1 May	10 ,	2015

Docket	Operations,	M

- 30
U.S. Department	of	Transportation (DOT) 1200	New	Jersey	Avenue,	SE
Room	W12

- 140,	West	Building	Ground	Floor Washington,	D.C.	20590

- 0001

RE: Petition	to	the	FAA	for	Section	333	Exemption

Dear	Sir or	Madam :

FP	AeroSol utions,	LLC	hereby	submits	to	the	Federal	Aviation	Administration, pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012,	an	exemption	for petition,	in	accordance	with	Section	333	of	the	Act.

This	letter	provides	requested	information	as	listed	in	the FAA’s	“Public	Guidance for	Petitions	for	Exemptions	Filed	under	Section	333”.

FP	AeroSolutions,	LLC	Background: FP	AeroSolutions,	LLC	is	comprised	of	professional s who	are	ATP	rated	and	have provided	aviation	solutions	for	15	years. The	backgrounds	includ e experience	as	an Assistant	Chief	Flight	Instructor	for	the	largest	collegiate	flight	school	in	the	world and	Director	of	Safety	for	a n FAA designated UAS	Test	Site.

Purpose	for	the	Exemption FP	AeroSolutions,	LLC requested	exemption	would	permit FP	Aero Solutions,	LLC to operate	SUASs	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,

s peed,	and	operating	capability.

FP	AeroSolutions,	LLC 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	o ffered	to homeowners,	realtors,	builders,	contractors,	and/or	inspectors	for	use	in,	but	not limited	to,	real	estate	marketing	and	safe r inspections	of	home and	building exteriors.	All	operations	will	be	conducted	on	private	property	and	with	the	written

a nd/or	oral	permission	of	the	property	owner(s).	Operations	will	always	be conducted	in	areas	that	are	clear	of	all	people,	except	the	pilot	in	command	(PIC)
and	the Visual	Observer .	Such	operations will	ensure	that	the	SUAS	will not	create	a hazard	to	user s	of	the	national	airspace	system	or	the	publ ic

. FP	AeroSolutions,	LLC operation	will not	differ	significantly	from	the	situation	described	in	Grant	of Exemption	No.	11 191 ( Singler’s	Creations ).2 Contact	Information

Nicholas	Flom FP	AeroSolutions,	LLC
156 0	49 th Ave	S Grand	Forks,	ND	58201
Mobile:	701

- 610

- 3434 Email:	nicholasflom@aol.com

List	of	Specific	Section	of	14	CFR	for	which	exemption	is	sought:

The	listing	matches	the	list	on	page	7	of	the	FAA’s	“Public	Guidance	for	Petitions
Filed	Under	Section	333 ”,	Rev.	9/25/2014

14	CFR	21,	Subpart	H

– Airworthiness	Certificates

14	CFR	61.113 (a) and	(b),	Certification:	Pilots,	Flight	Instructors,	and	Ground
Instructors

14	CFR	91.7(a),	Airworthiness	required	for	operation

14	CFR	91.105,	Flight	crewmembers	at	stati ons

14	CFR	91.119(c) ,	Minimum	safe	altitudes

14	CFR	91.121,	Altimeter	settings

14	CFR	91.151 ,	Fuel	requirements	for	flights	in	VFR	conditions

14	CFR	91.405 (a) ,	Maintenance	required

14	CFR	91.407 (a)(1),	Operations	after	maintenance

14	CFR	91.409 (a)(1) an d	(2) ,	Inspections

14	CFR	91.417	(a)	and	(b) ,	Maintenance	records

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,	operational capability,	proximity	to	ai rports	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	airwort hiness	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	requirement s	for	the	safe	operation	of	such	aircraft in the	national	airspace	system

.3 Operation	Overview

FP	AeroSolutions,	LLC ’ s SUASs	are	quadcopters,	weighing	3	or	fewer	lbs.	(including payload).	The	SUASs	have	the	capability	to	hover	and	move	in	the	vertical	and horizontal	planes	simultaneously.	They	will	operate	only	in	visual	line	of	slight (VLOS)	and	will	operate	only	in	tightly	controlled	and	limite d	airspace.	They	are capable	of operating	at	speeds	of	up	to	29	knots,	but	will	be	routinely	operated	at
much	lo wer	speeds.	They	will	routinely	be	operated	below	200	feet	above	gro und level	(AGL),	and	never	above 400	feet	AGL.

