## A V I A T I O N L A W C E N T E R 205 Bulifants Blvd., Suite B | Williamsburg, Virginia 23188 | 757.229.0557 TGHaglund@AvLawUSA.com

1 8 June 2015
U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Wash i ngton, DC 20590

RE: PETITION FOR EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS

Dear Sir or Madam: In accordance with Sec tion 333 of the FAA Modernization and Reform Act of 2012 (the FMRA ) and 14 CFR Part 11, Petitioner hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial use of i ts s mall Unmanned Aircraft Systems ( UAS ) , so 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. An exemption is being requested because (1) ex i sting regulations will unduly burden Petitioner, (2) Some of the existing regulations are impossible to comply with, (3) Petitioner can provide a level of safety that i s equal (or greater than in many cases) to those pr ovided by existing rules, and (4 ) the request is in the public interest. The FAA's authority t o issue exemptions from operating rules, and the Secretary's authority granted by Section 333 of P.L. 112

- 95, Special Rules for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certa in UAS operations in the National Airspace System (N AS) prior to implementation of the UAS rule

. This incremental step will allow Petitioner to safely and legally2 enter into the NAS. As described in the following petition , the requested exemption would support an application for a commercial Certificate of Authorization and permit the commercial operation of small, unmanned and relatively inexpensive aircraft under controlled conditions in the NAS. The company objective is to conduct aerial photography and videography in order to provide high quality digita l imaging and video content to its clients for property owners and real ty agents for real estate marketing , to builders, contractors and inspectors for construction and inspection of commercial and residential property exteriors, and of weddings,	golf	tour naments,	and	sailing regattas

. These operations would be conducted in airspace no more than 200’ AGL and the UAS will remain within visual line of sight of the Pilot in Command at all times. We can assure that the combination of the UAS’ light weight, hi storically demonstrated flight performance, on board GPS system, fully qualified flight personnel, and strict operation s under the guidelines established, the FAA can have confidence that Petitioner ’s operation s will have an equivalent or greater level of safety that of full sized, manned aircraft performing the same missions.

T he name and contact information of the Petitioner are: Hawk’s Point of View, LLC William B. Barnes 120 North Turnberry Williamsburg, Virginia 23188

- 8984 48barnesw@cardinalmail.cua.edu
Regulations from which the exemption is requested are as follows: 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.3 14 CFR 61.23 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103(b)(2) 14 CFR 91.1093 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 1 4 CFR 407(a) (1) 14 CFR 409(a) (2) 14 CFR 417(a) & (b) A
Accordingly, the Petitioner respectfully requests that the FAA grant the requested exemption. Petitio ner remains prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Please contact the undersigned at any time if additional information or clarifications are needed. Thank you for your time and attenti on to this request.
Yours truly,

AVIATION LAW CENTER

Terence G. Haglund

TGH/ss Attachments4 

### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF HAWK’S POINT OF VIEW, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 14 CFR Part 21 , 14 CFR 45.23(b) , 14 CFR 61.3 , 14 CFR 61.23 , 14 CFR 91.7(a) , 14 CFR 91.9(b)(2) 14 CFR 91.103(b)(2) , 14 CFR 91.109 , 14 CFR 91. 119 REGULATORY DOCKET 14 CFR 91.121 , 14 CFR 91.151(a) , 14 CFR 91.203(a) & (b) NUMBER ______________ 14 CFR 91.405(a) 14 CFR 407(a) (1) , 14 CFR 409(a) (2) 14 CFR 417(a) & (b) CONCERNING COMMERCIAL OPERATIONOF THE DJI PHANTOM 3 UNMANNED AIRCRAF T SYSTEM PURSUANT TO SECTION 333 OF THE THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)
Submitted on 18 June, 2015

TERENCE G. HAGLUND AVIATION LAW CENTER 205 Bulifants Boulevard Suite B Williamsburg, Virginia 23188 Telephone: 757

- 229

- 0557 Email: TG Haglund@AvLawUSA.com Attorney for Petitioner5 TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

. ......................................................................................... 5 SUMMARY............................................

................................................................................. .... 7 BASIS FOR PETITION.

.. ............................................................................................................. 7 INTRODUCTION AND INTERESTS OF PETI TIONER....

.. ..................................................... 8 AIRCRAFT INFORMATION

....................................................................................................... 9 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEKS EXEMPTION........................................................

....................................... ...9 SUMMARY OF REQUEST................................................................................9 OPERATION OVERVIEW................................................................................12 AIRCRAFT ...................................................................................................13 EQUIVALENT LEVEL OF SAFETY....................................................................1 5 THE REASONS WHY GRANTING PETITIONER’S REQUEST WOULD BE IN THE PUBLIC INTEREST ......................................................

......................................... ..................... 24 REQUESTED EXEMPTIONS

– EQUIVALENT LEVEL OF SAFETY

............ ............... ....2 5 SUMMARY THAT CAN BE P UBLISHED IN THE FEDERAL REGISTER...........

.. .............. 34 CONCLUSION......................................................................

