# Aero Images LLC

1431 Capri Lane #5202 Weston, FL 33326 May 4 th of 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey

Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part II of the Federal Aviation Regulations. Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part II, Aero Im ages LLC (“AI ”), operating the DJIInspire 1 Unmanned Aircraft System (“UAS” or “Inspire 1”) seeks an exemption from the Federal Aviation Regulations (‘FARs”) listed below and discussed in Appendix A. Attached, as Appendix B is a summary of this request. The requested exemption would permit commercial operation of AI ’s In spire1, which weights under 7 lbs. and performs aerial photography and videography u sing onboard cameras. Applications for this UAS devices and associated data processing functions include residential and commercial real estate, event coverage, surveying, inspections and artistic endeavors. U se of the In spire1 for aerial photography reduces the need to operate conventional aircrafts. These s avings result in enhanced efficiency and productivity

for the affected activities, as well as environmental benefits. Operation under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently

authorized operations using manned aircrafts and under conditions as may

be modified by the FAA as required by Section 333. As described more full y bellow, the requested exemption would authorize commercial operations of aerial surveys using the Inspire1, which at under 7 lbs. is small in size. The Inspire1 will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will have automated control features, as described bellow. The Inspire1 will be operated by Miguel S. De Felice , (“owner and chief pilot of Aero Im ages LLC”) , who holds an Airline Transport Pilot Certificate # 2817924 , a current First Class Medical Certificate with around 9200 total hours log ged and who has performed more than 30 flights with the Inspire1 including training. A ero Images L. L.C, respectfully submits that because this small, unmanned aerial vehicle (“the Insp ire1”) will be used in lieu of comparatively h azardous operations now conducted with fixed wing and rotary

conventional aircrafts, the FAA can have confidence that the operati ons will achieve a greaterlevel of safety. Approval of this exemption would thereb y enhance safety and fulfill the S ecretary o f Transportation’s ( The FAA Administrator’s) responsibilities under Section 333 (c) of the Reform Act to “ establish requirements for the safe operation of such aircraft s ys tems in the national airspace s ys tem.” The name and address of the applicant are: Company : Aero Images LLC Attn: Miguel S. De Felice Phone: 954 - 599 - 2749 Email: aeroimagesllc@gmail.com Addre ss: 1431 Capri Lane #5202

Weston, FL 33326 The regulations from which the exemption is requested are as follow:

 14 C.F.R. Part 21  14 C.F.R. 45.23 (b)  14 C.F.R. 61.113 (a) & (b)  14 C.F.R. 61.133 (a)  14 C.F.R. 91.7 (b)  14 C.F.R. 91.9 (b)(2)  14 C.F.R. 91.109 (a)  14 C.F.R. 91.119  14 C.F.R. 91.151 (a)  14 C.F.R. 91.203 (a) & (b)  14 C.F.R. 91.405 (a)  14 C.F.R. 91.407 (a)(1)  14 C.F.R. 91.409 (a)(2)  14 C.F.R. 91.417 (a) Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provided an equivalent level of safety, and are in the public interest. 

### THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 AIsubmits that grant of this exemption application for use of the Inspire1 in precision aerial surveys will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs into the national airspace system (“NAS”) if it can be accomplished safel y. This law directs the Secretary o f Transportation to consider whether certain UASs may operate safel y in the NAS before completion of the rulemaking required under section 332of the Reform Act. In making this determination, the Secretary i s required to determine which ty pes of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:  The UASs size, weight, speed, and operational capability ;  Operational of the UAS in close proximity to airports and populated areas; and Operation of the UAS within visual line of sight of the operator.

Reform Act . 333 (a)(1) If the Secretary determines that such vehicles “may operate safely

in the national airspace system, the Secretary s hall establish requirements f or the safe operation of such aircraft in th e national airspace s ys tem.” Id 333(c) The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by

its terms , includes exempting civil aircraft, as the term i s defined under 40101of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exempti on from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702
- 44716 of this title if the Administrator finds the exemption is in the public interest. 49 USC 44701(f) See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91 .203(a)(1). The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost saving associated with transitioning the UASs for aerial survey photography. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay
. 

### Airworthiness of the Inspire1 A critical element of the exemption application involves evidence of the airworthiness of the Inspire1. AI believes that it is in compliance with the requirements of Order 8130.34C, Airworthiness Certification of Unmanned Aircraft System and Optionally P iloted Aircraft, in its use of systems developed by

D JI . The Inspire1 has a high degree of redundancy and numerous safety features, including:  Return - to - home failsafe in the event of a loss of communications  Configurable limitations for area of operation and altitude  Configurable limitations for vertical and horizontal speeds  High visibility

lighting system The criteria set forth in the Order specify the substantive showings of the device’s safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety. 

