04 August 2015

U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

Subject: Petition for Exemption under Section 333 of the FAA Modernization & Reform Act and Title 14, Part 11 of the Code of Federal Regulations (CFR)

De ar Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act a nd 14 C.F.R. Part 11, FlightGraphix LLC, a Texas based Limited Liability Company, hereby applies for exemption from certain Federal Aviation Regulations, utilizing the commerci a l operation

of the DJi Phantom Vision 2+ UAS ( N568AF )

. The requested exemption would support an application for a “ blanket ” commercial Certificate of Authorization (COA) to operate

the DJi Phantom Vision 2+ UAS with the following flight restrictions:

• Flight opera tions below 200 feet AGL

• UAV will less than 55 pounds

• Flight operations during daytime Visual Flight Rules (VFR) conditions and within visual line of sight (VLOS) of the pilots

• And during flight, stay ing certain specified distances away from airports or

h eliports

FlightGraphix LLC service offerings consists of collect ing aerial data for surveys, inspections

, and marketing in construction, roofing, and real estate

. FlightGraphix LLC,

will serve all three types of markets in the residential, commercial, and government

sectors. The operations will commence in the North Texas region and later expand into other geographical areas throughout the state and nation. The DJi Phantom Vision 2+

UAS consists of

- a lightweight, battery operated aircraft (2.73 lbs inclu ding batteries and propellers ), a computer based ground control station with video downlink support, a remote control with range extender, and an onboard camera with a secure gimbal mount.

The DJi Phantom Vision 2+ is a popular and compliant UAS , having pr eviously demonstrated to meet specific safety and operational requirements. Some of the Dji

Phantom Vision 2+ features consist of: auto

- return home and landing, intelligent orientation control, advanced power management, precision flight and stable hoverin g, and a 25 minute flight time with a smart battery (data retrieved from http://www.dji.com/product/phantom

- 2

- vision

- plus/spec ).The UAV will be carrying the

standard

- equipped Phantom Vision 2+ HD camera attached with the standard gimbal

mount. The hardware will be downlinked to a Ground Station on the 2.4 GHz frequency

band . The Pilot in Command (PIC) will be using the DJi Pilot mobile app , or other apps developed specifically for the Phantom Vistion 2+

, for aircraft navigation and data
storage

. The DJi Pha ntom Vision 2+ will be later be separately equipped with an infraredsensor for infrared inspections

, once UAV’s are approved for night flight (pending FAA regulation approval).

The UAS will be observed at all times through line of sight with a Pilot in C ommand (PIC) and a Visu al Observer (VO). The high

- resolution aerial data colle cted through t he

onboard high

- definition camera and infrared sensors will provide information that will be in high demand in the roofing, real estate, and construction industry

. Also, any research and development will consist of a PIC and VO using the onboard camera, infrared sensor, and downlink to collect data benefiting the roofing and construction industry.

The aircraft will be operated in accordance with both a PIC and a VO

, in accordance

with

, FAA Order 8900.1 Volume 16 “Unmanned Aircraft Systems” with the following

rules and exemptions :

• All opera tions will not take place over 4 00 feet AGL in any airspace, but can
operate in controlled airspace (Class C, Class D, and Class E) and uncontrolled airspace (Class G) in accordance with FAA Order 8900.1 Volume 16

. The PIC will, at a minimum, hold a FAA private pilot’s license and have a current third

class medical certificate

.

• The aircraft will not exceed an airspeed of 5 0 knots.

• The weight of the aircraft will never exceed 20 lbs. when fully equipped.

• FlightGraphix LLC will perform any necessary requirements to inform aircraft and airmen in same controlled and uncontrolled airspace of our operations

.

• Operations will take place ov er public or private property with prior permission and signing of a waiver by land owner and/or homeowner and flying will be confined to the property.

• When necessary, applicable permits will be requested from local authorities

.

