### Flyral Imaging 6845 Corsica Drive Memphis, TN 38120 January 8, 2016 Dept. ofTransportation , Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE ., Washington, DC 20590 VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM 

### Exemption Request underSection 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations- Amended August 7, 2015 Dear Siror Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C

.F

.R. Part 11, Flyrallmaging (Fiyral lmaging), a Tennessee based business operating small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photography and survey for various industries, hereby seeks an exemption from Federal Aviation Regulations (FARs) detailed below to allow operation ofour sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption is similar to previous FAA issued grants of exemption including but not limited to Exemption Nos. 11062, 11109, 11112, 11213 and 11295

. The requested exemption would allow Flyral Imaging to pursue commercial business by being permitted to provide services to consumers, companies, local law enforcement and first responders as well as government agencies interested in training , research , and aerial data capture using sUAS in the following areas:

- Agricultural Surveying and Application ;

- Aerial Photography and Videography for real estate, insurance, construction, mining and utilities companies;

- Disaster relief and emergency managementefforts;

- Product and Service Demonstrations;

- OperatorTraining;

- Research and Development.

1 1The petitioner request relieffrom the following regulations: 14 CFR 

### §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61

.113(a), 61.315(a), 91.7(a), 91.109, 91.119(c), 91.121 , 91.151(a)(1), 91

.215, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow Flyrallmaging to operate a UAS to perform research, training and aerial data collection. Petitioner's sUAS platforms We are petitioning for exemption to enable Flyral Imaging to operate a series ofwidely operated and well established sUAS platforms manufactured by DJI that have been previously approved by exemption. These include: DJI Phantom 2 DJI Phantom 2 Vision + DJI Phantom 3 DJI Inspire 1 Exemption 11398 Exemption 11398 Exemption 12342 Exemption 12331 These sUAS all weigh less than 55 lbs, have a built-in capability to limitthe height flown above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function ofthe autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger Return to Home and will land safely. This submission does not include the Operating Manuals for each model requested above, as they have been reviewed by the Administrator in granting previous exemptions. Copies of all Operating Manuals for the individual models listed can be submitted on request. General Operating Standards The Flyral Imaging sUAS will be operated in the field with both a PIC (Pilot in Command) and a VO (Visual Observer) in accordance with FAA Policy and with the following Restrictions: a) Noflight will be made with a UAS Gross weight exceeding 55 pounds, including payload; b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of no more than 87 knots (100 miles per hour) and be operated within the visual line ofsight (VLOS) ofthe PIC at all times; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; d) Operations will be restricted to flights over private property with the permission of the property owner(s);

2 2e) The PIC will hold either airline transport, commercial, private, recreational, or sport pilot certificate

. The PIC will also hold a current FAAAirman medical certificate or avalid U

.S

. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession , or the Federal government. The PIC will also meet the flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate

. f) All required permits will be obtained from state and local government prior to operation; g) The 901 Drone sUAS will not be operated over densely populated locations; h) The 901Drone sUAS will not be operated at air shows; 

### i) j) 

### k) 

### I) The 901 Drone sUAS will not be operated over any open-air assembly ofpeople; The 901 Drone sUAS will not be operated over heavily trafficked roads ; The 901Drone sUASwill not be operated within 5 NM of an airport or heliport; Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PIC will briefthe VO and property owner about the operation and risk before the first flight at each new location ; n) No flight may be made without a Preflight Inspection by the PIC before each operation to ascertain that the sUAS is in a condition saf e forflight (see Appendix A)

. We submit that the combination of the sUAV's light weight, flight performance and ability, fully qualified flight crew and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned aircraft performing the same mission. All sUAS operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C

. Markings will be as large as practicable

. Exemption Requests and Equivalent Level ofSafety Flyrallmaging requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe sUAV System : 14 CFR 61.23 Medical Certificates The regulation provides that a person requires a first or second class medical to act as Pilot in Command of an aircraft for compensation or hire

. Our proposed operations require that the PIC must hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, orthe Federal government. Since the aircraft cannot carry passengers or property, we feel we meet the intent of61

.23 even though the intent ofthis application is to conduct a business

. 14 CFR 61.101 , 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private Pilot certificate may act as Pilot in Command ofan aircraft for compensation or hire

. Our proposed operations require that the PIC must hold at least airline transport, commercial , private, recreational, or sport pilot certificate

. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61

.113 Subparagraph (b) even though the intent ofthis application is to conduct a business. 3 314 CFR 91.7 Civil AircraftAirworthiness This Section prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 CFR 91 .109 Flight Instruction; Simulated instrument flight and certain flighttests The regulation states that "No person may operate a civil aircraft that is being used for flight Instruction unless that aircraft has fully functioning dual controls." Training will be conducted by Flyrallmaging PIC instructors. We have the ability to provide dual controls utilizing two transmitters with a wireless and orwired link between the transmitters. One transmitter is designated the master transmitter and the othertransmitter is designated as a slave. The Flyral lmaging PIC instructor, utilizing the master transmitter, will be at all times be able assume control ofthe sUAS. 14 CFR 91.119 Minimum safe altitudes: General The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person , vessel , vehicle, or structure. Since the typical mission ofthesUAS would be photography or survey of persons, vessels, vehicles or structures itwould be necessary to operate closer than 500 feet to the items listed. Operations will only beflown over property where permission has been obtained and careful pre-planning has been performed. The sUAS will be operated at a low altitude allowing, ifa power unit fails , an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should·be considered in granting the exemption. 14 CFR 91 .121 Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feet AG L and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration offlight from a single battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve afterthat.

4 414 C.F.R. 91 .215 ATC transponder and altitude reporting equipment and use: This regulation states all aircraft operating within 30 nautical miles ofclass A, B and C airspace must be equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations. Due to the small size and lifting capabilities ofour sUAS we cannot carry a traditional transponder. All of our operations will be under 250' ifwe are operating within the 30mi reach of a mode C vail. 14 CFR Subpart E (91.401- 91 .417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43

. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the Flyrallmaging PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the sUAS is in an airworthy condition prior to every flight and in addition, conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer ortheir designated repairfacility

. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. Howthis request is to the betterment ofour community Our UAS are powered by batteries, smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels associated with traditional aircraft, enhance safety and diminish the likelihood of death or serious bodily injury

. Also with a small payload and typical flight time of only 20 minutes, there is little or no risk to national security. Low level photos and video are far more effective than ground or high altitude manned aircraft imagery for displaying detailed characteristics of ground based objects. The applicant in the past has chartered full-sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford

.The benefits of reduced cost and improved quality of presentation from the UAS will be incredibly valuable to future clients. Additionally, we will make our sUAS available to first responders in our community who might require assistance, including fire fighters, police, sheriff, et al. , while remaining subject to all limitations cited in this application

.

5 5The name and contact information ofthe petitioner are: 

### Flyrallmaging Attn: Aaron Jaffe Phone: 901

.834.9566 Email: Aaron@flyral.co
We are prepared to modify or amend any part ofthis request to satisfy the need for an equivalent level ofsafety

. Please contact us at any time ifyou require additional information or clarification. We lookforward to working with your office. Sincerely,

Aaron Jaffe, Owner Flyral Imaging

6 6