### Mandatory Operating Conditions Grant of the exemption to Aero Images LLC will be subject to the following mandatory c onditions, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of Authorization, with additional restrictions:  All operations to occur in Class G airspace.  Operations to avoid congested or populated areas, which are depicted in yel low on VFR charts Operations to be conducted over private or controlled
- access property.

 Permission from land owner/controller required before commencing any flight.  Operations to occur during Visual Flight Rules Meteorological Conditions (VMC)  Aircraft to remain within Visual Line of Sight (VLOS). 1. VLOS guaranteed with a cylinder operation around operator of 1⁄2 nautical miles (NM) 2. Cylinder walls may

be expanded by

observer with ability

to control aircraft  Operations to occur during daylight hours  Altitude restricted to 400 feet Above Ground Level (AGL)  All operations conducted in vicinity o f airport to remain more than 2.5 NM from centerl ine azimuth of runway

centerline measured from runway thresholds.  Operator will file a NOTAM for each flight as required  All required permissions and permits would be obtained from territorial, state, county or city jurisdiction, including local law enforcement, fire, or other appropriate governmental agencies. 

### Operator Requirements AIrespectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Certain UASs, such as the AI s Inspire1, are characterized by a high degree of pre programmed control and various built
- in technical capabilities that l imit the potential for operation outside of the operating conditions set forth above. The Inspire1 has a semi
- autonomous navigation and control system comprised of a Ground Control Station (GCS) and autopilot system. All flights are pre -programmed with GP S guidance and do not require human intervention. Flight mission area and routing cannot be changed after launch. Flights are not directed by

positive manual control, nor are evasive maneuvers. In the case of unplanned events, the operator inputs pre -programmed evasive maneuvers from the control unit and the control units ex ecutes that maneuver. Pre -programmed operator interventions include diversion to the right ; initiation of holding at present position; suspension of mission; fly b ack to launch point; f

ly to point and hold; abort mission and land; and emergency p ower cut off and land (Flight Termination System). 7 Additional automated safety

functions and safety- enhancing features of the Inspire1 include the following:  Autopilot detection of lost GPS or of insufficient satellites initiates an immediate vertical landing, unless overridden by pilot in command.  Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.  If the autopilot detects a lost
- link to the GCS for longer than 30 seconds, return - to - home sequence initiates.  The Inspire1 is inherently unstable, so auto
-pilot failure will result in a rapid exit from flight.  Aircraft has an on
-board failsafe that limits vertical speed to approximately 6 m/s (con figurable).  The aircraf

t, weighing less than 7 lbs., fully l oaded, is constructed of composite material intended to absorb impact energy
.  The motors are driven b y pulse width modulated signals, not analog signals. Given this safety features, Aero Images proposes that operators of the Inspire1 should not be required to hold a commercial or private pilot certification, although the owner
- operator and chief pilot of AI, holds an ATPLcertification. Instead, operators should be required to: Have successfull y completed, at a minimum, FAA private pilot ground instruction and passed

the FAA Private Pilot written examination or FAA
- recognize equivalents.  Have successfully

demonstrated capability to operate UAS in accordance with manufacturer standards. AInotes that the FAA has found that safety factors permitted operations of UASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N - 89 00.227, Unmanned Aircraft System (UAS) Operational Approval, at 20 - 21 (July 3 0, 2013). The FAA has the statutory a uthority to grant exemptions to the requirements for and privileges associated with the grant of airmen’s certificates. 49 USC 44701 (f). In summary, applicant seeks and exemption from the FARs set forth above and in Appendix A to allow commercial operations of a small
-unmanned vehicle conducting precision aerial surveys. Approval of the exemption allowing commercial operations of the Inspire1 for precision survey w ork will enhance safety by

reducing risk. Conventional aerial survey operations, using jet or piston
-powered aircraft present risks associated with v ehicles that weight in the neighborhood of 5,000 to 7,000 lbs., or more, carry

l arge quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fl y to and from the survey

l ocation. In contrast, an Inspire1 weighing less than 7 lbs. and powered by s mart batteries eliminates a portion of that risk given to reduce mass and lack of combustible fuel carried on board. The Inspire1 is carried to the survey l ocation , not flown there. The In spire1 will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights. Additionally, no national security issue is raised by the grant of the requested exemption. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the Inspire1 poses no threat to national security. The operation of the Inspire1, weighing less than 7 lbs., for precision surveys in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting Aero Images LLC from the requirements of Part 21. The Inspire1’s satisfaction of the criteria set forth in Section 333 of the Reform Act

—size, weight, speed, operating capabilities, lack of proximity to airports and populate d areas, operating within visual line of sight, and national security —and its showing of an equivalent level of safety as it may relate to the requirement of a pilot’s license, provide more than adequate justification for the grant of the requested exempti ons allowing commercial operation of the Inspire1 in the commercial precision aerial survey busin ess. Very Respectfully, Miguel S. De Felice Aero Images LLC