January 1, 2016

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Petitioner: Janis L. Powell

Matrix PhotoVideo , LLC

PO Box 693 Laconia, NH 03247

Phone: 207

- 370

- 9696

To Whom It May Concern:

Pursuant to Section 333 of the Federal Aviation Administration ( FAA ) Modernization and Reform Act of 2012 and 14 CFR Part 11, Matrix PhotoVideo , LLC requests an ex emption

from the Federal Aviation Regulations (FARs) identified below, to allow commercial operations of smal l unmanned aerial systems ( sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, pursuant to Section 333 o f the Modernization

and Reform Act of 2012

.

This exemption will permit commercial operation of sUAS’s, weighing less than 25 lbs, to provide photography and videography service to clients for the following applications:

• Real estate

• Marketing

• Promotion of tourism

• News gathering

• Search & rescue • Special events

• Industrial /construction inspections

• Education

• Sports

• P rivate for

- hire requests

Summary

Matrix PhotoVideo , a photography and video production company, provides clients with photo

and video related services for a variety of applications to include: r eal estate , m arketing

, tourism , n ews gathering

, s earch & rescue operations, s pecial events

, i ndustrial/construction operations

, e ducation , sports

, and p rivate for

- hire requests. Matrix PhotoVideo requests an exemption Pursuant to Section 333 of the Federal Aviation Administration (FAA)

Moder nization and Reform Act of 2012 and 14 CFR Part 11 to allow commercial operation of Small Unmanned Aircraft Syste ms (sUAS) in airspace regulated by, and under the conditions established by

, the Federal Aviation Administration (FAA )

. Matrix PhotoVideo operation s under the exemption will be subject to strict operating requirements and co nditions to ensuresafety at all times and under conditions as may be modified from time to time by the FAA

.

Relief Desired

Matrix PhotoVideo requests relief from the following r egulations:

14 CFR 21

, subpart H

14 C.F.R. 61.101(e)(4), (5), & (6)

14 C.F.R. 61.113 (a) & ( b )

, 61.315 (b ) (2)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.119 (c)

14 C.F.R. 91.121 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b)

14 C.F.R. 91.215 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2),91.417(a) and (b)

14 C

. F

. R

. 21

, subpart H

, 14 C.F.R. 91.203(a) & (b)

- CERTIFICATION	PROCEDURES	FOR
PRODUCTS	AND	PARTS, CIVIL	AIRCRAFT:	CERTIFICATIONS	REQUIRED Airworthiness certificates are not currently issued to sUAS. The petitioner will comply with the manufacturer manual in regard to inspection and determination of sUAS airworthiness. The sUAS will be registered with the FAA and properly identified with an assigned registration

number.

14 C.F.R. 61.101(e)(4), (5) , & (6)

, 14 C .F.R. 61.113 (a)&(b), C.F.R. 61.315(b)(2)

– PILOT

PRIVILEGES	AND	LIMITS The petition er is requesting exemption to allow commercial operations . Additionally, such operations may include operating at night to meet the needs of clients for night photography and videography. Night operations include addition a l safety measures for sUAS, including appropriate navigational lights for visibility

.

14 C.F.R. 91.9(b)(2)

- CIVIL AIRCRAFT FLIGHT MANUAL, MA RKING, AND PLACARD REQUIREMENTS Due to the size and nature of sUAS, the operating manual will not be on board the sUAS but instead be readily available to the operator. The operator will comply with all operating procedures and limitations as defined in the manufacturer operating manual.

14 C.F.R. 91.119

- MINIMUM	SAFE	ALTITUDES:	GENERAL

Some of the requested photography/videography needs of clients relate to towers, buildings, or other structures exceeding 400 ft AGL. Under these circumstances, flight operations will be less than 1500 feet horizontally, and no more than 100 ft vertically above a targ et structure (i.e.: tower or building). Given the distance requirements of manned aircraft, there is sufficient separation of activity to prevent an in

- air safety hazard under such circumstances

. Under all

other circum stances, sUAS shall not exceed 4 00 fee t altitude.

14 C.F.R. 91.121

- ALTIMETER	SETTINGS

The sUAS does not utilize an altimete r and instead uses GPS and barometric pressure to determine height above ground.

14 C.F.R. 91.205(b)

- INSTRUMENT	AND	EQUIPMENT	REQUIREMENTS Due to the nature of sUAS, the operating data available is from GPS and barometric pressureand includes ground speed, height above ground, direction, distance from the controller, battery level and voltage, and available flight time. The sUAS has programmable safety

features to su pport the prevention of any potential safety conflicts.

