March 11 , 2016

Docket Operations, M

- 30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue Room W1 2

- 140 We st Building Ground Floor Wa shington, DC 20590

- 0001

**RE:** Petition for Exemption under Section 333 FAA Modernization and Reform Act of 2012, Public 112

- 95 February 14, 2012, Section 333

Dear Sir or Madam:

Attached you will find my request for an exemption from the listed Federal Aviation Regulations to allow for commercial operations of a s mall Unmanned Aircra ft System ( UAS ) for aerial videography and photography for public and private use including, but not limited to, marketing of residential and commercial real estate.

I thank you for your time and consideration of this request. Should you have any questions or concerns plea se do not hesitate to contact me

.
**Introduction** Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Kenneth Duquaine (DBA Aeria l Photography Services) , hereby applies for an exemption from the listed Fede ral Aviation Regulations (FARs ) to allow commercial operation of his s ma ll Unmanned Aircraft Systems ( UAS ) for aerial imaging of residential and commercial real

es tate for advertising purposes s o long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As detailed in this document, the requested exemption would permit the operation of UAS 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 best practices safety protocols followed by the applicant. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "...establish requirements for the safe operation of such aircraft s ystems in the national airspace system" s ection 333(c) of the Reform Act. This exemption request is specifically for the use of a DJI Phantom 2 Vision+, which is on the FAA list of approved UAS under Section 333 as of February 18, 2016.

**Regulations from which the exemption is requested:**

14 C.F.R. Part 2114 C.F.R. 45.23( a & b)

14 C.F.R. 61.113 (a & b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 (a) 14 C.F.R. 91.119 14 C.F.R. 91.121 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) and (b).

**Exemption A pplicant**  **Contact Information** Kenneth R. Duquaine 4397 Top O Pines Drive Holly, MI 48442 (248) 634

- 2122 (248) 634

- 2123 (248) 342

- 0790 (mobile) kduquaine@h otmail.com windshoppe@comcast.net

**Intended S UA** **S Use**

The petitioner, Kenneth Duquaine, plans to use UAS in order to capture aerial video and photographs for the purpose of enhancing rea l estate listings. By allowing the requested exemption, FAA will provide the petitioner with a method for capturing aerial photos and video that are more economically accessible to the communities he intend s to serve, more environmentally friendly, and safer because of the UAS’s light weight, lack of combustibl e fluids, and not having to carry human occupants. The petitioner believes such advantages to be in the public’s best interests. All d eployment of UAS for the purposes stated will be with the permission of property owners.

**Extent of Relief Sought and Rea sons for Seeking Relief** 

Kenneth Duquaine submits this petition in accordance with Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable federal aviation regulations FARs pertaining to operation of UAS which prevent the petitione r from commencing commercial photographic flight operations within the U.S. national airspace

. The Reform Act in § 332 provides for such integration of civil UAS into our national airspace system as it is in the public’s interest to do so.The petitioner’s small and lightweight UAS, not exceeding 7 lbs, meet s the

definition of “small unmanned aircraft” as set forth in § 331. The petitioner requests exemption to use his UAS to capture videography and photography for real estate listings. The petitioner understand s that the FAA is committed to safely integrating UAS into national airspace and believe s that his many hours of experience safely operating UAS since the advent of the technology qualifies him as a candidate for exemption. Additiona lly, the petitioner requests the following facts be taken into consideration:

a. Th e size and weight of his UAS is under 7 lbs b. His UAS will be operated commercially at low speeds always less than 20 knots

c. His UAS is outfitted with the mos t up to d ate safety and fail

- safe features d. The petitioner is a very experienced UAS operator

e. The petitioner will strictly adhere to all of the “Conditions and Limitations” applied to rece nt grants for similar petitions, as well as any introduced in the fut ure.

