IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

IMAGERHEE, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151(a)

91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Submitte d on 07/28/2015

By:

Mary Anne Baker

ImageRhee LLC

354 Ivy Ridge Circle

Sylva, North Carolina 28779

(828) 226

- 4492PETITION FOR RELIEF OF REQUIREMENTN OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS, SPECIFICALLY AS AUTHORIZED UNDER

THE F.A.A. MODERNIZATION AND REFORM ACT OF 2012, SECTION 333;

SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS.

Mary Anne Baker as ImageRhee LLC

ImageRhee, LLC seeks exemptions from Title 14 of the Code of Federal Re gulations: 61.113 (a) and (b); 91.7 (a); 91.119; 91.121; 91.151.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b), in order to operate a DJI Phantom 2 Quadcopter and a 3DR

- Solo Drone UAS. This exemption will
allow ImageRhee LLC to operate an unmanned aerial vehicle commercially for the purposes of conducting aerial video and still photography in the Tourism, Real Estate, and Hospitality markets of North Carolina, Georgia, and Tennessee . These still images and videos will provide b oth commercial and community awareness and understanding of aerial imaging systems.

ImageRhee, LLC is a Tourism, R e al Estate, and Hospitality photography company producing high quality results for clients who want to display image s and video for tourism promotion, real estate promotion, and hospitality promotion in t he Western North Carolina , Northeast Georgia, and East Tennessee
markets.

ImageRhee, LLC will be using a DJI Phantom 2 Quadcopter and a 3DR

- Solo Drone quad copter to commercially capture video stills and fil m while working on private and public properties for the purpose of aerial location services. ImageRhee, LLC will employ both an experienced pilot and utilize a
visual observer to maintain a visual line

- of

- sight between the quad copter a nd the pilot UAV operator.

THE DJI PHANTOM 2 QUADCOPTER

The DJI Phantom 2 Quadcopter is an electric powered quad copter weighing less than three pounds and is operated via a handheld remote that featu res “Return to Home” and “Follow Me” commands. The Return to Home feature can be triggered manually and the UAV unit works off of a 2.4 GHz downlink for
remote control. The video function works on 5.8 GHz frequency video. The default altitude setting for

t he DJI Phantom 2 Quadcopter is 400 feet AGL. The camera system is a Hero 3 and is operated from the
handheld remote control. Both units are powered by a single battery giving the DJI Phantom 2 Quadcopter approximately 25 minutes of flight time.

3DR

- SOLO DRONE QUADC OPTER

The 3DR

– Solo Drone Quadcopter is an electric powered quad copter weighing less than three pounds and is operated via a handheld remote that features “Return to Home” and “Follow Me” commands. The Return to Home feature can be triggered manually and the UAV unit works off of a 2.4 GHz
downlink for remote control. The video function works on 5.8 GHz fr equency video. The default altitude setting for the 3DR

– Solo Drone Quadcopter is 400 feet AGL. The camera system is a Hero 4 and is operated from the handheld remote control. Both units are powered by a single battery giving the 3DR

– Solo Drone Quadcopter app roximately 25 minutes of flight time.BASIS FOR PETITION

ImageRhee, LLC , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. SS 11.61) and
the F.A.A. Modernization and Reformed Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Admi nistrator to operate the DJI Phantom 2 Quadcopter and the
3DR

- Solo Drone Q uad copter within the National Airspace System, and for an exemption from the requirements of 14 CFR SS 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), 91.417 (a) and (b).

NAME AND ADDRESS OF THE PETITIONER

Mary Anne Baker
354 Ivy Ridge Circle Sylva, NC 28779
828

- 226

- 4492

IMAGERHEE, LLC Requests Relief from the Following Sections of 14 C.F.R.

• Sections 61.113, entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) and (b).

• Section 91.7, entitled Civil airworthiness subsection (a).

• Section 91.119 entitled Minimum Safe Altitu des, General.

• Section 91.121, entitled Altimeter Settings.

• Section 91.151 entitled Fuel requirements for flight in VFR conditions.

• Section 91.405, entitled Maintenance required.

• Section 91.407 (a) (1), entitled Operation after maintenance, preventa tive maintenance, rebuilding, or
alteration.

• Section 91.409 entitled Inspections.

• Section 91 the .417 entitled Maintenance Records.