14 C.F.R. 91.215

- ATC	TRANSPONDER	AND	ALTITUDE	REPORTING	EQUIPMENT	AND

USE The sUAS does not have a transponder or code capability. The majority of operations do not

occur at an altitude within Clas s A, B, or C airspace. In the situations where there is an exception to this , or where the desired airspace of operation extends to ground level, approval and coordination will be required with the governing agency prior to engaging in any flight activity.

14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2),91.417(a) and (b )

– MAINTENANCE The petitioner will inspect the small UAS before each flight to ensure it is in a condition to be operated safely in accordance with the operating manual

.

s UAS Device

The current sUAS device s to be operated are DJI Inspire 1 s and are less than 25 pou nds . The Inspire 1 has failsafe modes of operation for either loss of radio control, GPS signal, or low battery level. Altitude can be limited by the onboard flight controller and maximum altitude

c an be programmed by the operator . Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot before reaching a low battery state. An automatic termination of flight and l anding will be initiated when the battery reaches a predetermined state. F lights most typically last less than 20 minutes.

Benefit to the Public

Matrix PhotoVideo ’s sUAS s are the ideal platform for providing services to clients due to their smaller size, less costly operation, reduced operator fatigue

, and reduced noise

. This provides

for less environmental impact and ease in ensuring public safety. s UAS operations enable service for clients seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography or through larger manned aircra ft. Aerial photography and videography via sUAS is a valuable marketing tool for many businesses, increasing competitive ness in the market and it provides individual and family clients with the personally desirable recording of life’s events

.

Privacy

Cons istent with all applicable United States legal requirements and Matrix PhotoVideo’s required level of professionalism and integrity, utmost care will be given to protect individual privacy. sUAS flights will occur: over private or controlled access propert y with the proper authority’s consent and knowledge, include only people who have consented or otherwise have agreed to be in the area where sUAS activity will take place, or in cases within the public domain, including events, diligence and care shall be applied to appropriately protect privacy.Safety and Operations

Under the requested exemption, the petitioner ensures all operators comply with applicable

reg ulations and guidance documents including aeronautical background information such as

charts

, NOTAMS and aircraft circulars, radio comm unications procedures, human facto rs and crew resource management, basic sUAS aerodynamics, weather factors, airmanship and decision-making and safe operations procedures.

Operation under this exemption will be sub ject to strict operating requirements and conditions to ensure safety of all persons and property:

• s UAS devices will only be operated by a holder of a FAA issued private, recreational, or sport pilot certificate

, must include a pre

- flight review to include review and consideration of all flight characteristics in advance of any operation, a preflight inspection of s UAS airworthiness, and knowledge of safe operations and limitations as defined by the s UAS

manufacturer.

• Crew for ea ch operation shall consist of a s UAS operator and will include a visual sUAS observer as projects require in accordance with Section 333.

• s UAS devices will only be used in line-of-sight of an operator and/or observer. Such operations will ensure th at sUAS devices will “not create a hazard to users of the national airspace system or the public.”

• Flights will be terminated with sufficient battery reserves to ensure enough flight time to safely land the sUAS.

• F lying a s U AS within five (5 ) miles of an airport is by exception only. The appropriate airport controlling office will be notified and coordinated with to ensure safety and separation from manned aircraft at all times; t he operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. Maximum flight time for each operation will be 30 minutes or less

.

• The s UAS will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which any videography or photography is planned.

• The petitioner requests an exception for photography/videography needs of clients with towers, buildings, or other structures requiring inspection that exceed 400 ft AGL. Under these circumstances, flight operations will be les s than 15 0 0 feet horizontally, and

no more than 1 00 ft vertically above a target structure ( i.e. : tower or building) . Given the

distance requirements of manned aircraft, there is sufficient separation of activity to

prevent a n in

- air safety hazard under su ch circumstances

.

• The s UAS will ope rate at speeds of no more than 6 0 knots

.

Closing

The granting of an exception under Section 333 to Matrix PhotoVideo will allow the business

to meet the aerial photography and videography needs of clients through efficient, limited,low-risk commercial sUAS operations for the activities stated in this petition

, respecting at all times the space and privacy of citizens and property while maintaining safety within the operating airspace.

Respectfully

,

Janis L. Powell

Matrix PhotoVideo , LLC