**The petitioner request** **s exemption from the following specific regulations:** 

**14 C.F.R Part 21 Certification Pr ocedures for Product and Parts,**  **Ai rw**  **orthiness Certificates**

The FAA is authorized to exempt UAS from the requirement for an airworthiness certificate upon consideration of the size, speed, weight, operational capability, proximity to airports and populated areas, and whether operation within visual line of sight creates a hazard to users of the national airspace system or the public. Because the petitioner plans to operate a DJI Phantom 2 Vision +, weighing no more than 7 lbs under extremely controlled circumstan ces as set forth herein and intends to keep speeds at less than 20 knots, he requests an exemption from the above.

**14 C.F.R. 45.23 (b) Display of Marks: General and 45.29 Size of Marks**  **(a) Each operator of an aircraft must display**  **on that aircraft marks consisting of the Roman capital letter "N" (denoting United States**  **registration) followed by the registration number of the aircraft. Each**  **suffix letter used in the marks display ed must also**  **be a Roman capital letter.**  **(b) When marks include only**  **the Roman capital letter “N” and the registration number is display** **ed on limited, restricted or light**

**- sport**  **category**

**aircraft or experimental or provisionally certificated aircraft,**  **the operator must also display**  **on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches**  **nor more than 6 inches high, the words “limited,” “restricted,” “light**

  ** sport,” “experimental,” or “provisional,” as applicable.**The siz e of the UAS the petitioner plans to use is not large enough to

accommodate the required size of the registration numbers. The petitioner requests relief from the above requirement on the grounds that it is not applicable at this time. The petitioner’s UAS is currently registered with the FAA and its applicable registration numbers are displayed on the UAF as required under the existing FAA guidelines.

**14 C.F.R. 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in**  **Command (a) Except as prov**  **ided in paragraphs (b) through (h) of this section, no person who holds**  a **private pilot certificate may act as pilot in command of**  **an aircraft that is carrying passengers or property for compensation or**  **hire; nor may**

**that person, for compensation or hire, act as pilot in**  **command of an aircraft. (b)**  **A priv** **ate pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any**  **business or employ ment if:**  **(1)The flight is only**

**incidental to that business or employ ment; and**  **(2)T he aircraft does not carry**  **passengers or property for compensation or**  **hire.**

The petitioner’s UAS will not carry a pilot or passengers. Traditional operations in the past required a person or persons to elevate in a potentially combustible vehicle in ord er to carry out the same operations the petitioner plan s to accomplish by way of UAS. Because the petitioner will operate in a controlled environment, at low altitudes and speeds, with no persons on board, using a light weight vehicles, the risks are subst antially less than in the past. The petitioner also requests exemption regarding the limitations of compensation for hire since h e will be charging clients for videography and photography in the real estate market.

**14 C.F.R. 91.7 Civil A ircraft Worthines**  **s (a) No person may** 

**operate a civil aircraft unless it is in an airworthy condition.**  **(b) The pilot in command of a civil aircraft is responsible for determining**  **wh ether that aircraft is in condition for safe flight. The pilot in command**  **shall discontinue the flight w**  **hen unairworthy mechanical, electrical, or**  **structural conditions occur.**

In the event that an exemption is granted, there will be no airworthiness certificate issued for the petitioner’s UAS. Wi thout an airworthiness certificate, no FAA regulatory standard will exist for determining airworthiness. As outlined above and in attached exhibits, the petitioner is committed to incorporating strict safety and operational procedures in order to create an adequate level of safety that should exceed current standards.**C.F.R.91.9(b)(2) Civil A ircraft Flight Manual, marking and placard** 

**requirements (b) No person may** 

**operate a U.S.**

**- registered civil aircraft** 

**— (1)For w**  **hich an A irplane or Rotorcraft Fl**  **ight Manual is required by § 21.5 of**  **this chapter unless there is available in the aircraft a current, approved Ai**  **rplane or Rotorcraft Flight Manual or the manual provided for in § 121.141(b); and**  **(2)For w hich an A**  **irplane or Rotorcraft Flight Manual is no t required by**  **§ 21.5 of this chapter, unless there is available in the aircraft a current**  **approved Ai**  **rplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any**  **combination thereof. (c) No person may** 

**operate a U.S.**

**- registe**  **red civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.** 

Since the UAS the petitioner plan s to use is not large enough to carry documentation and do es not have on board pilots, it does not have the ability to carry such documents. The petitioner can recreate the same standard of safety by having the required manuals on hand during each flight.

