Alex Lazzarinetti July 14, 2015

Dragonfly Visuals, LLC

619 Moss Circle

Placentia, CA 92870

Cell (714) 317-6634

Email: alex@dragonflyvisuals.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1) DJI Phantom 3 Professional User Manual V1.2

2) DJI Inspire 1 User Manual V1.2

3) DJI S900 User Manual V1.2

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481

in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355

in the matter of the petition of FLYING CAM INC

4) FAA Exemption No. 11437 Regulatory Docket No. FAA20150221

in the matter of the petition of MARCUS D MELHUS

Dear Sir or Madam,

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

section 333 of the FAA Modernization and Reform Act of 2012, I Alex Lazzarinetti, referred to

hereafter as the petitioner, request exemption from 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, and other flight operations that could be performed safely and

more cost effectively with the use of small UAS at low altitude within the U.S. national airspace

system as compared to a manned aircraft. Operations will be in support of local fire departments

and related emergency service agencies, focusing on pre-incident planning and imaging that

would form the basis for incident action plans in the event of a real emergency. Operations will

be performed only at the request of and with the authorization and permission of clients

(municipalities) or their authorized agents in order to improve incident pre-planning and raise

awareness of the beneficial uses of small unmanned air systems for use within the fire service to

improve their ability to respond in the event of a real incident. Furthermore, operations would 

also be for production companies wanting to get aerial cinematography thru the use of 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 exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an experienced UAS

operator with the addition of a trained observer. All pre-flight inspection, maintenance and flight

logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for

review; with the purpose of safely integrating civil UAS operation in the National Airspace

System.

91.119(c)

As discussed in Exemption 11138 (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 “congested areas”'and

“densely populated”. The petitioner requests waiver for this condition to allow reasonable and

responsible operations in areas of subdivisions and neighborhoods if required.

The petitioner will primarily operate the UAS between ground level and 200 feet. The

UAS will be operated over designated properties with the consent of the local municipality or

their designated agent and while maintaining a safe distance from persons. The petitioner will

compile flight data from the logs. This data may assist the FAA in development of regulations

for commercial operations in low-risk, controlled environments.

91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the

UAS does not have an altimeter and instead utilizes electronic 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 the prescribed minimums,

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has
been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. 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. Those documents contain a

condition in which the PIC will initiate a landing procedure when 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)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to

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

documents. The FAA found that adherence to the petitioner’s operating documents and the

conditions and limitations specified, describing the requirements for maintenance, inspection,

and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS's

The DJI Phantom 3 professional, Inspire 1 and S900 are highly successful consumer and 

professional grade small rotorcraft in both the quadcopter and hexacopter (S900) configurations. 

The Phantom 3 with an advertised weight of less than 46 Ounces (1282g) is designed

primarily to carry aloft a high definition camera. It has an advertised maximum speed of less

than 31 knots (16 m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is

powered by four electric motors with a distance between motors of less than 14 inches (350mm).

It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented

with two global positioning systems (GPS/GLONASS) to maintain its geospatial orientation and 

position. It is controlled primarily through an FCC certified radio control (RC) 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 

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 and external lighting cues 

before reaching a low battery state. An automatic termination of flight and landing will be 

initiated when the battery reaches a predetermined low state. It is anticipated that flights will 

usually last less than 15 minutes. More information is available in attachment 1.

The Inspire 1 also known as T600 with an advertised weight of less than 104 Ounces (2936g) is 

designed primarily to carry aloft a high definition camera. It has an advertised maximum speed 

of less than 43 knots (22m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/

s). It is powered by four electric motors with a distance between motors of less than 16 inches 

(350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS) to maintain its geospatial orientation and 

position. It is controlled primarily through an FCC certified radio control (RC) 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 

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 18 

minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues 

before reaching a low battery state. An automatic termination of flight and landing will be 

initiated when the battery reaches a predetermined low state. It is anticipated that flights will 

usually last less than 13 minutes. More information is available in attachment 2.

The S900 (with gimbal and camera) has a weight of 17.68 lbs and is designed primarily to 

carry aloft a high definition camera. It has an advertised maximum speed of less than 31 knots 

(16m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by six 

electric motors with a distance between motors of less than 20 inches. It utilizes an internal 

inertial measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) to maintain its geospatial orientation and position. It is controlled 

primarily through an FCC certified radio control (RC) 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 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 15 minutes. The 

onboard flight controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. An automatic termination of flight and landing will be initiated 

when the battery reaches a predetermined low state. It is anticipated that flights will usually last 

less than 13 minutes. More information is available in attachment 3.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 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 checklist will be developed and 

employed to ensure that the UA airworthiness will be verified before launch.

Airworthiness will be maintained by performance of routine inspections before each flight, 

maintaining flight and maintenance logs to record time on failure prone components. These 

documents will be made available to the FAA and to assist in future implementation of safety 

standards and regulations. The petitioner will only operate the UAS over designated properties 

with the clients consent. Flight plans will be predetermined to limit the UASs flight time and 

limit safety concerns. The petitioner will take into account distance from persons and potential 

flight obstacles prior to operating the UAS. UAS operation will always be within VLOS of the 

PIC and the observer.

Public interest
Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, 

carrying a crew and flammable fuel. The petitioner will provide clients with photographic data 

for these purposes on a ‘for hire’'basis acting as an independent contractor. A visual observer will 

be utilized. Flight data including UA flight time, Control Unit operation time, incident, accident, 

and details concerning any deviations from normal operations will be available to FAA for use in 

collecting data regarding the use of UAS as part of this application. This data may be submitted 

to FAA via traditional means or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, inspections and other flight operations”. The reason for such a

general and broad based request is that the petitioner wishes to provide services to both private 

and public sectors that can only be provided through the quick deployment and cost effective 

operations provided by a UAS. It is believed that these services will allow clients to significantly 

improve their pre-planning and situational awareness which in turn will lead to more efficient 

mitigation of incidents, thereby reducing property loss and improved the safety of both building 

occupants and emergency services personnel. In additional to proving services to production 

companies. The petitioner's business model is based on the idea of offering ad hoc small UAS 

services to clients who wish to employ these services as a safe, effective, and legal option to 

enhance their operations and/or needs. By providing this service to multiple clients, the petitioner 

can ensure adherence to standards and protocols and can develop and refine generally applicable 

safety guidelines and processes. The petitioner has refrained from engaging in commercial use of 

the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those 

services while remaining in compliance. The petitioner over 10 years of experience in the radio 

control model aircraft hobby. In addition, the petitioner has more than 15 years of general 

aviation SEL experience and holds a current Private Pilot certificate (2859057).

Respectfully submitted

Alex Lazzarinetti