June 14, 2015 Docket Operation, M-30 1200NewJersey Avenue, SE Room W12-140 West Building Ground Floor Washington, DC 20590-0001**Ae~al** PhotographJ And VldeographJ ...

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RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. §21, subpart H; 14 C.F.R. 42.23(b); 14 C.F.R. §§61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);(91.203(a) and (b); 91.405 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) and (b) to operate commercially for purposes in Real Estate. PERSONAL INFORMATION Name VINCENT ANTONIO PIATEK Company QUADPICTURES ADDRESS 1911 SW CAMPUS DR. #392 Federal Way, Washington 98023 253-335-2531 vincentapiatek@gmail.com

Dear Sir orMadam, / /

My name is Vincent Piatek, an owner and operator ofsmall unmanned aircraft systems and I am submitting request for exemption of Section 333 of the FAA Modernization and Reform Actof2012 and 14 C.F.R. Part 11oftheFederal Aviation Regulations. BACHGROUND I work is the Real Estate industry and specialize in photography and videography in Real Estate. When a realtor in the greater Seattle area is looking to list a piece ofproperty they want to showcase the best angles ofthe property, it is ofsignificant benefit to use an UAS for aerial photography and videographyto help the listing be very unique, Giving the buyer a greaterpicture ofthe quality and build ofthe house/property.REGARDING THE UNMANNED AIRCRAFT SYSTEM The UAS I will be using is a small quadcopter weighing less than 55 pounds with any and all payload. These UAS's operate at a speed no greater than 30 knots and can and can climb to an altitude to higherthen 400ftAGL. Itoperates only in the line ofmy sight as the sole operator and within a radius of300ft. These flight restrictions ensure that it is not a hazard to the aerospace in which it will operate. This UAS fall within the safety zone that the FAA will, with an exemption in place, allow commercial operations ofa UAS. The UAS I will be flying is a DJI PHANTOM 3 ADVANCED Serial number P76DCGI50I0484. The specific specifications are found below.



### Aircraft

Camera WEIGHT(INCLUDING BATTERY AND PROPELLERS) 1280 g DIAGONAL SIZE (INCLUDING PROPELLERS) 590mm MAXASCENT SPEED 5 m/s MAX DESCENT SPEED 3 m/s HOVERACCURACY

• Vertical:+/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m • Horizontal:+/- 1.5 m MAX SPEED 16 m/s (ATTI mode, no wind) MAXALTITUDE ABOVE SEALEVEL 6000 m OPERATING TEMPERATURE 

### ooc to 40°C GPSMODE GPS/GLONASS SENSOR SonyEXMOR l/2.3" Effectivepixels: 12.4M (total pixels: 12.76 M) LENS FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo ISO RANGE 100-3200 (video) 100-1600 (photo) SHUTTERSPEED

### Gimbal

VisionPositioning 8s -1/8000s IMAGEMAX SIZE 4000 X 3000 STILLPHOTOGRAPHYMODES

• Single Shot • Burst Shooting: 3/5/7 shots • Auto Exposure Bracketing (AEB): 3/5 • Bracketed Frames at 0.7EV Bias • Time-lapse VIDEO RECORDINGMODES 

### Phantom 3Advanced

• FHD: 1920x1080p 24/25/30/48/50/60 • HD: 1280x720p 24/25/30/48/50/60 SUPPORTED SD CARD TYPES Micro SD Max capacity: 64GB. Class 10 orUHS-1 ratingrequired MAXBITRATE OFVIDEO STORAGE 

### Phantom 3 Advanced 40 Mbps SUPPORTEDFILEFORMATS

• FAT32/exFAT • Photo: JPEG, DNG • Video: MP4, MOV (MPEG-4 AVC/H.264) OPERATINGTEMPERATURE 

### ooc to 40°C CONTROLLABLERANGE Pitch -90° to +30° STABILIZATION 3-axis (pitch, roll, yaw) MAXVELOCITY Less than 8 m/s (when 2m above ground) ALTITUDE RANGE

