James T Freeman 207 Evergreen Lane Meriden, CT 06450 (203)-634-8286
Jtfc5@msn.com

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, James T Freeman, a licensed Real Estate agent, here by applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of ou r Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Av iation Administration (FAA ) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Jame s T Freeman to pursue his commercial interests in providing services to clients using a small advanced sUAV in the following area s: Real Estate, Marketing, Land Management/Surveying, and Special Events. James T Freeman states that all sU AS flights will occur over private or controlled access property and will do so with the property owner's consen t and knowledge and that only people who have consented or otherwise have agreed to be within the UAS’ radius during filming and photography applications.

James T Freeman has demonstrated the ability to safely an d effectively fly the sUAS DJI Phantom 3 which will be used for all commercial and private purposes. James T Fr eeman complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and envi ronmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

I, James T Freeman, am seeking the exemption because I am committed to complying with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have descri bed. Without the exemption request granted, I would be unable to safely and effectively run my business, and it is my intention to comply with the FAA and obtain an exemption of the following regulations.

The following contains my list of regulations from wh ich I am seeking exemption, and a complete list of responsibilities I assume as operator; it also contains info rmation regarding the aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which ex emption is requested:

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. 91.7(a) 14 C.F.R. 91.9(b) (2)
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.12114 C.F.R. 91.151(a) 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. 91.401 - 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES 1. Operations authorized by this grant of exemption ar e limited to the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed-set motion picture and television f ilming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine comp liance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds great er than the maximum UA operating ai rspeed recommended by the aircraft
manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued
airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). Th e UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be us ed to satisfy the VLOS requi rement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight opera tions. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemptio n, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS ope rations and made available to the Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limita tions herein take precedence and must be followed. Otherwise, the operator must follow the procedures as ou tlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s re sponsibility to track such revisions and present updated and revised documents to the Administrator or any law enforc ement official upon request. The operator must also present updated and revised documents if it petitions for exte nsion or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS

െ 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical co mponent, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspec ting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre-fli ght inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items,or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating un til the necessary maintenance has been perf ormed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul , replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must co mply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercia l, private, recreational, or sport pilot certificate. The PI C must also hold a current FAA airman me dical certificate or a valid 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 must also meet the flight review requirements specified in 14 CFR § 61.5 6 in an aircraft in which the PIC is rated on his or her pilot certificate. 5 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the
UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from n onparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not
authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denot ed with an ARP, the center of the airport symbol as denoted on the current FAA-publishe d aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon
request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 st atute miles from the PIC. 18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre-determined location within the private or co ntrolled-access property. 19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recomme nded by the manufacturer if greater. 21. Air Traffic Organization (ATO) Ce rtificate of Waiver or Authorization (COA). All operations shall be
conducted in accordance with an ATO- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 6 22. All aircraft operated in accordan ce with this exemption must be identif ied 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 must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These docu ments must be made available to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all ma nned aviation operations and activities at all times.25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 fe et from all nonparticipating persons, vessels, vehicles, and
structures unless: a. Barriers or struct ures are present that sufficiently prot ect nonparticipating persons from the UA
and/or debris in the event of an accide nt. The operator must ensure that nonpa rticipating persons remain under such protection. If a situation aris es where nonparticipating persons leave such protection and are with in 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. Th e PIC, VO, operator trainees or e ssential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or co ntrolled-access property with perm ission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or f light operation that transgresses the latera l or vertical boundari es of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

െ 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained
on the NTSB Web site: www.ntsb.gov

.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relie f previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. James T Freeman is petitioning for an exemption to oper ate a DJI Phantom 3 with a built-in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no-fly zone feature.
The DJI Phantom 3 also has a failsafe function that is tr iggered in the event communication is lost between the
sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can rega in control of flight and land manually.

These specifications meet with the Model Airc raft Operating Standards as set below:

The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from populated areas within the ster ile area described in the FOPM. Such operations will ensure
that the sUAS will "not create a hazard to users of the national airspace system or the public." When flying the sUAS within three (3) miles of an airp ort, airport operators will be notified and the 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.Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the
sUAS. The sUAS will be programmed so it will not be operated at an altitude that exceeds 40 0 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned. Minimum crew for each operation shall consist of: sUAS p ilot, a visual sUAS observer, and the camera operator. The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot ce rtificate and a current FAA
medical certificate. The sUAS operated by the petitioner weighs less than 25 pounds, including all payl oad (i.e. came ra, lens, and stabilized gimbal). The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally.
Given the small size of the sUAS and the restricted sterile environment within which it will operate, SkyVideoCT’s operations adhere to the Reform Act's safety requirements.