an overage of wear and tear including, but not limited to, swollen or bloated cells, dents, discoloration, etc). Clean the contact needles and pads if necessary 3. Gently rotate the motor shafts with your fingers and verify they do not exhibit excessive play or bindin g 4. Verify that the propellers are mounted correctly. *Note that Porche Aerial Imagery’s SUAV is transported in a large case with all propellers installed. Therefore only a brief visual inspection is necessary at this step. 5. Run finger along the edge of the propeller blade to check for any rough edges or imperfections.

PORCHE AERIAL IMAGERY 96. Gently flex both sides of the propellers' blades to check for hairline cracks where the blades connect in the center of the propeller

. 7. Verify that the landing gear is secure (not cracked/broken/loose)

. 8. Verify that the compass and compass cable is firmly attached to the landing gea r. 9. Verify that the Micro-SD card has been inserted and formatted

. 10. Verify that the damping absorbers are not broken and/or wor n. 11. Verify that the camera is secure and clean. Inspect the camera for signs o f any wear and

tear. 12. Set the tablet in “Airplane Mode” mode to prevent distractions while flying

. 13. Set the tablet to forget any Wi-Fi networks in range in order to prevent the Wi-Fi connections from changing mid-flight

. 14. Verify that the tablet's audio is on to ensure the low battery warning and other alarms can be heard

.

**B. Power up**  1. Verify that the transmitter is in the “P” mode on F-A-P switch. 2. Power on the equipment : 2.1. SUAS battery (blinking green indicates GPS lock and ready to fly ). 2.2. Remote control (solid green and chime indicate lock on SUAS and ready to fly)

. 3. Check the DJI Pilot app to ensure lock on 6+ satellites and home point is marked (for use by the failsafe feature)

. 4. Calibrate the compass

. 5. Check MOD values. 6. Place the Inspire 1 on open, flat ground with the battery indicators facing towards the PIC at least 10 feet away

.

**C. DJI Pilot Ap**  **p** 1. Connect the tablet to the transmitter via USB

. 2. Launch the app . (select “Trust this device”) 3. Verify the number of satellites is 6+

. 4. Verify signal strength

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PORCHE AERIAL IMAGERY 105. Verify that the tablet battery has a full charg e. 6. Verify that both the PIC's and the Inspire 1's location is the same before taking off to ensure the home point has been accurately marked

. 7. Verify the location of the Inspire 1 in the "flight radar." If it is not in the correct position/ direction and/or shows a distance of "N/ A", it did not mark the home point

. 8. Use the "find my Inspire" feature to ensure the blue (home point location) and red (Inspire 1 location) dots are in the same location on the scree n.

**D. Ready to fly**  1. Verify that the remote antenna is perpendicular to the ground (pointing skyward ). 2. Verify that the front, flat face of the range extender is pointed toward the Inspire 1

. 3. Verify that the rear LED's are slowly blinking green and still connected to 6+ satellites

. 4. Start the Inspire 1 motors using the remote control

. 5. Verify the motors are functioning normally, and are not making any unusual noises, and are all spinning at the same speed

. 6. Verify that the area is clear of obstructions, people, power lines, etc

. 7. Take off and hover at approximately 6-8 feet above the takeoff point to verify that the Inspire 1has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc) land immediately and repeat the "Pre-flight inspection" and "power up" sequence s. 8. Verify the Inspire 1 holds a steady position while yawing 360 degrees

. 9. Verify the Inspire 1 responds appropriately to all controls-yaw left/right, pitch forward/ backward, roll left/right, and throttle up/dow n.

**PREVENTATIVE MAINTENANCE** A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS's software is up-to-date, the batteries are in good health, and the aircraft itself is always ready for safe flight. This maintenance plan includes a routine inspection after SUAV is retired for the day. Any abnormalities will be immediately addressed prior to any future flight.

**PILOT IN COMMAND (PIC) QUALIFICATIONS**

PORCHE AERIAL IMAGERY 11The PIC does not hold an airman certificate or medical certification. Since the SUAS is similar in size, weight, speed, and operating capability as those currently allowed to be flown for hobby/ recreation, holding the PIC to those same set of standards will allow for an equivalent level of safety.

The PIC has years of computer systems and RC systems. Since the SUAS is controlled by a highly advanced computer system and runs on software that must be configured, updated, and maintained, computer proficiency is a must to ensure the SUAS is ready to be safely operated in the NAS

.
It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace. Since there are no standards for either private or commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the SUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. With that in mind, Porche Aerial Imagery proposes that its PIC be required to do the following prior to the first commercial operation: 1. Perform a minimum of 20 flights without issue or log 20 hours of flight time (the greater of the two) with the Inspire 1. 2. Successfully learn and demonstrate all flight maneuvers in the Inspire 1 User Manual. (downloadable at http://www.dji.com/product/inspire-1/download ). 3. Study and be familiar with all sections of "Inspire 1 User Manual ”.