### Remote Controller

Battery Charger 30 cm-300 em OPERA TJNG RANGE 30 cm-300 em OPERATING ENVIRONMENT Surface with clearpattern and adequate lighting (Lux> 15) OPERATING FREQUENCY 2.400 GHz-2.483 GHz MAXDISTANCE 2000m (outdoors and unobstructed) VIDEO OUTPUTPORT USB OPERATINGTEMPERATURE

6000 mAh LiPo 2S MOBILE DEVICE HOLDER Fortablet orphone RECEIVER SENSITIVITY (1 %PER) -101 dBm ±2 dBm TRANSMITTERPOWER (EIRP)

• FCC: 20 dBm • CE: 16 dBm WORKINGVOLTAGE 1.2 A @7.4 V VOLTAGE 17.4

### v RATED POWER 

### Phantom 3 Advanced

• 57W CAPACITY 

### IntelligentFlightBattery 4480 mAh VOLTAGE

• 15.2

### vBATTERY TYPE LiPo 4S ENERGY 68Wh NETWEIGHT 365 g MAXFLIGHTTIME Approximately 23 minutes OPERATING TEMPERATURE -1

## ooc to 40°C MAX CHARGING POWER 100

### w PROCEDURESFORFLIGHT I will always follow procedures outline in the UAS operator's manual as to proper preflight inspection ofall hardware, software, environmental and any other factors needed to ensure a safe flight.