• The aircraft will not be op erated over densely

- populated urban areas, but will take place in suburban and rural areas

• The aircraft will not be operated at air shows or over a large, open mass of people

• The aircraft will not operate over roads with high

- density traffic

• The aircraft w ill not operate in high wind conditions

• The aircraft will be kept away from high voltage power lines, trees, and bodies of water while in flight

• FlightGraphix LLC will take notice to no

- fly zones and temporary flight restrictions (TFR)

• The aircraft will no t be operated within 5 nautical miles of an airport or helipad, unless prior permission is first granted through air traffic control (ATC), or the proper authorities

• Operations will be limited in windy conditions and operations will not commence
if wind ex ceeds 15 knots

• Operations will be limited to day, visual meteorological conditions

• Aircraft will remain within 500 feet of the PIC and VO and within line of sight.

• While the aircraft is in flight, the VO will remain within voice distance with the

PICBa sed on a full y qualified flight crew, the UAS aircraft model , and general compliance with most of the regulations for UAS operations, the FAA can have the greatest confidence that FlightGraphix LLC will operate in safe and knowledgeable

manner at all times during their operations. Additional documents will be supported with this request, including a Certificate of Authorization (COA).

Sincerely, Christopher M. Suldo

FlightGraphix LLCChris Suldo FlightGraphix LLC

28 07 Allen St. #379 Dallas, TX 75204

Phone Number: 817

- 703

- 2448

E

- mail: csuldo@gmail.com Website(s): www.flightgraphix.com

Relief Sought From Following Section(s):

FlightGraphix LLC petitions for exemptions from t he following regulations listed in Title 14 Code of Federal Regulations (CFR):

• 14 CFR Part 21, Subpart H

• 14 CFR Part 45.23

• 14 CFR Part 45.27

• 14 CFR Part 45.29

• 14 CFR Part 61.113

• 14 CFR 61.133

• 14 CFR Part 91.9

• 14 CFR Part 91.103

• 14 CFR Part 91.109 (a)

• 14 CFR Part 91.119

• 14 CFR Part 91.121

• 14 CFR 91.151

• 14 CFR 91.405

• 14 CFR 91.407

• 14 CFR 91 .409

• 14 CFR 91.417

Relief Defined For Exemption

In order to perform these commercial operations, FlightGraphix LLC will seek relief in the following manner:

• 14 CFR Part 21, Subpart H These regulations state procedural re quirements for the issue of air worthiness certificates and 21.19 (a) addresses research and development including testing new aircraft design concepts, new aircraft equipment, new aircraft instal lations, new aircraft operating techniques, or new uses for the aircraft. FlightGraphix LLC
requests an exemption from this regulatory 14 CFR Part 21, Subpart H

, due to the

fact the UAS will be in compliance with safety a nd FAA airworthiness standards,wit hout the need for an airworthiness certificate. The aircraft will not be carrying

any passengers or fuel and will fly under strict operational requirements and supervision.

• 14 CFR Part 45.23

- Display of Marks These regulations state that each aircraft display an “N” and the aircraft’s registration number and letters are at least three inches high. Drone Roofing & Construction LLC requests an exemption from 45.23. If the FAA requires an “N” number to be placed on the UAV, the aircraft N

- Number will be si zed and displayed, according to the amount of space available on the UAV

.

• 14 CFR Part 45.27

– Location of Marks These regulations state that each operator of the rotocraft must display on that rotorcraft horizontally on both surfaces of the cabin, fusela ge, boom, or the tail marks required by 45.23. FlightGraphix LLC requests exemption from 45.27 and

will locate the marks on the UAV according to the amount of space available.

• 14 CFR Part 45.29

– Size of Marks These regulations state that on rotorcraft t he marks need to be at least 12 inches high and two

- thirds as wide as they are high. FlightGraphix LLC requests exemption from 45.29 and the marks will be sized on the UAV, according to the amount of space available.