**C.F.R. 91.103 Pre**

**- Flight A** **ction Each pilot in command shall, before beginning a flight**  **, become familiar with all available information concerning that flight. This information must**  **include**

**— (a)For a flight under IFR or a flight not in the vicinity of an airport, weather**  **reports and forecasts, fuel requirements, alternatives available if th e**  **planned flight cannot be completed, and any know**  **n traffic delays of w hich**  **the pilot in command has been advised by A TC;**  **(b) For any**

**flight, runway**

**lengths at airports of intended use, and the follow**  **ing takeoff and landing distance information: (1)For c**  **ivil aircraft for w hich an approved A**  **irplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff**  **and landing distance data contained therein; and**  **(2)For civil aircraft other than those specified in paragraph (b)(1) of this**  **section, other reliable information appropriate to the aircraft, relating to**  **aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.** 

There is no pre

-flight manual to refer to in regards to the UAS the petitioner plan s to use. The petitioner will apply all pre

-flight recommendations from the Manuals provided from the manufacturer along with his own safety measures as outlined herein

. The petitioner is committed to incorporating all of the safety measures illustrated throughout this petition as well as evolving practices as needed to ensure a high level of safety.

**C.F.R. 91.109(a) Flight Instruction; Simulated Instrument flight and certain flight tests** 

**(a) No pers on may** 

**operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully**  **functioning dual controls. However, instrument flight instruction may be**  **given in an airplane that is equipped with a si ngle, functioning throw**  **over control w**  **heel that controls the elevator and ailerons, in place of fixed, dual controls, when** 

**— (1)The instructor has determined that the flight can be conducted safely**  **; and**  **(2)The person manipulating the controls has at least a private pilot**  **certificate with appropriate category and class ratings.** 

Because the UAS is radio controlled and operated, it does not have fully functional dual controls. It is

, however, outfitted with very effective safety features that assist the craf

t in returning to a safe landing zone that is designated before flight if the Pilot in Command ( PIC ) is no longer able to operate the UAS. The petitioner does not consider this regulation applicable and requests exemption.

**C.F.R. 91.119 Minimum Safe A lti**  **tudes Except when necessary**  **for takeoff or landing, no person may operate an**  **aircraft below the follow ing altitudes:**  **(a)A ny**  **wh ere. A**  **n altitude allowing, if a power unit fails, an emergency landing without undue**  **hazard to persons or property on the surfac**  **e. (b)over congested areas. Over any**  **congested area of a city , town, or**  **settlement, or over any open air assembly of persons, an altitude of 1,000**  **feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.**  **(c)Over other tha n congested areas. A**  **n altitude of 500 feet above the surface, except over open water or sparsely**  **populated areas. In those cases, the aircraft may not be operated**  **closer than 500 feet to any person,**  **vessel, vehicle, or structure.** Page **8** of **19 d)**  **Helicopters, powered parachutes, and weight**

**- shift** 

**- control aircraft. If the** 

**operation is conducted without hazard to persons or property on the**  **surface**

**— (1) A**  **helicopter may**

**be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the**  **helicopter complies with any routes or altitudes specifically**  **prescribed for helicopters by** 

**the FAA ; and**  **(2) A**  **pow ered parachute or weight** 

**- shift** 

**- control aircraft may**  **be operated at less than the minimums prescribed in paragraph (c) of this section.** 

The petitioner asserts that the above is not applicable and believes it is in the interest of safety to maintain s trict rules for maximum altitudes. The petitioner will not be operating his UAS commercially above 2 00 feet. His UAS do es not contain flammable or combustible fluids and

, therefore

, offers a safer circumstance compared to current standards. The petitioner’s UAS is also small and lightweight and is designed to automatically return to safe landing zones in the event of an emergency. Risks are minimized through operating in extremely controlled circumstances as outlined in this petition.

