United States of America Department of Transportat on 

Federal Aviation Administration 

Federal Docket Management System 

Washington, D.C. 

James M. Harper 

Inspectrite Inc. 

P.O. Box 231784 

Encinitas, CA 92023 

matt@inspectrite.com 

RE: Petition oflnspectrite Inc. for Exemption Purs t to section 333 of the FAA Reform Act. 

Attn: To whom it may concern 

Pursuant to Section 333 of the FAA Modernization d Reform Act of2012 (the Reform 

Act) and 14 C.F .R. Part 11, Hollenbeck Pest Control, operator of Small Unmanned 

Aircraft Systems (UAS) equipped to conduct aerial p otography and videography, 

hereby applies for an exemption from the listed Fede Aviation Regulations ("FARs") to 

allow commercial operation of its UAS, so long as su h operations are conducted within 

and under the conditions outlined herein or as may b established by the FAA as required 

by Section 333.1 

The proposed exemption, if granted, would allow Ins ectrite Inc. to conduct commercial 

operations of small, unmanned aircraft systems 

("U AS") meeting or exceeding all of the operational d safety requirements Congress has 

set forth in Section 333. 

Inspectrite Inc. plans to exploit the capabilities ofU 

multitude of services, including: 

• Aerial surveying 

• Creating own Commercial Advertising 

• Structural Inspections 

• Real Estate Photography 

• Aerial film making and photography 

• Construction site inspections and monitoring 

• Educational and research operations 

• Producing training videos 

Statutory Authority Section 333, titled "Special Rules or Certain Unmanned Aircraft 

Systems", provides a mechanism for seeking expedite 

operations in the NAS. Section 333(a) states that the "shall determine if certain unmanned 

aircraft systems may operate safely in the national air ace system before completion of the 

(comprehensive) plan and rule making required by secti n 332(b)(l) ofthis Act or the guidance 
required by section 334 of this Act." In Section 332(b) 1), Congress made it clear that Section 

333 provides a mechanism for "expedited operation au orization" if several factors are met. 

Petitioner meets all requirements to permit FAA appro al of commercial UAS operations. 

The Petitioner Requests Relief from the Following: 

Regulations from which the exemption is requested: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 (b) 

• 14 C.F.R. 61.113(a) and (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b) (2) 

• 14 C.F.R. 91.105 

• 14 C.F.R. 91.109 

• l4C.F.R.91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203 (a) & (b) 

• 14 C.F.R. 91.205 (b) 

• 14C.F.R.91.215 

• 14C.F.R. (91.401-91.417) 

Unmanned Aircraft System 

UA V s are oftentimes seen as superior to helicopters du to the smaller devices cheaper 

equipment and personnel cost, reduced noise and as sue , a much smaller environmental impact 

which promotes public safety. 

DESCRIPTION OF UAV TO BE DEPLOY D UNDER REQUESTED 

EXEMPTIONS 

Petitioner currently owns a DJI Phantom 3 UAS, Phantom as the primary UAS in commercial 

applications described herein . The Phantom 3 is a quad c pter that can take off and land vertically. It 

weighs approximately 3 lbs. and has a maximum airspeed of approximately 25 knots. This UAS uses 

lithium polymer batteries which have approximately 20 - 2 minutes of total charge time . This gives this 

UAS approximately 12-15 minutes of flight time with suffici nt remaining battery charge to land safely. 

The particular model of OJI Phantom 3being utilized unde this request for exemption has First Person 

View (FPV) which allows the PIC to visually monitor certai telemetry data on a ground station monitor 

including altitude (AGL), GPS signal strength, battery char e information, etc. This FPV also gives the 

PIC video feed from the attached camera showing what i ges are being captured . This is a significant 

safety feature as it shows the attitude of the UAS and its f rward direction. However, this FPV feature will 

never be used as a tool to deviate from VLOS operation b the PIC. 

PREFLIGHT 

The petitioner will always follow procedures outlined in the UAS operator's manual as to proper preflight 
inspection of all hardware, software, environment and an other factors needed to ensure a safe flight. 

The PIC will make a visual walk through of the area, ident fy hazard s, and notify and bystanders of the 

flight operation. 