................................... .................... 3 56 GLOSSARY OF ABBREVIATIONS AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation G CS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airme n PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Obs erver SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System (s) VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing7 **SUMMARY** Petitioner se eks exemption from the requirements of 14 CFR Part 21, 14 CFR 45.23(b), 14 CFR 61.3, 14 CFR 61.23, 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.103(b)(2), 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203(a) & (b), 14 CFR 91.405( a) 14 CFR 407(a) (1), 14 CFR 409(a) (2), 14 CFR 417(a) & (b) , to operate a small Unmanned Aircraft System ( UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Petitioner to operate an unmanned aer ial system (“ UAS ”) within the National Airspace System (“NAS”) in order to provide high quality digital imaging and video content to its clients for property owners and real ty agents for real estate marketing, to builders, contractors and inspectors for co nstruction and inspection of commercial and residential property exteriors, and of weddings,	golf	tournaments,	and	sailing	regattas

. **BASIS FOR PETITION** Petitioner, by and through undersigned counsel, pursuant to the provisions of the Federal Aviation Regu lations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 within the NAS, and for an ex emption from the requirements of 14 CFR Part 21, 14 CFR 45.23(b), 14 CFR 61.3, 14 CFR 61.23, 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.103(b)(2), 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203(a) & (b), 14 CFR 91.405(a) 14 CFR 407(a) (1), 14 CFR 409(a) (2), 14 CFR 417(a) & (b)

. Relief from certain requirements of Section 61.3(a) entitled Requirement for certificates, ratings, and authorizations , is requested by Petitioner to the extent necessary to al low operation of the P hantom 3 UAS by a Pilot in Command (PIC) who has demonstrated, by meeting minimum training, flight

- hour and currency requirements, including evasive and emergency8 maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures , that the PIC is able to safely operate the Phantom 3 UAS in a manner consistent with this exemption

. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Petitioner’s operation o f the Phantom 3 meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Petitioner requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply
to aircraft with an airworthiness certificate. Petitioner submits that the requested relief is proper since an equivalent (or greater) level of
saf ety will be ensured. Petitioner will perform maintenance, alterations, or preventive maintenance on the Phantom 3 using the methods, techniques, and practices prescribed in the operating documents (i.e., the Phantom 3 UAS User Manual, the Phantom 3 UAS Qu ick Start Guide, the Phantom 3 UAS Safety Guidelines, the OpenPilot Preflight Checklist, the Intelligent Flight Battery Safety Guidelines, and Petitioner’s SOP), or will utilize manufacturer authorized support services to perform maintenance, alterations, or preventive maintenance on the Phantom 3. Furthermore, Petitioner will
document and maintain all maintenance records for the Phantom 3.

INTRODUCTION AND INTERESTS OF THE PETITIONER Hawk’s Point of View , LLC (hereinafter referred to as " Petitioner ") is a Virginia limited liability
comp any owned and operated by William B. Barnes. The company objective is to lawfully conduct aerial photography and videography in order to provide high quality digital imaging and video content to it s clients, in particular to property owners, real estate agents, builders, contractors, and/or property inspectors for real estate marketing and inspections of home9 exteriors , and for weddings,	golf	tournaments,	and	sailing	regattas

. The proposed aerial filming will be conducted in the NAS with in controlled access over private property with the knowledge and permission of the property’s owner , or over open water

.

**AIRCRAFT INFORMATION**
Petitioner seeks an exemption to operate the D J l Phantom 3 UAS (or similar should newer, safer and/or more advanced models become available) for compensation or hire within the NAS

. The
Phantom 3 is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The Phantom 3 has a maximu m gross weight of 2.6 pounds , a diagonal size of approximately 17 inches including propellers, , and a maximum speed of approximately 35 miles per hour (no wind)

. The Phantom 3 is equipped with four horizontally
mounted rotors, each driven by a Lithium Pol ymer battery powered electric motor.
The Phantom 3 that will be operated by Petitioner will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and
marked in accordance with 14 C. F.R. Part 45, Identification and Registration Marking.

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEKS EXEMPTION

Summary of request Petitioner is submitting this petition pursuant to the FAA Modernization and Reform Act of 2012 and the pr ocedures contained within 14 C.F.R. 11, so that it may operate the DJI
PHANTOM 3 (or similar should newer, safer and/or more advance d models become available)
UAS for the limited purpose of conducting aer ial photography and videography below 200 feet
AGL a nd further than 5 miles from any airport or heliport, in order to safely and legally10 capture aerial photography and videograph y for use by owners of commercial and residential properties , building contractors and inspectors, developers, and realty agents , and for weddings, golf	tournaments,	and	sailing	regattas , for compensation or hire

. In Regulatory Docket No. FAA

– 2015

- 0280 

## , Exemption No. 11 783 , (which is essentially

identical to this request), an exemption was approved for the same aircraft and similar proposed operations.