• 14 CFR Part 61.113

– Private Pilot Pr ivileges and Limitations: Pilot in Command and 61.133 Commercial Pilot Privileges and Limitations

FlightGraphix LLC currently requests exemption from 14 CFR Part 61.113 and

14 CFR 61.133

. Drone Roofing & Construction LLC proposes if the operation takes pl ace in controlled airspace ( Class C, Class D, Class E) and/or uncontrolled airspace (Class G) the PIC will, at a minimum, hold a FAA private pilot’s license and possess a current third class medical certificate. FlightGraphix LLC will be operating for comm ercial purposes, line of sight (500 feet) and under 400 ft AGL. The UAS has navigation and a control unit

, compris ed of a Ground Control Station ( GCS) and auto

- pilot system

, and all flights will utilize precision GPS guidance. In the case of unplanned even ts, the operator can input evasive maneuvers from the control unit, and the control unit executes that maneuver. Operator interventions include

- diversion to the right, initiation of holding at present position, suspension of mission, fly back to launch p oint, fly to point and hold, abort mission and land, and em ergency power cut off and land ( Flight Termination System). By having these control capabilities, we believe the PIC will be fully capable of operating the UAS in commercial operations in

uncontrol led and controlled airspace in commercial operations.• 14 CFR Part 91.9

– Civil Aircraft Flight Manual, Marking, and Placard Requirements

This regulation requires that no person may operate an aircraft unless a current, approved flight manual is in the a ircraft. Since the aircraft is too small to carry documentation and the aircraft is unmanned, we would like to request exemption

from this 91.9 . However, the PIC and VO will carry a current an aircraft flight

manual near the ground station during all opera tions.

• 14 CFR Part 91.103 This regulation requires that each pilot in command takes certain actions before flight to ensure safety of the flight operations. FlightGraphix LLC would like to request an exemption from 91.103. FlightGraphix LLC will be perfo rming their own quality pre

- flight inspections

– to include

– checking weather and atmospheric conditions for flight permissibility, checking battery requirements, checking landing zones, and inspecting the equipment for any malfuctions or structural probl ems.

• 14 CFR Part 91.109 (a) This regulation requires dual controls for for civil aircraft involved in flight

instruction. FlightGraphix LLC would like to request an exemption from 91.109(a) and will be utlizing the UAS in commercial operations and flight

instruction as a remotely operated aircraft. Therefore, dual controls will not be a necessary requirement for commercial operations and/or flight instruction.

• 14 CFR Part 91.119

– Minimum Safe Altitudes

– General

This regulation specifies that over spa rsely populated areas, aircraft cannot be operated closer than 500 feet to any person, vehicle, vessel, or structure. Since the aircraft will be operating at less than 400 ft AGL

, FlightGraphix LLC will request an exemption from 91.119.

Our safety measur es include notifying the land or property owner before hand and receiving permission to fly within 500 ft. The land or property owner will be informed of all possible hazards and risks associated with the flight to people and property. Due the light weight of the DJi Phantom Vision 2 + , the unmanned aircraft does not pose such a safety threat like a manned aircraft poses to people and property. The DJi Phantom Vision 2 + will not be operated over any open air assembly of people. In case of a mechanical sy stem failure, the DJi Phantom

Vision 2 + will be operating at an altitude where a safe emergency landing can occur without any hazards to people or property. FlightGraphix LLC will be keeping a minimum of $1,000,000 dollars in liability insurance.

• 14 CFR Part 91.121This regulation states that aircraft shall maintain cruising altitude by reference to an altimeter setting available within 100 nautical mile s of aircraft. FlightGraphix LLC will request an exemption to 91.121. The DJi Phantom Vision 2+ will be fly ing below 400 ft AGL and the altitude will be determined based on the barometric pressure at the time of flight. Since the maximum operating time for

the DJi Phantom Vision 2 + is approximately 25 minutes, there will not be a rapid change in barometric pres sure affecting altimiter settings.