**C.F.R. 91.121 A ltim**  **eter Settings Requires each person to reference an altimeter** 

The UAS the petitioner plans to use utilizes GPS for altitude readings. Safety can be achieved by referencing the GPS data before and during each flight. The petitioner believe s that an exempt ion for this regulation is necessary on the basis that an adequate level of safety and adherence to the purpose of the regulation can be achieved through the GPS readings.

**C.F.R. 91.151(a) Fuel requirements for flight in VFR conditions. (a) No person ma**  **y begin 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 fo**  **r at least 30 minutes; or (2) A**  **t night, to fly after that for at least 45 minutes.**

The petitioner requests an exemption to the above regulation on the basis that the UAS he plan s to use do es not carry fuel and will only be used during daylight hours. Operations will only be conducted under clear and favorable conditions. The petitioner’s UAS is also outfitted with automatic return home features when the batter

y life reaches a certain level of depletion.

**C.F.R. 91.203 (a) &(b) Civil aircraft: Certifi cations required.** **(a) Except as provided in § 91.715, no person may operate a civil aircraft**  **unless it has within it the following: (1) A**  **n appropriate and current air worthiness certificate. Each U.S.**  **airworthiness certificate used to comply with this sub**  **paragraph (except a special flight permit, a copy**  **of the applicable operations specifications issued under § 21.197 c of this chapter, appropriate sections of the air**  **carrier manual required by parts 121 and 135 of this chapter containing that**  **portion of t he operations specifications issued under § 21.197 c or an**  **authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter . However, the**  **airworthiness certificate need not have on it an assigne d special**  **identification number before 10 day s after that number is first affixed to the**  **aircraft. A**

**rev ised airworthiness certificate having on it an assigned special**  **identification number, that has been affixed to an aircraft, may only**  **be obtained upon a**  **pplication to an FAA Flight Standards district office.**  **(2) A n effective U.S. registration certificate issued to its owner or, for**  **operation within the United States, the second copy of the**  **Ai rcraft**  **registration A pplication as provided for in § 47.31 c or**  **a registration certification issued under the laws of a foreign country** 

**. (b) No person may** 

**operate a civil aircraft unless the airworthiness certificate required by paragraph**  **(a) of this section or a special flight authorization issued under § 91.715 is**  **display ed at the cabin or cockpit entrance so that it is legible to**  **passengers or crew.**
The petitioner’s UAS is not capable of carrying certification and registration documents and therefore he believe s this is inapplicable. There is no onboard pilot and such documents would need to be produced by the ground operator. The petitioner will ensure that all docu mentation required by the FAA are on hand at ground level during all flight o perations.

**C.F.R. 91.405 (a) Maintenance Required Each owner or operator of an aircraft** 

**— (a) 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 prescr ibed in part 43 of**  **this chapter**

The petiti oner seeks exemption from the above on the basis that in the event of a grant, there will be no applicable airworthiness certificate. Though in the interest of assuri ng a high level of safety, the petitioner is committed to obtaining any repairs or replacements immediately from the manufacturer.

**C.F.R. 91.407 (a) (1) Operation after Maintenance, Preventative Maintenance, Rebuilding, or**  **(a) No person may**

**operate any**

**aircraft that has undergone maintenance, preventive maintenance, (1) It has been approved for return to service by**  **a person authorized under § 43.7 of this chapter** 

The petitioner points out that at this time there are no persons a uthorized to certify the model of UAS he intends to use for commercial purposes. Although, as stated above, he will seek the assistance of the best qualified service technicians and help from the manufacturer.

**C.F.R. 91.409(a)(2) Inspections (a) E**  **xcept as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has**  **had**

**— (2) A**  **n inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapte**  **r.**
In the event of an exemptio n being granted, the petiti oner believe s that this is inapplicable and therefore request s relief

.