Petitioner is supporting its request with the following information: 1) Uploaded Petition Exemption

– Hawk’s Point of View LLC .pdf; 2) PHANTOM 3 Quick Start Guide V 1.0 ; 3 ) PHANTOM 3 User Manual v1.2 ; and 4 ) PHANTOM 3 Pre

- flight Ch ecklist

.

Petitioner believe s that its request for exemption as outlined in this uploaded Petition for Exemption is warranted in this case and respectfully request s that it be granted without termination date for the reasons stated therein. Aerial photogra phy and videography operations for private and/or commercial properties and businesses benefit the public with enhanced perspectives of characteristics, amenities, and benefi t a property has that cannot be displayed through ground level photography and vid eography. UAS a erial videography and photography provides a much higher level of safety to the public and the structures at a fraction of the cost and without the burning of fossil fuels that contaminate the atmosphere. Approval of this exemption would thereby greatly enhance safety and fulfill the Secretary of Transportation's (the Secretary) responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the national a i rspace system" per Section 333 (c) of the11 Reform Act. 1
Petitioner is requesting exemption from the following regulations : 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.3 14 CFR 61.23 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103(b)(2) 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 1 4 CFR 407(a) (1) 14 CFR 409(a) (2) 14 CFR 417(a) & (b) A This petition for exemption is expressly subm i tted to fulfill Congress' goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary to consider whether certain unmanned aircraft systems may operate s afely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the
NAS , to the public, or pose a threat to national security. Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned aircraft system, as a result of its size, weight, speed, operationa l capability, proximity

1 Petitioner interprets this provision to place the duty on the Secretary to not only process applications for12 to airports and populated areas, and opera tion within visual line of sight (VLOS) does not create a hazard to users of the NAS or the public , or pose a threat to national security, and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 49 USC
44 704 is required for the operation of civil (nongovernmental) UAS . Therefore, if the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircr aft in the national airspace syste m ". 2 Operation Overview Petitioner’s DJI Phantom 3 is a quadcopter weighing 2.6 pounds (including payload). The aircraft has the capability to hover and move in the vertical and horizontal planes simultaneously. They wi ll operate only in visual line of slight (VLOS) and will only with in tightly controlled and limited airspace. They are capable of operating at speeds of up to 35 miles per hour but will be routinely operated at much lower speeds. They will be operated

com mercially below 200 feet above ground level (AGL), unless and until regulations permit otherwise

. Aerial photography and videography services will be offered for use by property owners, commercial and residential real estate agents, builders, contractors, and/or residential and commercial property inspectors for real estate marketing and inspections of home exteriors , and for weddings, golf tournaments and sailing regattas

. All operations will be conducted on private property and with the written and/or or al permission of the property owner(s) or over open
waters

. Operations will always be conducted in areas that are clear of people except for the pilot in command (PIC) and the PIC's helper(s). Such o perations will ensure that the UAS will "not

2 Reform Act Section 333 (b)13 create a ha zard to users of the national airspace system or the public" 3 Any exemption granted pursuant to this petition and all documents needed to operate the UAS and conduct its operations in accordance with the condition s and limitations stated in such grant of exemption, are hereinafter referred to as the “ operating documents ” . The operating documents will be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy should exist between the conditions and limitatio ns in such exemption and the procedures outlined in the operating documents, the conditions and limitations in such exemption shall take precedence and will be followed. Otherwise, the Petitioner will follow the procedures as outlined in its operating doc uments. The Petitioner may update or revise its operating documents. It will be the Petitioner ’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The Petit ioner shall also present updated and revised documents if it petitions for extension or amendment to any grant of exemption. If the Petitioner determines that any update or revision would affect the basis upon which the FAA granted an exemption, then it w ill petition for an amendment to its grant of exemption. The FAA’s UA S Integration Office (AFS

− 80) will be contacted if questions arise regarding updates or revisions to the operating documents.

Aircraft Petitioner operate s a Phantom 3 ( “ Phantom ” ) manufactured by DJI, a well

- known leader
in quad copter technology. DJI str ives to bring new perspectives to aerial work and help s companies accomplish feats safer, faster, and with greater efficiency. They have an unparalleled

3 http : //www.dji.com/product/phantom

- 2

- vision

- plus14 commitment to R&D, a culture of constant innova t ion, and a focus on transforming complex technology int o easy - to

- use devices. The standard Phantom quad copter package includes the Phantom itself, camera, gimbal, propulsion system, flight control system, 2.400

- 2.483 GHz remote controller, and 2.4 GHz Wi

- Fi communication system. The remote uses a 5.8 GHz fre quency to prevent interference with the video/telemetry channel. This second channel allows for a constant connection with the Phantom to monitor it via a smartphone or tablet that is attached to the remote controller. The Phantom is about 17 inches squar e in size , including rotors . It has a maximum ascent speed of 16.4 MPH , a maximum descent speed of 6.7 MPH , and a maximum flight speed of approximately 35 miles per hour . While operating within VLOS, the remote control has a range of 1.24 miles . The total weight ( including the payload) is 2. 6 pounds

. 4

T he Phantom flight control system provides for incredible ease of use and stability. Pilots can control the Phantom's movements in many directions

- including forward and backward , up and down , and left and right turns and banks . The flight control system can also provide Intelligent Orientation Control (IOC), failsafe (return to home) , battery level warnings, and show the aircraft's current heading, direction, speed, and approximate distance from home on the

on - screen radar. The built

- in Global Positioning System (“ GPS ”) aids in stabilizing the aircraft , and automatically and safely returns it back to its home point if communication between the remote control and UAS is lost or the battery level becomes too l ow
. The Inertial Measurement Unit (IMU) has a built

- in inertial sensor and a barometric altimeter that measures both attitude (ATTI) and altitude. The inertial measurement tel ls the UAS how it's tilted and the gyros tell it if it is rotating in any partic ular direction.