o Ifrequired, notify the appropriate FAA facility ofour launch schedule and location. o Checkweather for wind speed, cloud cover and any forecast change during flight. o Flowing takeoffI will hover 10 feet and assure the Home Point is solid and have Signalswith the GPS. o Iwill not fly over dense traffic orcrowds o I will give right-of-way to any manned aircraft. o I will stay clear ofFAA controlled airspace at airports as well as restricted and prohibited zones. o Examine the aircraft, Test batteries in remote control, and in the UAS. The only acceptable battle level before takeoffis 90% and the UAS with be grounded before battery reaches 25% o Permission from property ownerbefore flight. o With an Observer, make a walk around the area that is going to photographed or filmed. We will take note ofany trees, light poles, power lines, and or any other obstacles beforetakeoff. o Go over flight path, speed, distances, and altitude. o The operator will make sure the site is secure and a perimeter of25 feet offlight path ofUAS. FCCINFORMATION The UAS being deployed here is DJI PHANTOM 3 ADVANCED. The control link operates on a frequency of 2.4. The range is 2000m (outdoors and unobstructed) the receiver sensitivity is 1 01 dbm.QUALIFICATIONOFUAS PIC The PIC will have over 100 hours offlight time with UAS. The PIC has been flying UAS for over 3 years starting with the DJI PHANTOM 1 and then the PHANTOM 2+ and now operates the DJJ PHANTOM 3 ADVANCED. Because the UAS will not carry passengers and will fly within a restricted area, it will exceed the safety standards set forth in 14 C.F.R. 61.113 (a) and (b). At all times there will be an observer who will also monitor the UAS, surrounding buildings or obstacles and will be the second set ofeyes during flight of the UAS. OPERATIONS OFUNMANNED AIRCRAFT The UAS will be a tool for photography and video graphing real estate in the greater Seattle area. Clients will be able to view aerial pictures and videos ofproperty before purchase. This will give them abetterunderstating oflayout ofproperty. The flight ofthe UAS will not pose any safety threat to public. Flight will only be during the daytime. Batteries level will not be lowerthan 90% for takeoff. There will always be an observer for a second eye on the UAS during flight. A full pre-flight checklist and flight plan afterpermission is granted form property owner. The UAS will not operate if clouds are below 800ft AGL. This UAS does not fly over 29.1577 knots and speed will notreach over 10 knots (11.507 MPH). This will ensure great control ofthe UAS. The intended area ofoperation will be in rural settings, as well as neighborhood. Potential hazards are power lines, trees, structure, streetlights. Low flight speed oftheUAS when in operation for videography and photography for intended purpose, the PIC and observer will be able to safely maneuver the UAS around the hazards. The UAS also had capabilities to hover is place and fight the wind because ofGPS location. The UAS will NEVER be flown near the airports so as to pose any sort ofsafety concerns to pilots in the area. UAS Will never be flown within 5 miles radius of any large international airport and 0.6 miles ofa smaller regional airport. Ifthe UAS is in flight and tires to fly into a no fly zone, the UAS will stop and return home. Ifrequired by the FAA, I will notifythe FSDO ofmy flight operations priorto flight. 14 C.F.R. Part21, SubpartH, 91.203(a) & (b) Airworthiness Certificate Because the UAS in under 55lbs, fully loaded, and does not carry pilot, passenger, any explosive material or flammable fuel, operates in a fully restricted and controlled environment, Irequest exemption from 91.203 partA & B. 14 C.F.R. 45.23 B MarkingTheAircraft The UAS will not have an airworthiness certificate and because there is no entrance to the cabin, cockpit, or pilot station, there is no place inside the aircraft to place the word "Experimental" on the exterior ofthe UAS. However, due to size 2 inch lettering will not be possible.14 C.F.R. 61.113 A & B PrivatePilotPrivileges And Limitations: Pilotin Command Unlike civil aircraft, the UAS doesn't carry living things on board; rather, it is controlled remotely via a safe and restricted location. The risks during operation are so minuscule the PIC will exceed the present level of safety required for a commercial pilot to operate a rotorcraft. 14 C.F.R. 91.9 B(2): CivilAircraftFlightManualIn TheAircraft Because the UAS has not cockpit or storage space on board the flight manual will be carried by the PIC and observer at all timewhen operatingthe UAS. 14 C.F.R. 91.103 B(2): PreflightAction An extensive pre-flight inspection will take place before every flight. See Page 5 (Procedures for Flight) for pre-flight checklist. 14 C.F.R. 91.105: FlightCrewmembersat Station Because there are no human life aboard the UAS, regulation 91.105 should be exempt for my purpose ofusing my UAS. But the PIC and observer will be on the ground and have visual ofUAS at all time. 14 C.F.R. 91.109: FlightInstruction The UAS does not have dual controls. The PIC communicates to the UAS via radio Control Box. The FAA had approved exemption for flight training without fully functional dual controls for a number ofaircraft. 14 C.F.R. 91.119: Minimum SafeAltitudes The UAS will neverreach a flight altitude greater than 400ft AGL. Itwill always be flown with permission and consent ofproperty owner. 14 C.F.R. 91.121: Altimeter Settings The UAS doesn't use an altimeter. It has GPS (connects to 18 satellites) to determine the altitude. Will need and exemption since normal protocol is to set the altimeter to the barometric pressure reading at the time offlight. Before takeoffofthe UAS, I will ensure that GPS altitude is working correctly. 14 C.F.R. 91.151: FuelRequirementsForFlightin VFRCondition The battery life ofthe DJI PHANTOM 3 ADVANCED is capable of23 minutes (with mild temperature conditions) offlight and will not take flight with battery life lower than 90%. The UAS will not fly higher than 400ft AGL and 300ft away, at the furthest feet away the UAS will take no longer than 2 minutes to reach the ground. Battery life at 25% will be about 5mins offlight time, plenty oftimeto safely gethome and land. Battery life and time remaining offlight is displayed on the 1 0" screen visible to the PIC and observer at alltime. When battery life reaches 25% the UAS will automatically return home and land from place oftakeoff. 14 C.F.R. 91.203 A & B: Carrying CivilAircraftCertification And Registration The UAS does not have any storage on board to carry such documents. UAS weight under 55lbs and doesn't have an onboard pilot operating it. Ifrequired by the FAA, they will be carried at all time bythe PIC. 14 C.F.R. 91.405 A; 407 A(l); 409 A(2); 417 A & B: MaintenanceInspection This regulation applies to aircraft that have an airworthiness certificate and should not apply to the operation ofmy intended use for the UAS. Before each flight, maintenance of the UAS such as cleaning ofmotors, light, inspection ofprops and body for damage will take place. Each flight is logged on the software and also hand written. Ifrequired byFAA log book and software will be surrendered uponrequest. SUMMARY I Vincent Piatek feel my operation of my UAS will meet/exceed all current safety standards and regulations set by the FAA. I am seeking exemption from the following rules: REGULATIONFROMWHICH THEEXEMPTIONIS REQUESTED 14 C.F.R. §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. 91.103(b); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203 (a) and (b); 14 C.F.R. 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409(a) (2); 91.417(a) & (b) STATUATORYAUTHORITYFOREXEMPTION The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §401 01 ofthe Act, including sUASs, from the requirementthat all civil aircraftmust have a cur rent airworthiness certificate.The Administratormay grant an exemption from a requirement ofaregulation pres cribed under subsection (a) or (b) ofthis section or any sections 4470244716 ofthis Title Ifthe Administrator finds the exemption in thepublic interest.3 Section 333(b) ofthe Refor m Act assists the Secretary in determining whether sUASs may operate in theNational Air space System ("NAS") without creating ahazardtothe user, the public, or athreatto natio nal security. Inmakingthis determination, the Secretary must consider:

• The sUAS's size, weight, speed, and operational capability • Whetherthe sUAS operates within the visual line ofsight ofthe operator • Whetherthe sUAS operates outside ofhighlypopulated areas and away from close proximityto airports Ifthe Secretary determinesthat a sUAS "may operate safely in the national airspace system, the Secretary shall establishrequirements for the safe operation ofsuch aircraft in the national airspace system. Holder's proposed sUASs aremultirotorvehicles, weighing 15 orfewer lbs. includingpayload. They will operate under normal conditions at a speed ofno more than 5 0 mph and havethe capabilityto hover, and move in the vertical and horizontal plane simul taneously. They will operate only in line ofsight and will operate only withinthe sterile are a described inthe attached Exemption RequestAddendum (hereinafter "the Addendum"). Such operations will ensure thatthe sUASs will "not create a hazard to users ofthe nationa l airspace system orthe public. Given the small size ofthe sUASs involved and the areawithin which they will ope rate, Holder's application falls squarelywithin the zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofsUASsto commence. Also dueto the small size ofthe sUASs and the low altitudes and limited areas in which Holder's sUASswill operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 oftheReform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surroundingtheproposed operations, and the significantpublicbenefit, including enhanced safety and reduced environment impacts, the grant oftherequested exe mptions is in thepublic interest. Accordingly, Holderrespectfully requests thatthe FAA gr anttherequested exemption without delay so a sUAS can be leveraged on several projectsthat are already in construction. PUBLIC INTREST The fact the pilot has over 5 years ofexperience flying sUAS's demonstrates Quad Pictures without incident shows a high regard for safe operation with an understanding of FARs, pre-flight inspection, knowledge of operation and difference in airspace classification, maintenance and repair, as well as being trained to high safety standards. The DJI Phantom 3 is an extremely safe, efficient, and an economical alternative to manned, fix wing aircraft that are currently being used for aerial imaging ofreal estate property's. Three reasons why the public would benefit from granting Quad Pictures · exemption from these regulations 1) reduce the number ofmanned aircraft in the NAS. 2)The DJI P3 is much quit and would reduce air and noise pollution. 3) Reduce the risk of life and property the ground because ofno flammable materials on board and the size of the DJI P3.

Satisfaction of the criteria provided in the section 333 of the reform act of 2012 size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security, provides adequatejustification for the grant of the requested exemption allowing commercial operation of the DJI Phantom 3 (serial number P76DCG15010484) in the purpose of commercial real estate photography.

I respectfully request exemption for the above listed regulations in order to conducted aerial videography and photography for Real Estate. Please contact me at any time for any further information. Thank you for yourtime. Sincerely,

VincentPiatek Quad Pictures 1911 SW Campus Dr. #392 Federal Way, WA, 98023