Aircraft

FP	AeroSolutions,	LLC operates	Phantom	2	Vision+ (Phantom)	SUASs	manufactured by	DJI,	a	well

- known	leader	in	quadcopter	technology .	DJI	strives	to	bring	new perspectives	to	aerial	work	and	help	companies	accomplish	feats	safer,	faster,	an d with	greater	efficiency.	They have	an	unparalleled	commitment	to	R&D,	a	culture	of constant	innovation,	and	a	focus	on	transforming	complex	techno logy	into	easy

- to

use	devices.

The	standard	Phantom	quadcopter	package	includes	the	Phantom	itself,	camera, gimbal,	propulsion	system,	flight	control	system,	5.8	GHz	remote	controller,	and	2.4
GHz	Wi

- Fi	communication	system.	The	remote	uses	a	5.8	GHz	freq uency	to	prevent interference	with	the	video/telemetry	channel.	This	second	channel	allows	for	a constant	connection	with	the	Phantom	to	monitor	it	via	a	smartphone	that	is
attached	to	the	remote	controller.

The	Phantom	is	about	1	foot	square	in	size.	It has	a	maximum	ascent	speed	of	11 knots,	a	maximum	descent	speed	of	3	knots,	and	a	maximum	flight	speed	of	29 knots.	While	operating	within	VLOS,	the	remote	control	has	a	range	of	2,624	feet. The	total	weight	(including	the	payload)	is	2.55	lbs.

The	Phant om	is	equipped	with	a	DJI	Naza

- M	V2	flight	control	system.	This	provides for	incredible	ease	of	use	and	stability.	Pilots	can	control	the	Phantom’s	movements in	many	directions

– including	pitch	(forward	and	backward),	roll	(left	and	right), elevator	(up	a nd	down),	and	yaw	(turn	left	or	right).	The	flight	control	system	can also	provide	Intelligent	Orientation	Control	(IOC),	failsafe,	battery	level	warnings, and	show	the	aircraft’s	current	heading,	direction,	and	approximate	distance	from
home	on	the	on

- scr een	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	(ATTI)	and	altitude.	The	inertial	measurement tells	the	Phantom	how	it’s	tilted.	And	the	gyros	tell	it	if	it’s	rotating	in	any	particular
direction.

The	Phantom’s	compass	r ead s geomagnetic	information	and	assist s the	Global4 Positioning	System	(GPS)	to	accurately	calculate	the	position	and	height	of	the aircraft.	The	vertical	hover	accuracy	is	+/

- 2.6	ft.	The	horizontal	hover	accuracy	is +/

- 8.2	ft.

The	Phantom	has	LED	fligh t	indicators	beneath	each	of	its	four	rotor	arms.	The	LEDs 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	SUASs	can	be	safely	operated

and	“no t	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public.” 6

Equivalent	Level	of	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, FP	AeroSolutions,	LLC 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 (Attachment: “AmaSafetyCode.pdf”	document. ) : 1. SUASs	will	not	be	flown:

a. In	a	careless	or	reckless	manner.

b. At	a	location	where	SUAS	activities	are	prohibited.

2. SUAS	pilot s	will:

a. Yield	the	right	of	way	to	all	human

- carrying	aircraft.

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

c. Not	fly	higher	than	400	feet	above	ground	level	or	within	three (3)	miles		of	an	airport	without	notifying	the	airpo rt	operator.

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

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

f. Ensure	the	aircraft	is	identified	by affixing	the	owner’s	contact5 information	to	the	outside	of	the	SUAS.

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

h. Not	operate	SUASs	carrying	py rotechnic	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:

a. The	aircraft,	control	system	and	pilot	skills	have	successfully
demonstrat ed	all	maneuvers	intended	or	anticipated	prior	to the	specific	event.
b. 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	endangerme nt	of	life	and	property
of	others.
5. 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	aircraft.
6. SUASs	must	use	the	radio

- control	frequenc ies	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	the	PIC	and	the Visual	Observer (VO) 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:

a. Maintain	control	during	the	entire	flight,	maintaining	visual contact	without	enhancement	other	than	by	corrective	lenses prescribed	for	the	pilot.

b. Fly	using	the	assistance	of	a	camera	or	First

- Perso n	View	(FPV) only	in	accordance	with	the	procedures	outlined	in	AMA
Document	#550.

c. Fly	using	the	assistance	of	autopilot	or	stabilization	system only	in	accordance	with	the	procedures	outlined	in	AMA
Document	#560.6 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 VO

.