4 http://www.dji.com/product/phantom

- 3/spec15 The Phantom's compass re ads geomagnetic information and assist s the GPS to accurately calculate the position and height of the aircraft. The Phantom 3 m aximum altitude is 6000

meters. The Phantom 3 has LED flight indicators beneath each of its four rotor arms. The LEDs illuminate to indicate the status of the flight control system and alert the PIC of any possible issues. Such highly advanced capabil i ties will ensure that the Phantom 3 can be safely operated and "not create a hazard to user s of the national airspace system or the public." 5

Equivalent Level of Safety In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the world and to minimize the risk to the NAS or to persons and property on the ground, Petitioner agrees to be bound by the following limitations and conditions when conducting commercial operations under an FAA issued exemption:
A. For the purposes of ensuring the aircraft will be operated within the standards that the
FAA h as allowed in the AMA National Model Aircraft Safety Code , except as modified or superseded by the proposed FAR Part 107 : 1. UAS will not be flown: a. In a careless or reckless manner. b. At a location where UAS activities are prohibi t ed

. 2. UAS pilots will:

a
. Yield the right of way to all human

- carrying aircraft.

5 Reform Act Section 333 (b)16 b. See and avoid all aircraft and a Visual Observer will be used when appropriate

. 6

c. Not conduct commercial operations higher than 200 feet above ground level or with i n five (5) mile s of an airport or heliport without notifying the airport operator and obtaining a COA , until such time as the FARs have been written or revised to permit higher flights or flights closer to an airport

. d. Not interfe r e with operations and traffic patterns at any a i rport, heliport or seaplane base except where there is a mixed

- use agreement.

e. Not exceed a takeoff weight of 55 pounds (including payload). f. Ensure that affixing the owner’s contact inf ormation to t he outside of the UAS identifies the a ircraft

. g. Not operate UAS while under the influence of alcohol or while using any drug that could adversely affect the PIC's ability to safely control the mode l. h. Not operate UAS carrying pyrotechnic devices that explode or burn , or
any device that propels a projectile or drops any object that creates a hazard to persons or property.
3. UAS will not be flown unless:

a. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the spe cific

event.

6 AMA Document #540

- D17 b. An inexpe r ienced pilot will be assisted by an experienced pilot.
4. All pilots will avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.
5. A succes sful radio equipment ground

- range check in accordance with manufacturer's recommendations will be completed before the first flight of a new or repaired model aircraft

. 6. UAS will use the radio

- control frequencies allowed by the Federal Communications Co mmission (FCC).
7. UAS will	not	knowingly	operate	within five ( 5 )	miles	of	any	pre

existing	flying	site	without	a	frequency

- management	agreement. 7
8. Excluding	takeoff	and	landing, no UAS will be	flown	outdoors	closer
than at	least	500	feet	from	all	no nparticipating	persons,	vessels,	vehicles,	and

structures.
9. Under	no	circumstances will a	pi lot	or	other	person	touch	a UAS	in flight	while	it	is	still	under	power,	except	to	divert	it	from	striking	an	individual.
10. The	PIC	of	the UAS	shall:

a. Mainta i n control during the entire flight, mainta i ning visua l contact without enhancement other than by corrective lenses prescribed for the pilot

. b. Fly using the assistance of a camera or First

- Person View (FPV) only in accordance with the procedures o utlined in AMA Document #550.

c. Fly using the assistance of autopilot or stabilization system only in

7 AMA Documents #922 and #92318 accordance with the procedures outlined in AMA Document #560.
11. T he flying area will be clear of all utility w i res or poles and , except for utility l ine inspections, an UAS will not be flown closer than 50 feet to any above

ground electric utility lines

. 12. The flying area will be clear before the engine s are started, except for PIC and the PIC's helper(s).
B. In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in an effort to enhance the safety offered by the already safe operations mentioned above , Petitioner also agrees to be bound by the following limitations and conditions : 1. Flights will be operated with in VLOS of the P I C. All operations will utilize a visual observer (VO). The UA S will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS capability. The VO and PIC will be able to communicate verbally at all times; electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC shall ensure that the VO can perform the duties required of the VO.
2. Maximum total flight time for each operational flight will be 17 minutes. Flights will be terminated at 25% battery power reserve should that o ccur prior to the 17 minute limit.
3