FCC INFORMATION 

The UAS being deployed here is a OJI Phantom 3. The c ntrollink operates on the 2-4 GHz ISM radio 

frequency. Its published range is 1000 meters (3280 feet) The receiver sensitivity is -97d8m. 

PIC QUALIFICATIONS 

The PIC for lnspectrite Inc. will hold no less than a Sport ilot Certificate and/or UAS Operator 

Certificate (Docket No. : FAA 2015-0150; Notice No. 15-0 ) and have no less than 25 hours of PIC time 

in the UAS being deployed before beginning any type of c mmercial for hire operations and conform to all 

safety protocols. 

DESCRIPTION OF INTENDED COMMERCI L OPERATIONS 

Petitioner intends to solicit work for aerial photography, re I estate or construction inspections from real 

estate agents and brokers, insurance companies & relate vendors, banks and private property owners to 

provide photography and videography of residential, com ercial and rural real estate, land or crop 

surveys, or general aerial photography/videography. This ark will always be conducted with the 

permission of the property owner or their respective agent Flight operations will be restricted to flights 

directly over the property that has granted permission. Gi n the type of work being targeted here , the 

Petitioner does not foresee any instance where the UAS auld be flown over any crowds or assemblages 

of people in an open air environment. Safety will always b the primary concern regarding any flight at 

any time. 

UAS OPERATING PARAMETERS 

The UAS being deployed in these exemption request can ly at a speed of approximately 25 knots. 

However, given the intended use describe here, this spee will never be necessary. Much slower speeds 

are preferred to collect the photographic material needed. 

Although the UAS being deployed has an approximate co trol link distance of 3/4 mile, this is much more 

than VLOS will allow. Petitioner agrees never to fly UAS o tside of VLOS . 

Petitioner will only fly UAS during the day in VMC conditio s. Given the petitioner agrees to never fly 

higher than 300 feet AGL, distance from clouds should no be a factor if flown in VMC condition s. 

Petitioner agrees to use a Visual Observer (VO) during all perations. The VO will be used to help assure 

VLOS at all times. The UAS will not operate within 5 nauti al miles of an airport reference point as 

denoted on a current FAA published aeronautical chart. W thout first obtaining proper clearances. 

The UAS being deployed with these exemption requests h s the capability of using GPS signals to return 

to its initial point of take off if connection with the radio con rol link is lost. 

The petitioner agrees to yield right of way to all manned a ation activities at all times. 

EXEMPTION REQUESTS 

The following are a list of Title 14 CF As which the petition r seeks exemption . Please note that the 

Petitioner has used Exemption No. 11138 to Douglas Trud au (Regulatory Docket No. FAA-2014-0481) 

as a reference. Given that the petitioner and Mr. Trudeau i tend to use the exemptions in similar manners 

and both use similar equipment, it seemed prudent not to urden the reviewer in this matter with 

exemption requests that have been previously deemed th relieve was not necessary. These rules are 

Part 21, 45.23(b). 91.9(b)(2), 91.1 03(b), 91.109 and 91 .2 (a) & (b). If the reviewer believes that these 

rules need to be addressed in this request, the petitioner ill make a supplemental request including 

these additional rule exemptions. 

RULE 61.113 PRIVATE PILOT PREVELEGES AND LIMITATIO S 

As to private pilot limitations concerning operations for hire or compensation, it seems that Exemption 
No. 11062 to Astraeus has allowed this exemption previa sly and was noted in the Trudeau Exemption 

No. 11138. 

As to airmanship skills, the Petitioner has been operating is UAS since 2013 and has over 100 hours of 

flight time. Petitioner currently fly's this UAS several hour a month as a hobby and is very proficient and 

has the skills to maintain altitude, maintain VLOS, navigat , avoid obstacles, avoid air traffic and respond 

to loss of control link. 

RULE 91.7(a) CIVIL AIRCRAFT AIRWORTHINESS 

There is no current FAA regulatory standard for determini g airworthiness of UAS and there is no 

certificate currently available for UAS airworthiness. Petiti ner seeks an exemption from this rule by 

ensuring that the UAS is in an airworthy condition based compliance with the operating documents 

prior to every flight. Flight manuals and other important d uments will be kept in a location readily 

accessible to the PIC at all times. 