. **14 C.F.R. 91.417(a) Maintenance Records (a) Except for work performed in accordance with §§ 91.411 and 91.413,**  **each regist ered owner or operator shall keep the following records for the**  **periods specified in paragraph (b) of this section: (1)Records of the maintenance, preventive maintenance, and alteration and**  **records of the 100**

**- hour, annual, progressive, and other required**  **or approved inspections, as appropriate, for each aircraft (including the**  **airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include** 

**— (i) A**  **description (or reference to data acceptable to the A dministrator) of**  **the wo**  **rk performed; and (ii) The date of completion of the w**  **ork performed; and (iii) The signature, and certificate number of the person approving the**  **aircraft for return to service. (2)**  **Records containing the following information: (i) The total time in**  **service of the airframe, each engine, each propeller, and**

**each rotor. (ii) The current status of life** 

**- limited parts of each airframe, engine,**  **propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which**  **are required to be overhauled on a specified time basis. (iv** **) The current inspection status of the aircraft, including the time since the last inspe**  **ction required by the inspection program under which the**  **aircraft and its appliances are maintained. (v** **) The current status of applicable airworthiness directives (A D) and safety**  **directives including, for each, the method of compliance, the A D or safety**  **directive number and revision date. If the A D or safety directive involves**  **recurring action, the time a nd date when the next action is required.**  **(v i)Copies of the forms prescribed by**  **§ 43.9 d of this chapter for each major alteration to the airframe and currently**  **installed engines, rotors, propellers, and appliances.** 

The petitioner requests relief from t he above on the basis that at this time, those regulations are inapplicable to the small and relatively simple UAS he plan s to use. Because of the size of the small UAS he plan s to use modifications are limited. The only possible modifications the petition er contemplates would be for safety purposes in the form of prop guards designed by the manufacturer. In addition, the petitioner plan s to utilize the most detailed records possible relative to the op erations of the UAS.

**How y** **our request woul d benefit the**  **public as a whole**

Up to the present time the services the petitioner intends to offer have been performed by commercial aircraft and at considerable cost. The petitioner believes that the substitution of small UAS in place of traditional aircraft to

accomplish the same services provides a host a safety benefits. The UAS are considerably safer because of their size, weight, and power source. They are operated at low altitudes under extremely controlled circumstances and do not require onboard pilots. The petitioner believe s that this strongly supports the position that the risks to person or property are dramatically lower with UAS. It is undoubtedly in the public’s interest to reduce the occurrences of catastrophic or fatal crashes by way of integrating newer and safer tech nologies to accomplish the same goals. From an environmental standpoint the use of UAS will eliminate the emissions created by conventional aircraft in the course of providing the same services.

Through the use of UAS, the petitioner will be able offer e conomically accessible alternatives to homeowners and realtors that previously were completely out of reach except for a limited group.

**Reasons w hy** 

**the exemption w ould not adversely affect safety**  **, or how the** **exemption would provide a level of safety at l east equal to the existing rule** 

As stated and supported throughout this petition, the petitioner, is fully capable of integrating UAS in a manner that will not adversely affect safety. The petitioner has also pointed out that integrating UAS for the purp ose of obtaining real estate photos and videography not only meets but exceeds the current level of safety offered through traditional manned aircraft.

**Summary**

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federa l Register:

Kenneth R. Duquaine seeks an exemption from the following: 14 C.F.R. Part 21 14 C.F.R. 45.23( a & b) 14 C.F.R. 61.113 (a & b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 (a) 14 C.F.R. 91.119 14 C.F.R. 91.121 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) and (b). The exemption requested by the pe titioner, Kenneth R. Duquaine, would allow commercial operations of UAS under strictly controlled conditions for the purpose of real estate photography, videography, and marketing. The pilot in command is an experienced UAS operator and will be accompanied by a visual observer. The peti t ioner plans to use the DJI Phantom 2 Vision +.which is outfitted with numerous safety features and is commonly used. This small, lightweight, UAS poses minimal risks to property and people. The UAS’s physical characteristics and fail safe features combine d with the petitioner’s commitment to safe operating procedures and policies meets or exceeds the level of safety commonly accepted with traditional manned aircraft.