. The UAS will only operate in tightly controlled and limited airspace.19 4. A briefing will be cond ucted in regard to the planned UAS operations prior to each flight

. It will be mandatory that all personnel who will be performing duties with i n the boundaries of the safety perimeter be present for this briefing.
5. The PIC and the PIC's helper(s) will hav e been trained in operation of UAS and received up

- to

- date inform ation on the particular UAS to be operated.
6. The p ilot and the PIC's helper(s) will at all times be able to communicate by voice

. 7. If the UAS loses communications or loses its GP S signal, the UAS will have the capability to return to a pre

- determined location with i n the security perimeter and safely la nd.
8. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.
9. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized

re presentative , or over open water . Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
10. All f light operations will be conducted at least 500 feet from all nonparticipating persons, vess els, vehicles, and structures unless (a) barriers or structures are present that sufficiently protect non participating persons from the UAS and/or debris in the event of an accident. The Petitioner will ensure that nonparticipating persons remain under su ch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations will cease immediately in a manner ensuring the safety of20 nonparticipating persons; and (b) the owner/controlle r 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.
11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during severe weather conditions.
12. Flights will not occur in weather cond i tions that prevent the PIC from operating within visual line

- of

- sight (VLOS) at all ti mes or in weather conditions th at dramatically affect the UAS’ flight (e.g

. high winds)

. 13. If an operation occurs in an area where people could inadvertently enter the area, an operational border will be established with traffic cones

. If it is not fe asible to use traffic cones due to interference with the photography/videography, the PIC's helper(s) will be responsible for keeping a safe perimeter around the operation. The operation will cease immediately and be rescheduled if it is impossible to est ablish a safe per i meter around the operation.
14. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Offic e (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

. The operation of UAS weighing less than 3 pounds , conducted in the strict conditions a s outlined above, will provide an equivalent or greater level of safety supporting the grant of exemptions requested herein, including exempting the applicant from the requirements of Part 2121 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled environment. As a result, they offer a much safer way to capture aerial photography and videography. Furthermore, the proposed operations represent a safety enhancement to the alrea dy safe operations that have been granted by the FAA for the establishment of the AMA National Model Aircraft Safety Code.

Preflight Action Plan The Petitioner will be	responsible	for maintaining	and	inspecting	the UAS	to ensure	 that	it	is	in	a	conditio n	 f or	safe	operation. Prior to each flight, the PIC shall conduct a pre

- flight 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 until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. This pre - flight	 inspection	 checklist will	 be revised as	 needed	 in	 order	 to ensure	 all	 known	 safety	 precautions	 and/or	 safety	 precautions	 suggested	 by	 the manufacturer	are	being	accounted	for.

1. Visual inspection for defects
2. Batteries fully charged and chec ked

- Transmitter, UAS, iPad, iPhone, approved/compatible device
3. Props tightened and locked
4. SD card in camera22 5. Run finger along the edge of edge of each rotor blade to check for any rough edges.
6. Lens cap removed (a s necessary)
7

. Antenna e up and parallel
8. Transmitter turned on (press once, release, then press and hold for 3 seconds)
9

. Ensure Transmitter is in P Mode
10. Verify that the damping absorbers are not broken and/or worn.
11. UAS turned on (press once, release, then pres s and hold for 3 seconds)
12. Flick the transformation switch on transmitter up and down 4 times quickly to convert from travel mode to flight mode or use the app
13. DJI Pilot app quit and restarted, no other running apps on iPad
14. Tap bar at top of app (Safe to Fly GPS) for full status
15. Maps are cached (move the map around, zoom in an out)
16. Minimum return height adjusted (check for tallest object and set accordingly)
17. Home point reprogrammed via app
18. UAS placed in safe launch and reco ver position
19. Area clear of people / obstructions

Preventative Maintenance A	comprehensive	preventative	maintenance	plan	will	be	followed	in	order	to	ensure
the UAS software	is	 up

- to

- date,	 the	 batteries	 are	in	 good	 health,	 and	 the	 aircraft	itself	is23 always	ready	for	safe	flight. Each	UAS	operated	under	this	exemption shall comply	with	all manufacturer	safety	bulletins. In	seeking	this	exemption,	Petitioner	submits	that	the	equivalent	level	of	safety	with regard	to	the	regulatory	maintenance	and alteration	requirements	established	by	Sections 91.405(a),	 91.407(a)(1),	 91.409(a)(1)	&	 (a)(2),	 and	 91.417(a)	&	 (b)	 will	 be	met	 because Petitioner	 will	 perform	 maintenance,	 alterations,	 or	 preventive	 maintenance	 on	 the UAS using	 the	methods,	 techniques,	a nd	practices	prescribed	in	 the	operating	documents	 (i.e., the	Monthly	Maintenance	Log,	and	DJI	Phantom	3 User Manual). The Petitioner will follow the	 UAS	 manufacturer’s	 maintenance,	 overhaul,	 replacement,	 inspection,	 and	 life	 limit requirements	for	the	ai r craft	and	aircraft	components,	and	shall	document	and	maintain	all
mainten ance	records	for	the UAS. Since the UAS will be inspected as prescribed by the operating documents, Petitioner will maintain the equivalent or greater level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). Any UAS that has undergone maintenance or alterations that affect its operation or flight characteristics, e.g., replacement of a flight critical component, shall undergo a functional test flight pri or to conducting further operations under this exemption. Functional test flights will only be conducted by a PIC with a VO and shall remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as to not po se an undue hazard to persons and property.