• 14 CFR 91.151 This regulation states that no person may begin a flight in an airplane under Visual Flight Rules (VFR) conditions

, unless there is enough fuel to fly to the first point of intended landing and, assuming n ormal cruising speed, (1) During the day, to fly for at least 30 minutes; or (2) At night, to fly after that for at least 45

minutes. FlightGraphix LLC will request an exemption to 91.151. The DJi Phantom Vision 2+ is a battery operated aircraft and the ma ximum operation of the flight with full payload is 25 minutes . Since the aircraft will never fly more than .5 miles from the point of intended landing, a full battery charge at launch and landing the aircrat with 20% charge (5 minutes) is more than enough time for performing a landing.

• 14 CFR 91.405 This regulation requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in Subpart E of the same part and shall, between required inspections, except a s provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. FlightGraphix LLC will request an exemption to 91.405. FlightGraphix LLC will inspect the UAS prior to each flight for mechanical or struc tural discrepancies and

malfunctions to ensure airworthiness. Drone Roofing Solutions will follow the maintenance requirements set forth by the manufacturer

– DJi. Additionally, FlightGraphix LLC will perform maintenance dealineated by the FAA as pertinent for UAS operations.

• 14 CFR 91.407 This regulation requires that no person may operate any aircaft that has undergone maintenance, preventitive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authoriz ed under 43.7 of the same chapter. FlightGraphix LLC will request an exemption from 91.407. The PIC, VO, and authorized personnel will ensure proper maintenance and inspection of the aircraft and be fully authorized to approve aircraft fit for flight.

• 1 4 CFR 91.409 This regulation requires inspections of an aircraft

. FlightGraphix LLC will request an exemption from 91.409. The PIC, VO, and authorized personnel will ensure proper maintenance and inspection of the aircraft and be fully authorized to

approv e aircraft fit for flight.• 14 CFR 91.417 This regulation requires records being maintained f or maintenance and alterations and how long to keep the records. FlightGraphix LLC will ask for an exemption

from 91.417. FlightGraphix LLC does not feel the mai ntenance and alterations performed to the UAS will n eed to be documented.

Benefit To The Public

In 2009, four of the top 10 most frequently cited OSHA violations were directly related to commercial roofing, including: scaffolding requirements, fall prot ection and training, and ladder requirements. Out of numerous possible violations, scaffolding was first and fall protection was second. In 2008, more than 1,200 scaffolding

- related citations were issued with more than $1.1 million in penalties. Clearly it is a common safety violation, as well as a financially burdensome one.

Additionally, fall protection takes center stage in commercial roofing safety, as falls are one of the leading causes of death in commercial industries. According to the National

Safe ty Council, over 6,000 people die from falls each year caused by such factors as falling off roofs and ladders. And to emphasize the importance of safety in the commercial roofing industry

- more than 30,000 people are injured annually as a result of

falls involving ladders.

FlightGraphix LLC’s operations will benefit the public by offering a safer solution for roofing inspections, surveys, and estimates. Roof inspections are one of the most dangerous jobs today, and utilizing UAVs, the roofers/adjusters wo uld not have to walk around roofs for roofing inspections/surveys/estimates. Additionally, FlightGraphix LLC

‘s will be operating unmanned aircraft that poses no flight risks to pilots.

Through our UAS operations and research and product development unde rtakings, we will be able to more effectively troubleshoot roofing issues, save time and money for contractors and insurance companies, and provide better solutions for our clients in roofing and construction industry.

Additional benefits include local j ob crea tion due to hiring of staff under our Company.