**PUBLIC INTEREST** Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent level of safety, a reduction in environmental impacts, and allow for a reduction in harmful emissions associated with the manned aircraft that are currently used for aerial photography and videography. Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this application presents no risk to the public. Furthermore, the public and/or corporations will be able to legally acquire aerial photography

PORCHE AERIAL IMAGERY 12and videography to help in, but not limited to, monitor progress on major construction sites, review future construction sites for consideration, obtain videography of events, and even obtain aerial photographs of their new building.

**PRIVACY** Since the areas being photographed or filmed will be on private property, accessed only after given written and/or oral consent by the property owner(s), and clear of people, except for the PIC and the PIC's helper(s), approval of this application presents no risk to public privacy.

**NATIONAL SECURITY** Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this application presents no risk to national security.

**REQUESTED EXEMPTIONS** Porche Aerial Imagery requests exemption from the following regulations since it's not possible to fully comply with them, and since attempting to follow them for the purposes of operating a SUAS would be a burden: **Airworthiness Certificates** 14 CFR Part 21, Subpart H Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by Porche Aerial Imagery, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC 44701(f)) and Section 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 SUAS. In all cases, an analysis of these criteria demonstrates that the SUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least safe, or safer, than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed.

PORCHE AERIAL IMAGERY 13**Medical certificates** 14 CFR 61.23(a) This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks associated with the operation of the proposed SUAS are so diminished from the level of risk associated with any manned aircraft; the SUAS is of a size, weight, speed, and operational capabilities which make it much safer than any manned aircraft; since operations will occur in tightly controlled and limited airspace; and considering that all operations will be on private property that is clear of people, obtaining and maintaining a medical certificate would not improve the safety of the operation. In the very rare case of a mishap, the SUAS being flown will pose significantly less of a threat than manned helicopters and fixed wing aircraft because the SUASs are a fraction of the size and weight will be flown at a fraction of the speed, carry no flammable fuel, and carry no crew or passengers.

**Private pilot privileges and limitations: Pilot in command** 14 CFR 61.113(a) and (b) These regulations limit private pilots to non-commercial operations. Because the SUAS will not carry a pilot or passengers; due to the SUASs size, weight, speed, and operational capabilities; and since operations will occur in tightly controlled and limited airspace, the proposed operations can achieve the equivalent level of safety of current operations that require a commercial pilot's license. Furthermore, since there are no standards for either private or commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the SUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. It cannot be assumed that a commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace.

**Flight I nstruction**  14 CFR 91.109 This regulation provides that no person may operate a civil aircraft (except a manned free

PORCHE AERIAL IMAGERY 14balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. SUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot or passengers will be carried in the aircraft and by the size and speed of the aircraft.

**Altimeter S ettings**  14 CFR 91.121 This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the SUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator by confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

**Fuel Requirements for Flight in VFR Conditions** 14 CFR 91.151(a) This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions 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 SUAS provides approximately 20 minutes of powered flight. That would make it impossible to meet the 30 minute reserve requirement. Given the limitations on the SUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. An equivalent level of safety can be achieved by limiting flights to 20 minutes or 30% of battery power (whichever occurs first). This restriction would be more than adequate to return the SUAS to its planned landing zone from anywhere in its limited operating area.

PORCHE AERIAL IMAGERY 15**Maintenance Inspections** 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) and (b) These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply. Maintenance will be accomplished by the operator pursuant to the aforementioned Inspire 1 user manual. An equivalent level of safety will be achieved because these small SUASs are very limited in size, will carry a small payload, and operate only in restricted areas for limited periods of time. If mechanical issues arise, the SUAS can land immediately and will be operating from no higher than 400 feet AGL. As outlined in the aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is in working order prior to initiating flight and perform maintenance as required. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

**SUMMARY** In accordance with 14 CFR Part 11, the following summary is provided for publication in the Federal Register: **The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR 61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR**  **91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) and (b) to commercially operate small unmanned aircraft systems (55 lbs. or less) in**  **order to safely and legally capture aerial photography and videography for use by large or small corporations, small public events, private events, commercial and**  **personal realtors, contractors, or property inspectors.**

PORCHE AERIAL IMAGERY 16The operation of SUAS conducted in the strict conditions outlined above, will provide an equivalent and/or greater level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and as a result, are far safer than existing operations conducted with helicopters operating in close proximity to the ground, people, or other buildings in the vicinity.

Given the small size of the SUASs involved, the slow speed at which they must be operated in order to capture photos and videos, and the restricted environment within which they will operate, the Inspire 1 demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by exemption, allow commercial operations of SUASs to commence immediately.

Also, due to the size of the SUASs and the restricted areas in which the relevant SUASs will operate, approval of this application presents no threat to national security. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations, the significant public benefit - including enhanced safety, reduction in environmental impacts, no emissions, ability to legally obtain aerial photography and videography services - the grant of the requested exemptions is in the public interest. Accordingly, Porche Aerial Imagery respectfully requests that the FAA grant the requested exemption without delay.

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, operating capability, proximity to airports and populated areas, operation within the visual line of sight, public safety, and national security- provide more than adequate justification to grant Porche Aerial Imagery the requested exemption, allowing for commercial operations as described herewith.

With anticipation, Cody Porche Owner , Porche Aerial Imagery

PORCHE AERIAL IMAGERY 17