Pilot in Command (PIC) Qualifications
T he P etitioner , with over 80 flights to date operating the Phantom 3 as a hobbyist , has the requisite experience, skill and ability to safely operate an unmanned aerial ve hicl e conducting24 similar commercial operations below 200 feet within strictly controlled , pre - approved a i rspace
. Since there are no standards fo r either private or commercial UAS pilot certificates, knowledge of airspace regulations and dexterity in th e c ontrol and operation of the UAS acquired from actual operation of the aircraft will be the most important factors in establishing an equiva lent level of safety.
T he petitioner has accomplished the following:
1. Perform ed in excess of 80 flights with the Phan tom. 2. Studied and is familiar with all sections of the "Phantom 3 User Manual "

. 3. Successfully learn ed and demonstrate d all flight maneuvers in the "Phantom 3 User Manual ".
4. Studied and is familiar with weather theory, aviation weather resources , and air space ,

Public Interest Granting this exemption would benefit the public as a whole

. UAS offer a strong equivalent or greater level of safety, a reduction in env i ronmental impacts , and are free from the harmful emissions associated with the manned aircraf t that are currently used for aerial photography and videography. Due to the small size of the UAS and the tightly controlled and limited airspace in which the UAS will operate, approval of this application actually reduces the risk to the public

. Furthe rmore, the public will be able to legally acquire ae r ial photography and videography to help in advertising commercial, residential and agricultural property for sale or development, safely accessing high and/or awkward areas of building exterior s to asses s damage that needs to be repaired , and to enjoy special events such as weddings or sporting events

.25 Privacy Since the areas being photographed or videoed will be on private property or over open
water , accessed only after receiving written and/or oral consent by the property owner(s), and clear of people except for the PIC and the PIC's helpe r (s), approval of this application presents no risk to the public privacy

.

National Security Due to the small size of the UAS a nd the tightly controlled and lim ited airspace over private property or open waters in which the UAS will operate, approval of this application presents no risk to nat i onal security

.

Requested Exemptions Petitioner requests exemption from the following regulations since it is not , in s ome instances, possible to comply or comply fully with them, and since attempting to follow them f or the purposes of operating a UAS would be unreasonably burden some if not impossible :

14 CFR Part 21, Subpart H Airworth i ness Certif i cates Subpart H est ablishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1)

. Given the size and limited operating area associated with the aircraft to be utilized by Petitioner , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act

. The Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the26 requirement for an ai rworthiness certificate, upon consid e ration of the size, weight, speed , operational capability, and proximity to airports and pop ulated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and u n der the condit i ons proposed, will be at least as safe , or safer, than a conventional aircraft operat i ng with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 3 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a controlled a rea . Unlike other civil aircraft, operations

un der this exemption will be tightly controlle d and monitored by the Petitioner . Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its diminutive size, relatively slow spee d of operation, location of operation s , lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 CFR § 45.23 (b). Marking of the Aircraft
The regulation requires: When marks include only the Roman cap ital letter "N" and the registration number is displayed 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 , cockpi t, 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

. Even though the UAS will27 have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed

. Given the size of the UAS, two

- inch lettering will be impossible. The word "Experimental" will be placed on the fuselage i n compliance with §45

. 29(f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45

. 29(f) where the operator working with the UAS will see the identification of the UAS as " Experimental." The FAA has is sued exemptions to this regulation to petition number s 10700, 8738 , 10167 and 10167 A

.

14CFR 61.3 Pil ot Certification This regulation requires that a person operating an aircraft in the NAS hold a pilot certificate. Relief from Section 61.3 entitled Req uirement for certificates, ratings, and authorizations may be required to the extent that the operator of an UAS is deemed to be

a “ required flight crewmember ” of that aircraft ( i.e. : a pilot is required to operate it). Relief is further requested to the extent required to allow Petitioner to operate the DJI Phantom 3 in the NAS without first obtaining any pilot certificate issued by the FAA or any other domestic or foreign licensing authority. Petitioner is of the belief that obtaining any pilot certifica te will not imp rove his ability to operate an UAS, whether within the NAS or otherwise. The re is very little similarity between the flight characteristics of a Phantom 3 UAS and any full sized,
passenger - carrying aircraft . The Phantom 3 cannot stall or s pin , can not taxi, is not adversely affected by crosswinds, does not need to make short or soft field takeoffs or landi ng s like a fixed wing aircraft (due to its very light weight, short and soft fiel d operations are unnecessary), and it typically climbs an d descends vertically . T he airspace28 within which the UAS will be operated will be at altitudes far lower than full