The petitioner does not seek to exercise the privileges of an exemption outside of the Un ited States.

**AD DENDA**  Phantom 2 Vision Plus Specifications, Operational considerationsDJI Phantom 2 Vision +

**Quadcopter: Hover Accuracy**  Vertical: 2.6' / 0.8m Horizontal: 8.2' / 2.5m **Quadcopter: Max Yaw A ngular Velocity**  200 deg. /s **Quadcopter: Max Tilt An**  **gle** 35 deg. **Quadcopter: Maximum A scent/Descent Speed**  Ascent: 19.7 fps / 6 m/s Descent: 6.6 fps / 2 m/s **Quadcopter: Maximum Flight Velocity** 49.2 fps / 15 m/s (not recommended) **Quadcopter: Flight Time** Up to 25 minutes per battery **Quadcopter: Takeoff Weight**  = 2.9 lb / 1.3 kg **Quadcopter: Operating Temperature** 14 to 122 deg. F /

- 10 to 50 deg. C **Quadcopter: Power Requirements** DJI Phantom 2 Smart Battery **Flight Control: Connectivity** 1x Micro

- USB for user with Assistant Software **Flight Control: Sy stem Requ**  **irements** Assistant Software: W in dows or OS X **Motors: Model** CCW : Phantom 2 2312 Motor (Part 10) CW : Phantom 2 2312 Motor (Part 11) **Motors: Recommended Takeoff Weight** 10.6oz / 300.50g per axis **Motors: Maximum Tension** 1.8lbs / 0.82kg per axis **Motors: Stator Size**  0.9 x 0.5" / 22.86 x 12.70mm **Motors: Motor Velocity Constant** KV: 960 rpm/V **Motors: Working Temperature** 23 to 104 deg. F /

- 5 to 40 deg. C **Transmitter: Operating Frequency** 2.4 GHz ISM **Transmitter: Communication Distance** Open Area: 3280.8' / 1000 m **Transmitter: Receiver Sensitivity** At 1% PER:

- 97 dBm **Transmitter: Working Current/Voltage** 120 mA at 3.7 VDC**Transmitter: Power Requirements**

Built

- In Lithium

- Polymer Battery: 3.7 V, 2000 mAh **Propellers: A**

**ttachment** Self

- tightening **Propellers: Maximum Thrust** 1.5lbs / 0.68kg (with 2212 motor KV 920 at 12 V) **Battery : Ty**  **pe** 3S lithium

- polymer **Battery : Capacity**  5200 mAh, 11.1 VDC **Battery : Charging Environment Range**  32 to 104 deg. F / 0 to 40 deg. C **Battery : Discharging Environment Range** 

-4 to 122 deg. F /

- 20 to 50 deg. C **H4**

**- 3D Gimbal: A**  **ngular Vibration Range** Pitch/Roll: +/

- 0.02 deg. Ya w: +/

- 0.03 deg. **H4**

**- 3D Gimbal: Maximum Rotation Speed**  Tilt Axis: +/

- 130 deg. /s **H4**

**- 3D Gimbal: Controlled Rotation Range**  Tilt Axis Control:

- 130 deg. to +45 deg. **H4**

**- 3D Gimbal: Working**  **Current** Electrical & Mechanical: Static Current: 400 mA (at 12 V) Dynamic Current: 600 mA (at 12 V) **H4**

**- 3D Gimbal: Po** **wer Requirement** Electrical & Mechanical: 3S to 6S (12 V to 26 V) **H4**

**- 3D Gimbal: Camera Compatibility**  GoPro HERO4 Black only **H4**

**- 3D Gimbal: Fl**  **ight Control Sy stems**  Supported: A2 Wo oKong

- M NAZA

- M NAZA

- M V2 **H4**

**- 3D Gimbal: Operating Temperature**  50 to 122 deg. F / 10 to 50 deg. C **Dimensions** Diagonal: 13.8" / 350.52mm H4

- 3D Gimbal: 4.1 x 3.6 x 3.1" / 104.14 x 91.44 x 78.74mm Propellers (Dia. x Pitc h): 9.4 x 5" / 238.76 x 127.00mm **Weight** Motors: 1.9oz / 53.86g General: 2.2lbs / 1.00kg Gimbal: 5.9oz / 167.26g GCU: 0.8oz / 22.68gBefore and after every flight, the multi