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, FP	AeroSolutions,	LLC also	agrees	to	be	bound	by the	following	limitations	and	conditions:

1. Operations	authorized	by	this petition	for exemption	are	limited	to	the following	aircraft	described	in	the	operating	documents	which	is	the	DJI Phantom	2	Vision	+	Unmanned	Aircraft	System,	a	quad	rotor	aircraft	with a	maximum	takeoff	weight	of	less	than	6	pounds.	Proposed	operations of

any other	aircraft	will	require	a	new	petition	or	a	petition	to	amend	this grant.

2. UAS	operations	under	this petition are	limited	to aerial	photography	and videography	services	will	be	offered	to	homeowners,	realtors,	builders, contractors,	and/or	insp ectors	for	use	in,	but	not	limited	to,	real	estate marketing	and	safe r inspections of	home	and	building	exteriors.

3. The	UA will not	be	flown	at	an	indicated	airspeed	exceeding	29	knots	(15 m/s).

4. The	UA will be	operated	at	an	altitude	of	no	more	than	400 feet	above ground	level	(AGL),	as	indicated	by	the	procedures	specified	in	the operating	documents.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL.

5. The	UA will be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all times.	This	requires	the	P IC	to	be	able	to	use	human	vision	unaided	by any	device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAA

issued	airman	medical	certificate.

6. All	operations will utilize	a VO .	The	VO will be	used	to	satisfy	the	VLOS requirement	as	long	as	the	PI C	always	maintains	VLOS	capability.	The	VO
and	PIC will be	able	to	communicate	verbally	at	all	times.	Electronic messaging	or	texting will not be permitted	during	flight	operations.	The
PIC will be	designated	before	the	flight	and	cannot	transfer	his	or	he r designation	for the	duration	of	the	flight.

7. The	VO will not	perform	any	other	duties	beyond	assisting	the	PIC	with seeing	and	avoiding	other	air	traffic	and	other	ground	based obstacles/obstructions	and	is	not	permitted	to	operate	the	camera	or7 other instruments.

8. Th e	operating	documents will be	accessible	during	UAS	operations	and made	available	to	the	Administrator	upon	request .	The operator will follow	the	procedures	as	outlined	in	its	operating	documents.	The operator may update	or	revise	its	oper ating	documents.	It	is	the responsibility	of FP	AeroSolutions,	LLC to	track	such	revisions	and present	updated	and	revised	documents	to	the	Administrator	upon
request. FP	AeroSolutions,	LLC will also	present	updated	and	revised documents	if	it	petitions	fo r	extension	or	amendment.	If FP AeroSolutions,	LLC determines	that	any	update	or	revision	would	affect the	basis	upon	which	the	FAA	granted	this	exemption,	then FP AeroSolutions,	LLC will petition	for	amendment	to	their	exemption.	The FAA’s	UAS	Integration Office	(AFS

- 80) will be	contacted	if	questions	arise regarding	updates	or	revisions	to	the	operating	documents.

9. Prior	to	each	flight	the	PIC will inspect	the	UAS	to	ensure	it	is	in	a condition	for	safe	flight.	If	the	inspection	reveals	a	condition	that affects the	safe	oper ation	of	the	UAS,	the	aircraft	is	prohibited	from	operating until	the	necessary	maintenance	has	been	performed	and	the	UAS	is found	to	be	in	a	condition	for	safe	flight.	The	Ground	Control	Station will be	included	in	the	preflight	insp ection.	All	maintenance	and	alterations
will be	properly	documented	in	the	aircraft	records.

10. Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the UAS	operation	or	flight	characteristics,	e.g.	replacement	of	a	flight	critical component,	m ust	undergo	a	functional	test	flight	in	acco rdance	with	the operating	documents.	The	PIC	who	conducts	the	functional	test	flight will make	an	entry	in	the	UAS	aircraft	records	of	the	flight.	The	requirements and	procedures	for	a	functional	test	flight	and aircraft	record	entry will be	added	to	the	operating	documents.

11. The	preflight	inspection	section	in	the	operating	documents will be amended	to	include	the	following	requirement:	The	preflight	inspection
will account	for	all	discrepancies,	i.e.	inoperable components,	items,	or equipment,	not	covered	in	the	relevant	preflight	inspection	sections	of the	operating	documents.

12. The	operator will follow	the	manufacturer’s	UAS	aircraft/component, maintenance,	overhaul,	replacement,	inspection,	and	life	limit

req uirements,	with	particular	attention	to	flight	critical	components	that may	not	be	addressed	in	the	manufacturer’s	manuals.