- sized aircraft operate , and in obstructed area s in which full

- sized aircraft cannot operate , so there will be no airspace conflicts or separ ation issues with them. A certificated pilot of a full

- sized aircraft capable of carrying passengers , who is lacking UAS flight training and experience , would not be as successful or safe as an non - certificated UAS pilot with extensive UAS training and fl ight experience. Petitioner also seeks the requested relief bec ause the Phantom is not capable of carrying ANY flight crewmembers

. Peti ti oner has studied those portions of the Private Pilot Handbook of Aeronautical K nowledge that pertain to the operation s to be conducted by the UAS.
T he equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft , and because the small size , light weight and slow speed of the aircraft do not require the airmanship skills required of a pilot of a full

sized aircraft, particularly if the aircraft were carrying passengers or cargo. Provided that the PIC maintain a high level of proficiency through initial and recurrent training and experience , the grant of this exempt ion would	 not	adversely	affect	 safety, but would provide	a	level	of	safety	at	least	equal	to	the	existing	rule.

14 CFR §91.7(a): Civil aircraft airworthiness. Petitioner seeks the requested relief because the DJI Phantom 3 does not require an airworthine ss certificate in accordance with 14 C.F.R. Part 21, Subpart H. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this29 exe mption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Procedures for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. Accordingly, r elief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Petitioner to determine that the DJI Phantom 3 is in an airworthy condition prior to every flight by ensuring that the UAS is in compliance with the DJI Phantom 3 User Manual, and that the aircraft is in a condition for safe flight. Therefore, prior to every flight, Petitioner will ensure that the DJI Phantom 3 is in an airworthy condition based upon a v isual inspection in order to determine that the aircraft and its components are in compliance with its type design and operating documents (i.e., the Phantom 3 User Manual and the requirements set forth herein ), and that the aircraft can be operated safely pursuant to the conditions and limitations stated herein.
14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9(b) (2) provides: No person may operate a U.S.

- registered civil

a ircraft ... (2) for which an Airplane or Rotorcraf t Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The Phantom 3 , given its size and configuration , has no ability or place to carry any flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety wi ll be maintained by keeping the flight manual at the ground30 control point where the PIC flying the UAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 956 58, 10167, 10167A, 10602, 32827, 10700 , and 11783



### .

14 CFR § 91.103(b): Preflight action This regulation requires that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This info rmation must include

— (b) for any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information... As FAA approved rotorcraft flight manuals will not be provided for the aircraft and because runways are not needed for takeoff and landing operations, an exemption will be needed. An equivalent level of safety will be provided as set forth in the operating documents . The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff locations and aircraft performance data before initiation of flight.

14 CFR 91.109 Flight inst r uction This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruc tion unless that aircraft has fully functioning dual controls.
UAS and most other remotely piloted aircraft, by their design , do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates wi th the air craft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of31 aircraft and for flight instruction in experimental aircraft. See	Exemption	Nos. 5778K	&
9862A. The equi valent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the small size and slow speed of the aircraft.

14 CFR §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exem ption is for a n UAS that is a helicopter and this petition requests authority to operate at altitudes up to 2 00 AGL, an exemption may be needed to allow such operations. As set forth herein, until future regulations permit otherwise the Petitioner’s UAS wi ll never operate at higher than 2 00 AGL. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it will be operated. In addition, the low

- altitude operations of the UAS will ensure separa tion between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119

.

14 CFR 91.121 Altimeter settings This regulation requires each person operating an aircraft to maintain cruising altitude by referenc e to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting avail able before departure." As the Phantom 3 does not have a barometric altimeter, but instead a is equipped with a barometric pr essure sensor32 and GPS equipment that automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the aircraft on the heads

- up display of the remote controller , an exemption may be nee ded. The PIC will achieve an equivalent level of safety by confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91 . 151 (a) Fuel Requirements for Flight in VFR Conditions This regulation prohibits an indi vidual from beginning "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 fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the Phantom 3 provides a maximum of 23 minutes of powered flight ; t hat would make it impossible to meet the 30

- minute reserve requiremen t. Given the limitations on the Phantom 3’s proposed flight area and the location of its proposed operations within a predetermined area, a shorter time frame for flight in daylight VFR conditions is reasonable. An equivalent level of safety can be achiev ed by limiting flights to 17 minutes or 25% of remaining battery powe r (whichever occurs first). This restriction would be mo re than adequate to return the UAS to its planned la n ding zone from anywhere in its limited operating area.33 14 CFR §91.203(a) an d (b): Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinent part : (a) Except as provided in § 91

. 715, no pe r son may operate a civil aircraft unless it has within it the following : (1) an appropriate and current airwo rthiness certificate ..

. (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 displayed at the cabin or cockpit entrance so that it is legible to passengers or crew

. The Phantom 3 fully l oaded weighs approximately 2.6 pounds and is operated without an on board pilot. As such , there is no ability or place to carry certification and registration documents or to display them on or in the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the PIC flying the UAS will have immediate access to them , to the extent they are applicable to the UAS

. The FAA has issued numerous exemp tions to this regulation

. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789 , 9789A, 9797, 9797A, 9816A , and 10700.

