### United States ofAmerica Department ofTransportat on Federal Aviation Administration Federal DocketManagement System Washington, D.C. James M. Harper Inspectrite Inc. P.O. Box231784 Encinitas, CA92023 matt@inspectrite.com 

## RE: Petition oflnspectrite Inc. for Exemption Purs t to section 333 ofthe FAAReform Act. Attn: To whom itmay concern Pursuant to Section 333 ofthe FAA Modernization d Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Hollenbeck Pest Control, operatorofSmall Unmanned Aircraft Systems (UAS) equipped toconduct aerial p otography and videography, hereby applies for an exemption from the listed Fede Aviation Regulations ("FARs") to allow commercial operation ofits 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, ifgranted, would allow Ins ectrite Inc. to conduct commercial operations ofsmall, unmanned aircraft systems ("UAS") meeting or exceeding all ofthe operational d safety requirements Congress has set forth in Section 333. Inspectrite Inc. plans to exploit the capabilities ofU multitude ofservices, including: • Aerial surveying • Creating ownCommercial 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 orCertainUnmanned Aircraft Systems", provides a mechanism for seeking expedite operations intheNAS. Section 333(a) states thatthe "shall determine ifcertain unmanned aircraft systems may operate safely inthe national air ace system before completion ofthe (comprehensive) plan and rule makingrequired by secti n 332(b)(l) ofthis Act

### orthe guidance

### required by section 334 ofthis Act." In Section 332(b) 1), Congress made it clearthat Section 333 provides a mechanism for "expedited operation au orization" ifseveral factors are met. Petitioner meets all requirements to permit FAA appro al ofcommercial UAS operations. ThePetitionerRequests Relieffrom the Following: Regulations from which the exemption is requested: • 14 C.F.R. Part21 • 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 superiorto 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 UAVTO 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 oftotal charge time . This gives this UAS approximately 12-15 minutes offlight time with suffici nt remain ing 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 ofthe 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 petitionerwill always follow procedures outlined in the UAS operator's manual as to proper preflightinspection ofall hardware, software, environment and an other factors needed to ensure a safe flight. The PIC will make a visual walk through ofthe area, identfy hazard s, and notify and bystanders ofthe 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 ofc 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 ofthe property owner ortheir respective agent Flight operations will be restricted to flights directly overthe property that has granted permission. Gi n the type ofwork 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 her e, 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 ofVLOS . 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 ifflown 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 ofan 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 capabi lity of using GPS signals to return to its initial point of take off ifconnection with the radio con rol link is lost. The petitioner agrees to yield right ofway to all manned a ation activities at all times. 

## EXEMPTION REQUESTS The following are a list ofTitle 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). Ifthe 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 ExemptionNo. 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 airtraffic 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 ofcivil a rcraft, but it a llows helicopters to be operated at lower altitudes in certain conditions
. Petitione seeks an exemption from this rule as Petitionerwill 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 ofthe 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 engag ing 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-offfrom 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 ofthe 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 ofthe 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 ofthis 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, CA92023



# m~s/7