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# ESSEX PHOTOGRAPHY •.- :T(':'

DECEMBER 28, 2015 509 JANE RANDOLPH STREET FOREST, VIRGINIA.

United States Department ofTransportation Docket Management System 1200New Jersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590 : ' ' i- '

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### RE: Essex Photography's Petition for Exemption to OperateUnmanned Aircraft Systems for Aerial Photography, Videography. Dear Sir or Madam: Pursuant to Section 333 ofthe 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 Vision2 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 ofan L19 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 andmulti rotors for the past 25+ years and is anAMA member. All ofthese skills enable him to safely maintain and fly a UAS in the proper environment. Because ofthe current regulatory environment, work has been limited to the full scale air craftwith high financial over head. Essex Photography would like to expandoperations 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 ofserious bodily injury. With a small payload and maximum flight time ofonly 18 minutes and flies line ofsight, this offers little orno riskto national security. Forthese reasons itwould 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 inpost fire investigations for local fire departments and documenting storm damage for NOAA ifa safe environment permits it while remaining subjectto all limitations and FAAguidelines. THE UNMANNED AIRCRAFT SYSTEM (UAS) SPECS DJI INSPIRE ONE

• Inspire OneAirframe o Maximum speed 15 MPH o Under 10 pounds takeoffweight o 4motors o 7 to 18 minute flight time depending onbattery size • DJI

- 5.8 GHzFlight Controllerwith 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. Ifbattery reaches a critical level, the aircraft will descend and land atthehome point location. Control ofthe aircraft is maintained during descent to allow the PIC to guide it to a safe landing. o Home Lock function allows safe operation atpre-programmed distance within line ofsight. o The programmed altitude limit is setat 200 ft o Contains a database ofairports andrestricted airspace and automatically prevents operation in these areas. • DJI 2.4 GHz Video DownlinkTransmitter

- FCC Licensed. • DJILightBridge On Screen Display ofTelemetry. The (LightBridge) system superimposes telemetry data onthe video downlink to provide thepilotwith heading, speed, height, distance, GPS information, and current battery voltage as well as indicating proximityto airports and restricted airspace. Direction back to launch point is also indicated. DJIVision 2+ V3.

• DJIPhantomAirframe o Maximum speed 10 mph o Under 5 pounds takeoffweight o 4motors o 7 to 15 minute flight time depending onbattery • DJI 5.8 GHz- Flight Controller With GPS and all ofthe same safety features as the DJIInspire One, Including analtitude limiter of400ft, but is set at 200ft, returnhome 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 ofa dual control and audio communication equipment.

• Primary controller is for the Pilot inCommand (PIC) o 5.8 GHz radio control unit (FCC Licensed) o 2.4 GHz video receiver (FCC Licensed) o Display ofvideo and telemetry Page 3

• 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 Cameramanreceive the same signal) o Display ofvideo 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 orprivate 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 ofsight ofa pilot and/or observer. 3. Maximum total flight time for each operational flight will be 18 minutes or less. Flights will beterminated at 30% battery powerreserve should that occurpriorto the 18 minute limit. 4. Flights will be operated at an altitude ofno more than 200 feet Unless a specific COA is obtained. 5. Minimum crew for each operation will consist ofthe UAS pilot and the Camera OperatorNisual Observer. 6. UAS pilotwill be an FAA licensed airman with at least a sportpilots license. PIC will have completedoperatorand safety training from Essex Photography. PIC will also have accumulated and logged atleast 30 hours total time as a UAS rotorcraft pilotincluding at least 10 hours logged as a UASpilotwith a multi-rotorUAS and 5hours in the same make and model ofUAS proposed underthis exemptionrequest Local AMAflying fields and rules will beused to accumulate flying time and practice emergency procedures. PIC will also remain current for the type ofaircraft for which the PIC is operating. 7. Written and Oral permission will be obtained from the property owners. 8. Pilot and observerwill be able to communicate by voice at all times during the operation, Textcommunications are not allowed 9. The UAS will only be operated during daytime hours in VFRweather conditions. 10. Operations maynot be conducted aboard a moving device orvehicle. 11. No operations will be permitted over crowds or sporting events oranyplace where potential bodily injury could occur. 12. No operations in restricted areas. PRE-FLIGHT CHECKLIST 

### 1. Weather conditions are suitable for VFRflight and wind is 15 mph orless. 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, Inspectfor cracks, damage, and loosehardware. 

### 5. Check to make surepropellers are secure and free from dirt, cracks and chips. 6. Install main battery and checkCGbalance. 7. Turn on camera equipment. 8. Verify all switch positions onthe RC transmitters and that the switches are intheproper position. 9. Tumonradio control transmitters and video equipment. 10. Connectthe UAS mainbattery. Check for radio connectionwith RC transmitters and video downlink. 11. During warm-up, check the status light for proper warm-up and any errormessages 12. Check for the correct amount ofsatellites and checkradio signal strength.December 29,2015

Respectfully Submitted, 

# J**a~ uJ~**  Chris Ward 509 Jane Randolph Street Forest, Virginia. 24551 434-660-9159 Page 5