Maintenance I nspections 14 CFR 91.405 (a); 14 CFR 91.407 (a)(l) ; 14 CFR 91.409 (a)(l); 14 CFR 91.409 (a )(2); 14 CFR 91.417 (a) and (b) These regulations require that an aircraft operator or owner "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 se ction, have discrepancies repaired as prescribed in part 43 of this chapte r
... " , and others shall inspect or maintain the aircraft in compliance with Part 43.34 Given that these sections and Part 43 apply only to aircraft with an airworthiness certif icate, they do not apply to the operation of this UAS

. The Petitioner , pursuant to the aforementioned DJI Phantom 3 User M anual , will accomplish any required maintenance

. An equivalent level of safety will be ac hieved because these UAS are small in size, carry a small payload, and operate only in restr i cted areas for limited periods of time. I f mechanical issues arise the UAS can land immediately , and it will be operating from no higher than 200 feet AGL ( until such time as regulations permit operations at higher altitudes)

. As outlined in the aforementioned Preventative Maintenance section , the PIC will ensure that the UAS is in working order prior to initiating flight and will perform maintenance as required. Moreover , the Petitioner is the person mos t familiar with the

a i rcraft and best su i ted to maintain the aircraft in an airworthy condition to provide the equiva l ent l e vel of safety.

In accordance with 14 CFR Part 11, the following summary is provided for publication in the Federal Register:
Peti tioner seeks an exemption from the following rules: 14 CFR Part 21 , 14 CFR 45.23(b) , 14 CFR 61.3 , 14 CFR 61.23 , 14 CFR 91.7(a) , 14 CFR 91.9(b)(2) , 14 CFR 91.103(b)(2) , 14 CFR 91.109 , 14 CFR 91.119 , 14 CFR 91.121 , 14 CFR 91.151(a) , 14 CFR 91.203(a) & (b) , 1 4 CFR 91.405(a) 14 CFR 407(a) (1) , 14 CFR 409(a) (2), 14 CFR 417(a) & (b) to operate commercially a small , 3 pound unmanned aerial system ( UAS) for the purpose of conducting aerial photography and videography for use by owners of commercial and residential properties, realty agents, builders, contractors, developers and/or inspectors, and for weddings, golf	 tournaments,	 and	 sailing	regattas and an y other lawful purposes. Approval of exemptions allowi ng commercial operations of UAS will create a level of safety by reducing risk. Conventional elevated photography and inspections and associated tasks involve extreme risks to personnel physically cli mbing such structures and/or utilizing high35 rise equipment both of which create numerous and extreme risk to such personnel. In contrast, an UAS weighing less than 3 pounds and powered by batteries eliminates virtually all of that risk. The UAS will carr y no passengers or crew nor burn any fossil fuel and, therefore, will not expose personnel to any of the risks described above.

CONCLUSION The operation of UAS conducted in the strict conditions outlined above, will provide an equivalent or greater level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requi r ements of Part 21 and allowing commercial operations

. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, a n d as a result are far safer than existing operations conducted with helicopters operating in close proximit y to the ground, to people, or to buildings in the vicinity. Given the small size of th e UAS involved, the slow speed at which they must be operated in order to capture photos and videos, and the restricted environment within which they will operate, the Phantom 3 demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by exemption , allo w commercial operations of
UAS to commence immediately

. Also, due to the size of the UAS and the restrict ed a reas in which the Petitioner’s UAS will operate, approval of this application presents no threat to nationa l security. Given the clear direction in Section 333 of the Reform Act, the author i ty contained in the Federal Aviation Act , the strong equivalen t level of safety surrounding the proposed operations , the significant public benefit

- including enhanced safety , reduction in environmental impacts, no emissions, ability to legally obtain aerial photography and videography services

- the grant of the re quested exemptions is i n the public interest. Accordingly, Petitioner respectfully requests that the FAA grant the req uested exemption without36 delay. Satisfaction of the criteria provided in Section 333 of the Reform Act

- size, weight, speed, operating ca pability, proximity to airports and populated areas, operation within the visual line of sight, public safety, and national security

- provide more than adequate justification to grant petitioner’s requested exemption, allowing for commercial operations as described herewith.
WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Petitioner respectfully requests that the Administrator grant this Petition for an exemption from the requi rements of 14 CFR Part 21, 14 CFR 45.23(b), 14 CFR 61.3, 14 CFR 61.23, 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.103(b)(2), 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203(a) & (b), 14 CFR 91.405(a) 14 CFR 407(a) (1), 14 CFR 409(a) (2), 14 CFR 417(a) & (b) and permit Petitioner to operate UAS for the purpose of conducting aerial photography and videography for use by owners of commercial and residential properties, realty agents, builders, contractors, developers and/or insp ectors, and weddings, golf	tournaments,	and	sailing	regattas any other lawful purposes, for compensation or hire.

Dated: 18 June 2015 Sincerely, AVIATION LAW CENTER

Terence G. Haglund Enclosures (4)