RULE 91.119(c) MINIMUM SAFE ALTITUDES 

91.119 prescribes safe altitudes for the operation of civil a rcraft, but it a llows helicopters to be 

operated at lower altitudes in certain conditions. Petitione seeks an exemption from this rule as 

Petitioner will only operate the UAS in a range from groun level up to but not exceeding 400 feet (AGL) 

and will only operate in safe areas away from the public th s providing a level of safety not available to 

manned aircraft. The petitioner asserts that given the size, weight, maneuverability and speed of the 

UAS, an equivalent or higher level of safety will be achiev d that from conventional manned helicopters. 

Petitioner will avoid actively populated areas. Petitioner in nds to operate the UAS over real estate for 

inspection purposes. Petitioner will not operate over any a semblage of people in an open air 

environment. 

Per the exemption granted in No. 11138 concerning 91.11 (c), Petitioner agrees to act in strict 

accordance to that exemption. However, Petitioner seeks n exemption from the rule stipulating that a 

UAS cannot be operated within 500 feet of a structure wit ut permission of the owner. Given the 

intended use Petitioner will use these exemptions for, whi h is for photography and videography of real 

estate for marketing & inspection purposes, agreement fro the engaging property owner or their 

agent is an absolute necessity. The UAS will only be flown over properties with this permission. 

However, given the housing density in the Atlanta, GA are , maintaining a 500 foot distance from other 

structures even while strictly flying over a permission gran ng owner's property is impossible in many 

instances. The Petitioner seeks an exemption to this rule hich would allow a so' stand-off from other 

structures as long as the UAS is operated completely over and within the property boundary lines of a 

permission granting property owner. Petitioner agrees to a ays keep privacy rights of other property 

owners in mind and will never engage a UAS in any type o surveillance or spying. 

RULE 91.121 ALTIMETER SETTINGS 

Petitioners' UAS has GPS derived altitude capabilities with a barometric sensor. The petitioner believes 

this rule in not applicable to the UAS operations intended. 

RULE 91.151(a) FUEL REQUIREMENTS FOR FLIGHT IN VFR ONDITIONS 

Petitioner seeks relief from this rule due to the UAS being eployed is battery operated and the 

requirements under this rule are not applicable. The UAV i question has First Person Vision capabilities 

which transmits certain telemetry to a monitor where the PI can monitor certain aspects of the flight 

including battery level. A typical battery for a Phantom 3 U Swill last approximately 20-25 minutes 

before total exhaustion. Certain battery level warnings are et where the PIC will know when the battery 

state is at 30% and 15% remaining charge levels. This will ormally allow a flight of 12- 15 minutes with 

sufficient battery charge to make a safe landing. Petitioner ill never begin a flight unless a fully charged 

battery is used. RULE 91.405(a) MAINTENANCE REQUIRED, 91.407(a) OPE TION AFTER MAINTENANCE, 

PREVENTITIVE MAINTENANCE, REBUILDING ORAL TERATI N; 91.409(a) (2) INSPECTIONS; 91.417(a) 

(b) MAINTENANCE RECORDS 

Petitioner seeks relief from these rules due to it being anal ernate inspection requirement of 91.409{a) 

(2). The Petitioner will inspect and ensure UAS is in a cond tion for safe flight and adhere to all operating 

documents. 
/_. 

SUPPLEMENTAL INFORMATION 

The Petitioner has provided the following information to s pport these requests for rule exemptions: 

1) OJI Phantom 3 User Manual 

2) OJI Phantom 3 Quick Start Guide 

3) DJI Phantom 3 Safety Guidelines and Disclaimer 

4) DJI Smart Flight Battery Safety Guidelines 

CLOSING 

The Petitioner believes that exemption from the above lis ed Title 14 CFRs is warranted given the nature 

of the type of UAS flights that will be undertaken, the size weight of the UAS being deployed, the 

safety precautions to the general public and the NAS the etitioner intends to adhere to, the positive 

environmental impact the flight operations would have co pared to manned fuel consuming missions 

and the economic benefit the Petitioner's business would ave in this new area of aviation. 

Thank you for your review of this matter. Please feel free contact me at any time with any questions 

regarding this matter. 

James M. Harper 

Inspectrite Inc. 

P.O. Box 231784 

Encinitas, CA 92023 

m~s/7