13. The	operator will carry	out	their	maintenance,	inspections,	and	record keeping	requirements,	in	accordance	with	the	operating	docu ments.8 Maintenance,	inspection,	and	alterati ons will be	noted	in	the	aircraft logbook, including	total	flight	hours, description	of	work	accomplished, and	the	signature	of	the	authorized	UAS	technician	returning	the	UAS	to

service.

14. Each	UAS	operated will comply	with	all	manufacturer	Safety		Bulletins.

15. An authorized	person will make	a	record	entry	in	the	aircraft	record	of the	corrective	action	taken	against	discrepancies	discovered	between inspections.

16. Qualification	for	the	Pilot	in	Command

a. Certificati ons:	Operations	will	be	conducted	by	a	Pilot in Command	(PIC)	possessing	at	least	a	private	pilot	certificate	and	at
least	a	third

- class	medical	certificate.

b. Logged	Hours:	Prior	to	operations	the	PIC	will	have	accumulated and	logged 20	flights	or	log	20	hours	of	flight	time	(the	greater	of the	two) with	the	Phantom.

c. Currency:	The	PIC	will	have	accomplished,	during	dedicated training	sessions,	3	take

- offs	and	landings	in	the	preceding	90	days (for	currency	purposes).

d. Flight	Training:

i. Successfully	learn	and	demonstrate	all	flight	maneuvers	in	the
“P hantom	Pilot	Training	Guide”.	(Attachment: “PhantomTrainingGuide.pdf”	document).

ii. Study	and	be	familiar	with	all	sections	of	the “Phantom	2 Vision+	User	Manual”.	(Attachment:	“PhantomUserManual.pdf” document).

iii. Study	and	be	familiar	with	all	sections	of the	“Guide	to the Phantom	2	Vision	&	Vision+”.	(Attachment: “PhantomGuide.pdf”	document).

iv. Study,	be	familiar	with,	and	demonstrate	(where	possible)	the “Always	be	Prepared	for	the	Worst”	scenarios. (See	“Always	be prepared	for	the	Worst”	on	page	13	of	the attached	“Guide	to the	Phantom	2	Vision	&	Vision+”).

e. Emergency	and	Evasive	Maneuvers:	The	PIC	will	have demonstrated	the	ability	to	safely	operate	the	Phantom	in	a manner	consistent	with	how	it	will	be	operated	in for	actual	FP AeroSolutions,	LLC	operation s ,	including	evasive	and	emergency9 maneuvers	and	maintaining	appropriate	distances	from	people, vessels,	vehicles	and	structures.	The	logged	hours	reference d
above	will	document	this.

17. UAS	operations will not	be	conducted	during	night,	as	defined	in	14	CFR § 1.1.	All	operations will be	conducted	under	visual	meteorological conditions	(VMC).	Flights	under	special	visual	flight	rules	(SVFR)	are	not
authorized.

18. The	UA will not	operate	within	5	nautical	miles	of	an	airport	reference point	as	denoted	on	a	curr ent	FAA

- published	aeronauti cal	chart	unless	a letter	of	agreement	with	that	airport’s	management	is	obtained,	and	the operation	is	conducted	in	accordance	with	a	NOTAM.	The	letter	of agreement	with	the	airport	management will be	made	available	to	the Administrator	upon	request.

19. Th e	UA will not	be	operated	less	than	500	feet	below	or	less	than	2,000 feet	horizontally	from	a	cloud	or	when	visibility	is	less	than	3 statute miles	from	the	PIC.

20. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA will return to	a	predeter mined	location	within	the	private	or	controlled

- access property	and	land	or	be	recovered	in	accordance	with	the	operating
documents.

21. The	PIC will abort	the	flight	in	the	event	of	unpredicted	obstacles	or emergencies	in	accordance	with	the	operating	docum ents.

22. The	PIC is prohibited	from	beginning	a	flight	unless	(considering	wind and	forecast	weather	conditions)	there	is	enough	power	to	fly	at	normal cruising	speed	to	the	intended	landing	point	and	land	the	UA	with	30% battery	power	remaining	in	accordan ce	with	the	operating	documents.

23. The	operator will obtain	an	Air	Traffic	Organization	(ATO)	issued Certificate	of	Waiver	or	Authorization	(COA)	prior	to	conducting	any operations	under	this petition	for exemption.

