May	1,	2015

Petition	for	Exemption	14	CFR	11.81

Dave	Kettering

801	Bluff	Street

Dubuque,	Iowa

52001

(563)-588-5715,	(563)	590-8205

Dear	Sir	or	Madam,

In	accordance	with	the	FAA's	Guidelines	for	Submitting	Petition	for	Exemption	under	

Section	333	of	the	FAA	Modernization	and	Reform	actof2012,	I	Richard	W,	Ross,	

owner	and	operator	of	Just	Homes	Photography,	LLC	referred	to	hereafter	as	the	

petitioner,	request	exemption	to	the	following	sections	of	Title	14,	Code	of	Federal	

Regulations:

61.113(a);	61.113(b);	91.119(c);	91.121;	91.151(a);	91.405(a)	91.407(a){1);	

91.409(a)(1);	91.409(a)(2);

91.417(a)&(b)

In	order	to	operate	small	unmanned	aircraft	systems	(UAS)	commercially	in	

airspace	regulated	by	the	Federal	Aviation	Administration	(FAA)	for	the	purposes	of	

Aerial	Photography,	Cinematography,	Videography,	Inspections	and	other	flight	

operations	that	could	be	performed	safely	and	more	cost	effectively	with	the	use	of	

small	UAS	at	low	altitude	within	the	US	National	Airspace	System	as	compared	to	a	

manned	aircraft.	Operations	will	only	be	performed	at	the	request	of	and	with	the	

authorization	and	consent	of	clients	and	their	authorized	agents	in	order	to	facilitate	

commerce	and	raise	awareness	of	beneficial	uses	of	small	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.	The	conditions	identified	and	

proposed	by	the	petitioner	are	drawn	from	references	1-3.

The	FARs

The	petitioner	seeks	the	exemption	from	the	above	mentioned	FARs	for	the	

following	reasons:

61.113(a)	&	(b):	The	petitioner	requests	relief	in	order	to	facilitate	utilization	of	

pilots	who	hold	a	PRIVATE	PILOT	(or	greater)	certificate.	Any	pilots	operating	
under	this	exemption	would	be required	to	comply	with	any	conditions	as	set	forth	

and	in	a	similar	fashion	as	the	previously	granted	exemptions.

91.119(c)	As	discussed	in	Exemption	11139	(Douglas	Trudeau),	operations	

conducted	closer	than	500	feet	to	the	ground	may	require	that	the	UA	be	operated	

closer	than	500	feet	to	essential	persons	or	objects	that	would	not	be	possible	

without	additional	relief.	The	petitioner	requests	modification,	waiver	or	exemption	

and	clarification	concerning	the	terms	of	"congested	areas"	and	"densely	

populated."	The	petitioner	requests	waiver	for	this	condition	to	allow	reasonable	

and	responsible	operations	in	areas	of	subdivisions	and	neighborhoods.

91.121	As	discussed	in	Exemption	11138	(DOUGLAS	TRUDEAU),	this	is	inapplicable	

since	the	UAS	does	not	have an	altimeter	and	instead	utilizes	GPS	with	a	barometric	

sensor	for	altitude	information.

91.151(a)	As	discussed	in	Exemption	11136	(ADVANCED	AVIATION	SOLUTIONS	

LLC)	prior	relief	has	been	granted	for	manned	aircraft	to	operate	at	less	than	

prescribed	minimums	including	Exemption	NO.s	2689,	5745,	and	10650.	In	addition	

similar	UAS	specific	relief	has	been	granted	an	Exemption	No.s	8811,	1080,	and	

10673	for	daytime,	VFR	operations.	The	UAS	provides	battery	power	remaining	in	

percent	to	the	PIC.	The	UA	batteries	provide	approximately	25	minutes	of	powered	

flight.	Information	provided	in	the	operating	documents	discusses	procedures	

regarding	remaining	battery	power	management.	The	documents	contain	a	

condition	in	which	the	PIC	will	initiate	a	landing	procedure	when	the	battery	

remaining	reaches	a	specified	level.	Given	the	limitations	on	proposed	operations	

and	the	location	of	those	proposed	operations,	the	FAA	found	that	a	reduced	

minimum	power	reserve	for	flight	in	daytime	VFR	conditions	was	reasonable.