Extent of relief that ImageRhee, LLC seeks regarding section 61.113 (a) and (b) Private pilot pri vileges and limitations: Pilot in Command, Subsections (a) and (b) prescribed the following, in part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compens ation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

–
(1) The flight is only incidental to that business or employment and

(2) The aircraft does not carry passengers or property for compensation or hire.Relief from section 61.113 (a) and (b) is requested to allow a PIC holding a current private pilot’s

certi ficate to operate the DJI Phantom 2 Quadcopter a or the 3DR

- Solo Drone Quadcopter

. The flight
would be complemented by a visual observer who will, along with the pilot, maintain visual line of sight
with the DJI Phantom 2 Quadcopter or the 3DR

- Sol o Drone Quadcopter at all times. All operations will be conducted as per ImageRhee LLC’s business related operations. The DJI Phantom 2 Quadcopter and
the 3DR

- Solo Drone Quadcopter are not able to carry passengers.

Extent of relief that ImageRhee, LLC seeks in regards to section 91.7(a), Civil Airworthiness; Relief from section 91.7(a), is requested to allow ImageRhee LLC to determine the air

- worthiness of the DJI Phantom 2 Quadcopter and the 3DR

- Solo Drone Quadcopter

.
Extent of relief that ImageRhee, LLC seeks in regards to section 91.119, Minimum Safe Altitudes; General. Relief from 91.119 is requ ested to allow operations of the DJI Phantom 2 Quadcopter or the
3DR

- Solo Drone Quad copter at altitudes not to exceed 400 feet AGL, over private property or at a distance at or greater than five nautical miles from the nearest airport as depicted on current
aeronautical charts.

ImageRhee, LLC also wishes to be granted exemptions to operate at an altitude not more than 50 feet
AGL or below tree level between one and five nautical miles from the nearest airport as depicted on
current aeronautical charts.

Extent of relief that ImageRhee, LLC seeks from 91.121, (a)

, Altimeter Settings

. Extent of relief from 91.121 is requested because the DJI Phantom 2 Quadcopter and the 3DR

- Solo Drone Quadcopter utilize an Electronic GPS with a barometric sensor.

Extent of relief that ImageRhee, LLC seeks in regard to section 91.151(a), Fuel Requirements for Flight in
VFR Conditions.

Relief from 91.151(b), is requested to the extent that ImageRhee LLC to operate the DJI Phantom 2 Quadcopter or the 3DR

- Solo Drone Quadcopter up to a point that there is enough power to fly at normal cruising speed to the landing point and land the vehicle with 25% battery power remaining. Note: a low battery alarm on the operating console s for the DJI Phantom 2 Quadcopter and the 3DR

- Solo Drone Quadcopter are equipped with a shaker mechanism to warn the pilot of a low battery
condition.

Extent of relief that ImageRhee, LLC seeks in regards to sections 91.405(a), 91.407(a)(1), 91 .409 point(a)(1) and (a)(2), 91.4179 1.417 ( a) and (b). These are all associated with an airworthiness certificate. There are currently no airworthiness certificates for small UAVs.

BENEFITS GAINED VIA RELIEF FOR ImageRhee LLC from the above stated Federal Regulations:

A. Use of the small UAV will allow for quicker and timelier aerial video and aerial photography of properties as contracted for.

B. Use of the small UAV will allow for more cost effective aerial video and aerial photography as the cost
to operate a small UAV is fractional compared to the cost of operating a full size aircraft for aerial photography.C. Use of the small UAV will l essen the use of full size aircraft for some aerial photography missions and

therefore give a somewhat greater safety ratio for the use of aerial photography.

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE REQUESTED EXEMPTIONS:

• Standard operating procedures prior to launch will include a preflight checklist of the vehicle and a visual inspection of area to be surv eyed at ground level will be performed.

• Flight operations will be conducted by a two man crew consisting of the PIC and the Visual Observer. All operations will be conducted with a clear line of sight between the UAV and the team.

• ImageRhee, LLC will only operate the UAV over private or public property with the permission of the property owner or the governing body and will maintain a safe distance from any structures, people or
vehicles.

This petition is being made pursuant to the FAA Modernization and Reform Act of 2012, Section 333, which directs the Secretary of Transportation to determine if any UAS may safely operate in the National Airspace. ImageRhee, LLC will operate all aircraft granted for use by the exemption as directed by the operating manual provided with the DJI Phantom 2 Quadcopter and the 3DR

- Solo Drone Quadcopter by the manufacturer s

.

IN CONCLUSION

As set forth previously ImageRhee, LLC seeks an exemption pursuant to 14 CFR: 11.61 and Section 333 of
the FAA Modernization and Reform Act of 2012 , which will permit safe operation of DJI Phantom 2 Quadcopter and the 3DR

- Solo Drone Quadcopter UAS commercially within the tourism , real estate and hospitality markets. The Administrator will be assisting small business and local tourism organizations by granting this petition.

In accordance with the FAA Modernization and Reform Act of 2012, ImageRhee LLC res pectfully requests that the FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF
FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91. 417 (a) and (b)

Respectfully submitted by Imag eRhee, LLC

.