24. All	aircraft	operated	in	accordance	wit h	this petition will be	identified	by serial	number,	registered	in	accordance	with	14	CFR	part	47,	and	have identification	(N

- Number)	markings	in	accordance	with	14	CFR	part	45, Subpart	C.	Markings will be	as	large	as	practicable.

25. Before	conducting	oper ations,	the	radio	frequency	spectrum	used	for operation	and	control	of	the	UA will comply	with	the	Federal10 Communications	Commission	(FCC)	or	other	appropriate	government oversight	agency	requirements.

26. The	documents	required	under	14	CFR	§§	91.9	and	91.2 03 will be available	to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time	the aircraft	is	operating.	These	documents will be	made	available	to	the Administrator	or	any	law	enforcement	official	upon	request.

27. The	UA will remain	clear	and	yield	the right	of	way	to	all	other	aviation operations	and	activities	at	all	times.

28. The	UAS will not	be	operated	by	the	PIC	from	any	moving	device	or
vehicle.

29. Flight	operations will be	conducted	at	least	500	feet	from	all nonparticipating	persons	(persons	other than	the	PIC	or	VO),	vessels,

ve hicles,	and	structures	unless:

a. Barriers	or	structures	are	present	that	sufficiently	protect nonparticipating	persons	from	debris	in	the	event	of	an	accident.	The
operator will ensure	that	nonparticipating	persons	remain under	such protection.	If	a	situation	arises	where	nonparticipating	persons	leave such	protection	and	are	within	500	feet	of	the	UA,	flight	operations
will cease	immediately	and/or;

b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the land	owner/controller	has	granted	permission	and	the	PIC	has	made	a safety	assessment	of	the	risk	of	operating	closer	to	those	objects	and;

c. Operations	near	the	PIC	or	VO	do	not	present	an	undue	hazard	to	the PIC	or	VO	per	§	91.119(a).

30. All	operations wi ll be	conducted	over	private	or	controlled

- access property	with	permission	from	the	property	owner/controller	or authorized	representative.	Permission	from	property	owner/controller or	authorized	representative	will	be	obtained	prior	to	the	beginning	of

ev ery	flight.

31. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or vertical	boundaries	of	the	operational	area	as	defined	by	the	applicable
COA will be	reported	to	the	FAA’s	UAS	Integration	Office	(AFS

- 80)	within
24	hours.	Accidents must	be	reported	to	the	National	Transportation Safety	Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site: www.ntsb.gov

.11 The	operation	of	SUASs,	weighing	less	than	3	lbs.,	conducted	in	the	strict	conditions as	outlined	above,	will	provide	an	e quivalent	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,	a nd	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.

Preflight	Action	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	o rder	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,	Phantom	battery,	range	extender,	and smartphone	are	all	fully	charged.
2. Verify	that	the	Phantom	battery	is	not	swollen	or	damaged	in	any	way. Clean	the	contact	needles	and	pads	if	necessary

. 3. Turn	the	motor	shafts	with	your fingers	and	verify	they	are	smooth without	excessive	play	or	binding.
4. Verify	that	the	propellers	are	mounted	correctly.	Propellers	with	a	black top	should	be	mounted	on	the	mount	shafts	that	have	a	black	dot. Propellers	with	a	silver	top	should	be	mount ed	on	the	mount	shafts	that have	a	silver	dot.	Each	propeller	should	spin	all	the	way	down	onto	the
motor	shaft.
5. Run	finger	along	the	edge	of	edge	blade	to	check	for	any	rough	edges.
6. Flex	both	side	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	gear.
9. Verify	that	the	Micro

- SD	card	has	been	inse rted	and	formatted.
10. Verify	that	the	damping	absorbers	are	not	broken	and/or	worn.
11. Verify	that	the	anti

- drop	pins	are	in	place	and	locked.
12. Remove	the	Gimbal	guard	and	camera	lens	cap.
13. Verify	that	the	camera	is	secure	and	clean.	Inspect	the	camera	ri bbon cables	for	tears	and/or	signs	of	wear.
14. Verify	that	the	smartphone’s	GPS	is	enabled.
15. Set	the	smartphone	to	do

- not

- disturb	mode	to	prevent	distractions	while flying.12 16. Set	the	smartphone	to	forget	any	Wi

- Fi	networks	in	range	in	order	to prevent	the Wi

- Fi	connection	from	changing	mid

- flight.
17. Verify	that	the	smartphone’s	audio	is	on	to	ensure	the	low	battery warning	and	other	alarms	can	be	heard.

