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ESSEX PHOTOGRAPHY • . - :T (':' 

DECEMBER 28, 2015 

509 JANE RANDOLPH STREET 

FOREST, VIRGINIA. 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

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RE: Essex Photography's Petition for Exemption to Operate Unmanned Aircraft Systems 

for Aerial Photography, Videography. 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) and 14 

C.F .R. Part 11, Essex Photography, Hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) listed herein and any other necessary to allow its operation of (SMALL 

Unmanned Aircraft Systems) (UAS) to provide aerial photography, and video production. The 

requested exemption would permit the operation ofDJI Inspire One and Vision 2 plus,V3 UAS 

to obtain aerial photographs and video footage for real estate sales and land development. 

BACKGROUND 

Chris Ward founded Essex Photography in 1997 and began producing photographic imagery and 

video virtual tours for real estate agents and land developers with the use of an L 19 Bird Dog . 

Mr. Ward's professional background includes education as an electronics engineer and a 

professional career as a photographer. He also has an intense mechanical background from 

working for Volvo for 30 plus years. He has built and flown numerous radio controlled 

helicopters and multi rotors for the past 25+ years and is an AMA member. All of these skills 

enable him to safely maintain and fly a UAS in the proper environment. Because of the current 

regulatory environment, work has been limited to the full scale air craft with high financial over 

head. Essex Photography would like to expand operations and provide professional aerial 

photography, and video services to it's clients and other individuals in the Lynchburg, Roanoke, 

Smith Mountain Lake areas as well some parts ofNorth Carolina. 

The Unmanned Aircraft System's (UAS) described herein is smaller, lighter and more 

maneuverable than conventional aircraft, they can operate at lower altitudes with no people on 

board and will thereby reduce current risks, enhance safety and diminish the likelihood of serious 

bodily injury. With a small payload and maximum flight time of only 18 minutes and flies line 

of sight, this offers little or no risk to national security. For these reasons it would be in the 

public interest to grant this petition. 
December 29, 2015 Page2 

Additionally Essex Photography requests to be allowed to use its systems to aid in post fire 

investigations for local fire departments and documenting storm damage for NOAA if a safe 

environment permits it while remaining subject to all limitations and FAA guidelines. 

THE UNMANNED AIRCRAFT SYSTEM (UAS) SPECS 

DJI INSPIRE ONE 

• Inspire One Airframe 

o Maximum speed 15 MPH 

o Under 10 pounds takeoff weight 

o 4motors 

o 7 to 18 minute flight time depending on battery size 

• DJI - 5.8 GHz Flight Controller with GPS 

o Provides Fail Safe features that allow the aircraft to return to the launch point 

and land automatically in the event the command and control signal is lost or 

the battery has reached a prewdetermined threshold. If battery reaches a 

critical level, the aircraft will descend and land at the home point location. 

Control of the aircraft is maintained during descent to allow the PIC to guide 

it to a safe landing. 

o Home Lock function allows safe operation at pre-programmed distance within 

line of sight. 

o The programmed altitude limit is set at 200 ft 

o Contains a database of airports and restricted airspace and automatically 

prevents operation in these areas. 

• DJI 2.4 GHz Video Downlink Transmitter - FCC Licensed. 

• DJI Light Bridge On Screen Display of Telemetry. The (Light Bridge) system 

superimposes telemetry data on the video downlink to provide the pilot with heading, 

speed, height, distance, GPS information, and current battery voltage as well as 

indicating proximity to airports and restricted airspace. Direction back to launch 

point is also indicated. 

DJI Vision 2+ V3. 

• DJI Phantom Airframe 

o Maximum speed 10 mph 

o Under 5 pounds takeoff weight 

o 4motors 

o 7 to 15 minute flight time depending on battery 

• DJI 5.8 GHz- Flight Controller With GPS and all of the same safety features as the 

DJI Inspire One, Including an altitude limiter of 400ft, but is set at 200ft, return home 

function, and a fly zone inhibitor. 
December 29, 2015 

• DJI 2.4 GHz Video Downlink (same as Inspire one) 

• DJI Telemetry System (same as Inspire one) 

GROUND STATION EQUIPMENT 

The ground station equipment is comprised of a dual control and audio communication 

equipment. 

• Primary controller is for the Pilot in Command (PIC) 

o 5.8 GHz radio control unit (FCC Licensed) 

o 2.4 GHz video receiver (FCC Licensed) 

o Display of video and telemetry 

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• Camera Controller operates the camera gimbal and does not affect aircraft control 

o 5.8 GHz radio control unit. (FCC Licensed) 

o 2.4 GHz video receiver (both PIC and Cameraman receive the same signal) 

o Display of video and telemetry 

o Dual Directional antennas for improved video reception. 

• (PIC) and camera operator stand side by side for safety and proper communication. 

GROUND CREW 

• Pilot in Command (PIC). The pilot in command will have at least a sport or private 

pilots license and a third class medical. 

• The Camera operator controls the camera onboard the aircraft for photography and 

videography sessions and acts as safety spotter. 

• Visual Observer . The visual observer will provide additional situational awareness 

during flight operations. 
December 29, 2015 Page4 

OPERATIONAL PARAMETERS 

1. The UAS will weigh less than 20 pounds. 

2. Flights will be operated within visual line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 18 minutes or less. Flights 

will be terminated at 30% battery power reserve should that occur prior to the 18 minute 

limit. 

4. Flights will be operated at an altitude of no more than 200 feet Unless a specific COA is 

obtained. 

5. Minimum crew for each operation will consist of the UAS pilot and the Camera 

OperatorNisual Observer. 

6. UAS pilot will be an FAA licensed airman with at least a sport pilots license. PIC will 

have completed operator and safety training from Essex Photography. PIC will also have 

accumulated and logged at least 30 hours total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS and 5 hours in the same 

make and model ofUAS proposed under this exemption request Local AMA flying 

fields and rules will be used to accumulate flying time and practice emergency 

procedures. PIC will also remain current for the type of aircraft for which the PIC is 

operating. 

7. Written and Oral permission will be obtained from the property owners. 

8. Pilot and observer will be able to communicate by voice at all times during the operation, 

Text communications are not allowed 

9. The UAS will only be operated during daytime hours in VFR weather conditions. 

10. Operations may not be conducted aboard a moving device or vehicle. 

11. No operations will be permitted over crowds or sporting events or any place where 

potential bodily injury could occur. 

12. No operations in restricted areas. 

PRE-FLIGHT CHECKLIST 

1. Weather conditions are suitable for VFR flight and wind is 15 mph or less. 

2. Measure battery voltage to make sure batteries are sufficiently charged before takeoff. 

3. Verify that all wiring connections are tight. 

4. Raise and actuate landing gear, Inspect for cracks, damage, and loose hardware. 

5. Check to make sure propellers are secure and free from dirt, cracks and chips. 

6. Install main battery and check CG balance. 

7. Turn on camera equipment. 

8. Verify all switch positions on the RC transmitters and that the switches are in the proper 

position. 

9. Tum on radio control transmitters and video equipment. 

10. Connect the UAS main battery. Check for radio connection with RC transmitters and 

video downlink. 

11. During warm-up, check the status light for proper warm-up and any error messages 

12. Check for the correct amount of satellites and check radio signal strength. 
December 29,2015 

Respectfully Submitted, J a~ uJ~ Chris Ward 

509 Jane Randolph Street 

Forest, Virginia. 24551 

434-660-9159 

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