Argument in Support of Application

FlightGraphix LLC understand the important and value of using UAV’s and UAV technology in the roofing and construction industry. FlightGraphix LLC is filing for a

p etition under Section 333 of the FAA Modernization & Reform Act, in order to become an independent provider of inspection, monitoring, surveying, and measuring services to

- contractors, residents, businesses, governments, and any other entities. The use o f a UAS will provide time and cost savings for residential, commercial, and government clients

. Because of this time saving solution, the UAS flying service(s) will be in high demand in roofing and construction. We will utilize the proven DJi Phantom Visio n 2+ camera and

aircraft sensors f or our operations.In the roofing industry, a demand exists for this service due to safety issues that exist when roofers access dangerous roofs for inspections and/or measuring. It is extremely dangerous for roofers to walk on roofs, especially roofs with a high pitch and many steep angles. Our Company can completely eliminate this risky procedure by using our UAS platform to perform the service for private and public clients.

In the construction industry, a demand ex ists due to cost and time constraints. It is relatively cheaper and quicker to perform the surveying, inspection, and monitoring

services utlizing an unmanned aircraft, rather than a manned aircraft.

Safety and Adherence and Benefit Thereof

FlightGraphi x LLC will at all times operate UAVs within visual line of sight of the operator, fly less than 400 feet AGL, and only during daylight conditions. The operations will take place inside Class G (uncontrolled airspace) and, if flying in controlled airspace, FlightGraphix LLC will obtain prior approval from ATC before operations can commence. Before each flight, the UAVs and ground station systems will be visually and operationally inspected for any mechanical or structural problems as part of pre

- flight

safet y measures. Any additional UAV pilots flying for FlightGraphix LLC will have to be approved by the FlightGraphix LLC owner to ensure they are capable of flying the UA S in a safe and effective manner. This may involve additional flight trainin g outside of

n ormal operations. FlightGraphix LLC will at all times follow all applicable regulations

listed in 14 CFR Parts 60 and 91. The owner of the Company is FAA certified rotorcraft private pilot and acknowledge s and understand s the NAS and the FAA’s rules and

re gulations. We will also be attending UAV operating and educational classes to provide a more effective and safe flying service. The owner also possess direct experience in airspace regulations, aeronautics, traffic patterns, flying, pilot training, mainten ance, and safety standards. This will provide extra safety measures beyond what a normal UAV

operator may possess. FlightGraphix LLC will also carry liability insurance with a minimum of $1,000,000 in coverage.

Summary That Can Be Published In The Fed eral Register

Description of Relief Sought:

The Limited Liability Company, FlightGraphix LLC , is requesting a petition for exemption under Section 333 of the FAA Modernization & Reform Act and Title 14, Part 11 of the Code of Federal Regulations (CFR). The Company will operate the DJi

Phantom Vision 2+ with a n equipped HD camera on a camera mount downlinked to a 2.4 Ghz ground station on a commercial basis. FlightGraphix LLC service offerings consists

of collect ing aerial data for surveys, inspections

, and marketing in construction, roofing,and real estate

. FlightGraphix LLC, will serve all three types of markets in the residential, commercial, and government sectors. FlightGraphix will be geographically expanding at

a future date. FlightGraphix LLC will also be using the DJi Phantom Vision 2+ with a equipped ca mera for research and pro duct development in the roofing and construction industry. These operations will assist clients with their real estate and construction product and service needs. The Company will abide by FAA laws and regulations governing operations of aircraft in the National Airspace System (NAS).

Petitioning Company:

FlightGraphix LLC

FAR’s that FlightGraphix LLC Will Be Petitioning For Exemption:

FlightGraphix LLC petitions for exemptions from the following regulations listed in Title

14 Co de of Federal Regulations (CFR):

• 14 CFR Part 21, Subpart H

• 14 CFR Part 45.23

• 14 CFR Part 45.27

• 14 CFR Part 45.29

• 14 CFR Part 61.113

• 14 CFR 61.133

• 14 CFR Part 91.9

• 14 CFR Part 91.103

• 14 CFR Part 91.109 (a)

• 14 CFR Part 91.119

• 14 CFR Part 91.121

• 14 CFR 91 .151

• 14 CFR 91.405

• 14 CFR 91.407

• 14 CFR 91.409

• 14 CFR 91.417