B. Power	Up
1. Verify	that	S1	and	S2	are	in	the	top	position	on	the	remote	control.
2. Power	on	the	equipment in	the	following	sequential	order:

a. Range	Extender	(“System”	is	blinking	green;	“Power”	is	solid green)

b. Remote	Control	(2	beeps	to	indicate	it’s	in	FCC	mode)

c. Insert	and	start	the	Phantom	battery.

3. Watch	the	Phantom	LED	startup	sequence	for	abnormal	in dications.	The rear	LEDs	should	blink	green	for	at	least	10

- 15	seconds	to	indicate	that	it locked	onto	6+	satellites	and	has	marked	the	home	point	(for	use	by	the failsafe	feature).
4. Calibrate	the	Phantom’s	compass.
5. Place	the	Phantom	on	an	open,	flat	gr ound	with	the	battery	indicators facing	towards	the	PIC	at	least	10	feet	away.

C. DJI	Vision	Application
1. Connect	the	smartphone	Wi

- Fi	to	the	range	extender.
2. Launch	the	“DJI	Vision”	application	on	the	smartphone.

a. Verify	that	the	Wi

- Fi	connection	is	“Ph antom

- #####”	and	is marked	with	a	green	dot.

b. Verify	the	number	of	satellites	is	6+.

c. Verify	the	Wi

- Fi	signal	strength.

d. Verify	that	the	Phantom	and	range	extender	batteries	are reporting	a	full	charge.

e. Verify	that	both	the	PIC’s	and	Phantom’s	location	is	the	same before	taking	off	to	ensure	the	home	point	has	been	accurately
marked.

f. Verify	the	location	of	the	Phantom	in	the	“Flight	Radar”.	If	it’s not	in	the	correct	position/direction	and/or	shows	a	di stance of	“N/A”,	it	did	not	mark	the	home	point.13 g. Use	the	“Find	my	Phantom”	feature	to	ensure	the	blue	(home point	location)	and	red	(Phantom	location)	dots	are	in	the
same	location	on	the	screen.

D. Ready	to	Fly
1. Verify	that	the	remote	control	antenna	is perpendicular	to	the	ground (pointing	skyward).
2. Verify	that	the	front,	flat	face	of	the	range	extender	is	pointed	toward	the
Phantom.
3. Verify	that	the	rear	LEDs	are	still	slowly	blinking	green	and	still
connected	to	6+	satellites.
4. Start	the	Phantom	mo tors	using	the	CSC command	on	the	remote	control.
5. Verify	that	the	motors	are	functioning	normally,	are	not	making	any unusual	noises,	and	are	all	spinning	at	the	same	speed.
6. Verify	that	the	area	is	still	clear	of	obstructions,	people,	power	lines,	etc.
7. Take	off	and	hover	at	about	6

- 8	feet	above	the	takeoff	point	to	verify	that the	Phantom	has	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”	seq uences. 8. Verify	that	the	Phantom	holds	a	steady	position	while	yawing	360 degrees.
9. Verify	that	the	Phantom	response	appropriately	to	all	controls

– yaw left/right,	pitch	forward/backward,	roll	left/right,	and	throttle	up/down.

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. (Attachment:	See	the	“Preventive	Maintenance
C hecklist”	on	page	41	of	the	attached	“PhantomGuide.pdf”	document).

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	are	free	from
the	h armful	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	pr esents	no	risk	to	the	public.	Furthermore,	the	public	will	be	able	to legally	acquire	aerial	photography	and	videography	to	help	in,	but	not	limited	to, advertising	homes	for	sale,	advertising	uninhabited	home	lots,	use	of	photos	and
video	as	an	aid	when	r esearching	homes	for	sale	on	the	market,	or	safely	accessing high	and/or	awkward	areas	of	a	home’s	exterior	to	assess	damage	that	needs	to	be repaired.14 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 all	people,	except	for	the	PIC	and	the	PIC's	helper(s),	approval	of	this	application presents	no	risk	to	the	public	privacy.