91.405(a);	91.407(a);	91.409(a)	(1)	&	(2);	91.417(a)	&	(b)	As	discussed	in	

Exemption	11138	(DOUGLAS	TRUDEAU),	the	petitioner	proposes	to	inspect	and	

ensure	the	UAS	is	in	a	condition	for	safe	flight	in	accordance	with	the	operating	

documents.	The	FAA	found	that	adherence	to	the	petitioners	operating	documents	

and	the	conditions	and	limitations	specified,	describing	the	requirements	for	

maintenance,	inspection	and	record	keeping,	were	sufficient	to	ensure	that	safety	

would	not	be	adversely	affected.

The	UAS

The DJI	Inspire	1	is	highly	successful	consumer	grade	small	rotorcraft	in	the	

quadcopter	configuration	with	an	advertised	weight	of	less	than	106	Ounces	

(3000g)	designed	primarily	to	carry	a	high	definition	camera	aloft.	They	have	an	

advertised	maximum	speed	of	less	than	43	kts	(22	m/s)	and	a	maximum	climb	rate	

of	less	than	1200	fpm	(6	m/s),	They	are	powered	by	4	electric	motors	with	a	

distance	between	the	motors	of	less	than	18	inches	(457	mm).	It	utilizes	an	internal	

inertial	measuring	unit	(IMU)	with	integrated	barometric	sensor	to	augmented	with	
Global	Positioning	System	(GPS)	to	maintain	its	geospatial	orientation	and	position.	

It	is	controlled	primarily	through	an	FCC	certified	radio	control	(Re)	unit.	Real	time	

video	and	telemetry	information	is	transmitted	back	to	a	ground	control	station	

allowing	the	operator	and/or	PIC	to	monitor	battery	level,	GPS	signal	strength,	

altitude	(AGL),	distance	from	the	PIC,	camera	imagery,	and	control	camera	angle.	It	

has	failsafe	modes	of	operation	for	either	loss	of	RC	or	GPS	signal.	Altitude	can	be	

limited	by	the	onboard	flight	controller	and	maximum	altitude	can	be	

preprogrammed	by	the	PIC.	Battery	life	limits	flight	times	to	approximately	25	

minutes.	The	onboard	flight	controller	will	warn	the	pilot	via	telemetry	data	and	

external	lighting	cues	before	reaching	a	low	battery	state.	An	automatic	termination	

of	flight	and	landing	will	be	initiated	when	battery	reaches	a	predetermined	low	

state.	It	is	anticipated	that	flights	will	usually	last	less	than	15	minutes.	More	

information	is	available	in	attachment	3	and	4.

Risk	Mitigation

The	petitioner	has	reviewed	FAA	exemptions	references	1-3	Conditions	and	

Limitations	section	and	believes	that	the	procedures	specified	therein	are	

reasonable	and	will	be	utilized	in	order	to	manage	and	mitigate	risk	and	ensure	

public	safety.	A	preflight	and	post	flight	checklist	will	be	developed	and	employed	to	

ensure	that	UA	airworthiness	will	be	maintained	for	flight	operations.	Flight	time	

and	maintenance	logs	will	be	maintained	to	ensure	tracking	on	failure	prone	

components.	The	petitioner	requests	that	in	a	manner	similar	to	reference	3,	he	be	

allows	to	operate	within	5	miles	of	an	airport	provided	that:

"The	UAS	may	not	operate	in	Class	8,	CorD	airspace	without	written	approval	of	the

FAA	The	UAS	may	not	operate	within	five	nautical	miles	of	the	geographic	center	of	a	

nontowered	airport	as	denoted	on	o	current	FAA-published	aeronautical	chart	unless	

a	letter	of	agreement	with	that	airport's	management	is	obtained,	and	the	operation	is	

conducted	in	accordance	with	a	NO	TAM	as	required	by	the	operator's	GOA	The	letter	

of	agreement	with	the	airport	management	must	be	made	available	to	the	

Administrator	upon	request.	"

Operations	within	5	miles	of	an	airport	are	not	anticipated	to	be	routine,	but	the	

petitioner	is	requesting	a	mechanism	to	facilitate	such	activities	without	requesting	

a	new	and	separate	exemption	should	the	need	arise.	Operations	within	class	B	

airspace	are	not	requested	due	to	the	lack	of	a	mode	C	transponder.

Public	Interest

My	goal	in	obtaining	the	exemption	for	14	CFR	11.81 section	333	is	to	add	the	

advantage	of	aerial	footage	used	to	inform	my	clients	of	news,	provide	them	with	a	
different	perspective	of	life	and	give	them	a	different	view	of	several	various	news	

situations.		

Allow	the	public	to	view video/photo	footage	to accompany	informative	news	

stories.