‐ rotor's operational condition will be

inspected for damage and deterioration, paying attention to the props for damage, cracks or wear and the UAS ’ s fuselage for damage. If damage, cracks or unusual wear is detected operations will be suspended until proper repairs have been made using the manufactures approved replacement parts and/or repair facilities

. There is no intention of modifying aircraft beyo nd factory specifications. The UAS will be in compliance with the FAA airworthiness regulations.

**Safety** Propeller guards: Propeller guards such as the DJI manufacture ’ s guards will always be in use during commercial flights. Spotter: To ensure safety, a second person acting as a spotter will be on site to review and observe any potential hazards before and during the flight.

**Population of Intend ed A**  **rea** To ensure safety, all non

‐ essential personnel will be removed from the area. There will be no flight over densely populated areas like stadiums, schools, malls, casinos, and the like during operating hours. **Ai rports**  According FAA rules and to ensure pilot(s) safety, there will no flight in or around airports unless explicit permission is granted according to current FAA regulations.

**Weather** To ensure safety of spotter, property owners, pets, and wildlife, flights will be conducted in optimal weath er conditions. Flights will not be conducted in winds above 20 mph.
**Return**

‐**to**

‐ **Home Feature** In the event the DJI Phantom 2 Vision + loses signal or runs critically low on battery the UAS has a GPS controlled return to home feature. The "home" is set upon flight startup.

**Fly ing in Confined A**  **reas** There is a high probability of flying in confined spaces, around residential properties. The PIC and spotter will be in constant communication by two way radio, cell phone, or other approved FAA communications dev ice when geographically separated during flight to ensure awareness of obstacles, ha zards and UAS location.

**Line of Site** The UAS will always be within the unaided line of site of the pilot and spotter.

**Heigh t** Fights will not exceed 200 AGL at a ny time w hile operated commercially.

**Potential Hazards** The following are potential hazards that may, or may not be, present during flight operations. The PIC and spotter will make every attempt to be aware of: O t h e r UASs H o m e s , co m m e rc i a l b u i l d i n g s , o u t buildings, low and high voltage power lines T re e s , s h r u b s , a n d h e d g e s A u to m o b i l e s a n d o t h e r m e c h a n i c a l ve h i c l e s W i l d l i fe R i ve rs , l a ke s , p o n d s , a n d o t h e r b o d i e s of wa t e r The unforeseen presence of people or animals

**Privacy Concerns** During flight operations privacy concerns are of high priority . W ith each commercial flight permission will be obtained in advance from the property owner

or an authorized agent

. During eac h flight operation, the petitioner will make every effort to avoid filming neighboring properties.

**Pilot Qualifications** The current PIC, Kenneth Duquaine

, has had considerable experience flying UAS recreationally and has been flying the DJI Phantom 2 Vision + since its introduction. Any future PIC employed by the petitioner wil l * Be familiar with current FAA regulations regarding UAS commercial usage. * have sufficient eye sight (with or without corrective lenses and without the aid of binoculars) to see and operate the UAS at the distances necessary for the purpose of the flig ht.

* be in good health. New Pilots in training will * Be fully trained and experienced in the operation of the Phantom 2 Vision + * shadow and act as the Pilot in Command Spotter for 1 month or for a minimum of 10 hours prior to first flight as PIC. * demonstrate a workable knowledge of the UAS and proficiency in operational control at all times. * watch online training videos to further enhance their skills.

Each pilot will follow set flight plans and schedules and be aware of all current FAA regulati ons.
This concludes my petition. Thank you for your consideration.

Kenneth R. Duquaine