National	Security

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

Requested	Exemptions

FP	AeroSolutions,	LLC requests	exemption	from	the	following	regulations	since	it’s not	possibl e	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,	Subpart	H

Part	21	covers	certification	procedures	for	products	and	parts.	Subpart	H specifies	requi rements	for	Airworthiness	Certificates	for	various	aircraft types.	Small	unmanned	aircraft	systems	are	not	specifically	called	out	and
addressed	in	these	rules. FP	AeroSolutions,	LLC will,	in	lieu	of	airworthiness certification	by	aforementioned	rule,	if exemption	is	granted,	ensure	that	the Phantom	2	Vision+	system	is	in	compliance	with	its	operating	documents	as described	herein.	The	PIC	will	assure	that	all	Preflight	Checks	are	completed and	documented	and	thee	is	full	compliance	with	all	manufacturer’s operation	and	maintenance	documents.		Due	to	consideration	of	the	size, weight,	speed,	and	limited	operating	area	associated	with FP	AeroSolutions,
LLC’s proposed	Phantom	2	Vision+,	we	believe	it	will	not	create	a	hazard	to users	of	the	National	Airspace System	(NAS)	or	the	public.	Therefore,	a request	is	made	for	exemption	from	14	CFR	part	21,	and	any	associated	noise certification	and	testing	requirements	of	part	36.

Private	pilot	privileges	and	limitations:	Pilot	in	command

14	CFR	61.113	(a)

Under	c urrent	regulations,	civil	operations	for	compensation	or	hire	require a	PIC	holding	a	commercia l	pilot	certificate	per	14	CFR	Part	61.	Based	on	the
Private	P ilot	limitations	in	accordance	with	pertinent	parts	of	14	CFR §61.113(a),	a pilot	holding	a	Private P ilot	certificate	cannot	act	as	a	PIC	of	an aircraft	for	compensation	or	hire.	However,	in	Grant	of	Exemption	No.	1106215 to	Astraeus	Aerial	(Astraeus),	the	FAA	determined	that	a	PIC	with	a	private pilot	certificate	operating	the	Astraeus	UAS	would	not	adve rsely	affect operations	in	the	NAS	or	present	a	hazard	to	persons	or	property	on	the ground.

FP	AeroSolutions,	LLC operation	will not	differ	significantly	from	the situation	described	in	Grant	of	Exemption	No.	11062	(Astraeus	Aerial). FP AeroSolutions,	LL C plans	to	operate	over	private	property	with	controlled
access	in	the	NAS. With the	similar	nature	of	the	proposed	operating

envi ronment	to	that	of	Astraeus, the	para llel	nature	of	Private	P ilot aeronautical	knowledge	requirements	to	those	of	commercial	r equirements [re f:	Exemption	No.	11062],	and the	airmanship	skills necessary	to	operate the	UAS, FP	AeroSolutions,	LLC believes	t hat	the	additional	airmanship experience	of	a	commercially	certificated	pilot	would	not	correlate	to	the airmanship	skills	neces sary	for	the	specific	proposed	operations.	Therefore, FP	AeroSolutions,	LLC PIC s will	hold a minimum	of	a private	pilot	certificate
and	a	third

- c lass	airman	medical	certificate.

Airworthiness	required	for	operation

14	CFR	91.7(a)

If	the	exemption	from	14	C FR	21,	Subpart	H	(item	1	above)	is	granted,	no airworthiness	certificate	will	be	required.	On	this	basis,	exemption	from	14 CFR	91.7	(a)	is	requested,	presuming	that	airworthy	condition	by	definition in	the	rule	means	having	an	airworthiness	certificate. F P	AeroSolutions,	LLC will,	in	lieu	of	airworthiness	certification	by	14	CFR	21,	ensure	that	the Phantom	2	Vision+	system	is	in	compliance	with	its	operating	documents	as described	herein.	The	PIC	will	assure	that	all	Preflight	Checks	are	completed
and	docu mented	and	execute	full	compliance	with	all	manufacturer’s operation	and	maintenance	documents.

Flight	crewmember	at	stations

14	CFR	91.105

This	part	requires	certain	actions	by	onboard	crewmembers.	Since	the Phantom	is	unmanned,	an	exemption	from	this	r ule	is	requested.

Minimum	Safe	Altitudes

14	CFR	91.119(c)

This	regulation	requires	all	operation	to	remain	no	closer	than	500	feet	from persons,	vessels,	vehicles,	and	structures. FP	AeroSolutions,	LLC requires relief	from	§	91.119(c)	is	because	all	operat ions	will	be	conducted	below	400 feet	AGL	and	may	be	operated	closer	than	500	feet	from	persons,	vessels,16 vehicles,	and	structures	as	described	above.

P rior	to	conducting	UAS	specific	operations

, all	persons	not	essential	to	flight operations	(nonparticip ating	persons)	must	remain	at	appro priate	distances. In	open	areas,	the	UA	will remain	500	feet	from	all	persons	other	than essential	flight	personnel	(i.e.	the	PIC	and	VO).	If	barriers	or	structures	are present	that	can	sufficiently	protect	nonparticipati ng	persons	from	debris	in the	event	of	an	accident	then	the	UA	may	operate	closer	than	500	feet	to persons	afforded	such	protection. FP	AeroSolutions,	LLC will ensure	that nonparticipating	persons	remain	under	such	protection.	If	a	situation	arises
where	n onparticipating	persons	leave	such	protection	and	are	within	500 feet	of	the	UA,	flight	operations	must	cease	immediately.	The	primary concern,	when	considering	how	to	immediately	cease	operations,	is	the safety	of	those	nonparticipating	persons. O peration s	may	be	conducted closer	than	500	feet	to	vessels,	vehicles	and	structures	when	the	land owner/controller	grants	such	permission	and	the	PIC	makes	a	safety assessment	of	the	risk	of	operating	closer	to	those	objects.

Altimeter	settings

14	CFR	91.121

Th is	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	n ot	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.”

S imilar	UAS

- specific	relief	has	been	granted	an	Exemp tion	Nos.	8811,	10808, and	10673	for	daytime,	Visual	Flight	Rules	(VFR)	conditions. FP AeroSolutions,	LLC UAS	provides	low	battery	warnings	at	30%	capacity	that indicate	the	PIC	must	command	the	UA’s	return	to	the	launch	point	when	low battery	capacity	vol tage	is	reached.	The	UAS	also	provides	critical	low battery	warnings	at	15%	battery	capacity	indicating	that	the	UA	will	begin	to descend	and	land	automatically.	These	factors	provide an	equivalent	level	of17 safety	by	prohibiting	t he	from	beginning	a	flight unless	(considering	wind and	forecast	weather	conditions)	there	is	enough	power	to	fly	at	normal cruising	speed	to	the	intended	landing	point	and	land	the	UA	with	30% battery	power	remaining.

Maintenance	Inspections

14	CFR	91.405	(a);	14	CFR	91.407	(a)( 1);	14	CFR	91.409	(a)(1) and	(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	Phantom	user manual	and	guide.	An	equivalent	level	of	safety	will	be	achieved	because these	small	SUASs	are	very	limi ted	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	P re

- 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.

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 ) ; 14	CFR	91.7(a); 14	CFR	91.10 5 ; 14	CFR	91.119(a); 14	CFR 91.121;	14	CFR	91.151 ; 14	CFR	91.405	(a);	14	CFR	91.40 7	(a)(1);	14	CFR	91.409 (a)(1)	and	( 2);	14	CFR	91.417	(a)	and	(b)	to	commercially	operate	small	unmanned aircraft	sy stems	(55	lbs.	or	less)	in	order	to	safely	and	legally	capture	aerial photography	and	videography	for	use	by	homeowners,	realtors,	builders, contractors,	and/or	inspectors.

The	operation	of	SUASs	conducted	in	the	strict	conditions	outlined	above,	will

pro vide	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	spe eds,	close	to	the	ground,	and	in	a	sterile	environment, and	as	a	result,	are	far	safer	than	existing	operations	conducted	with	helicopters18 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	Phantom	demonstrates	that	it	can	be	operated within	an	equivalent	level	of	safety	in	whi ch	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	present s	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

– i ncluding 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, FP	AeroSolutions,	LLC respectf ully 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	vis ual	line	of	sight,	public	safety,	and	national	security

– provide	more than	adequate	justification	to	grant FP	AeroSolutions,	LLC the	requested	exemption, allowing	for	commercial	operations	as	described	herewith.19 Summary	for	Publication	in	Federal	Regist er

Petition	for	Exemption

Docket	No.:	FAA

- 2015

- xxxx

Petitioner:	FP	AeroSolutions,	LLC

Sections	of	14	CFR

Description	of	Relief	Sought:	The	petitioner	is	seeking	an	exemption	to	utilize an	unmanned	aircraft	system	(UAS)	to	accomplish a erial	photography and videography	services	to	homeowners,	realtors,	builders,	contractors,	and/or inspectors	for	use	in,	but	not	limited	to,	real	estate	marketing	and	safer inspections	of	home and	building exteriors.

Sincerely,

/s/	Nicholas	Flom

__________________________ __________

Nicholas	Flom Managing Partner

, FP	Aero Solutions ,	LLC

Enclosures	(4)