October 12, 2015

United States Department of Transportation Federal Aviation Administration 800 Independence Ave, SW Washington, D C 20591
Re: Exem ption from requirements of specific provision s of Section 333 of the FAA Modernization and Reform Act of 2012 pursuant to the Federal Aviation Regulations Dear Sir or Madam; I, Dane Sponberg , of Raftermen Photography (Petitioner) , respectfully request an exem ption from

several provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of a small Unmanned Aerial System (UAS) commercially, in airspace regulated by the Federal Aviation Administration (FAA). Raftermen Photography provides clients with photographs and videos for advertising and public uses , and wishes to operate a small light
- weight UAS for the commercial purpose of conducting aerial video and photography of events and real est ate for public and private use
. This r equest is for exemption from 14 C.F.R §§ 91.7(a), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b), pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems. The basis for this exemption request is outlined in this petition as well as in the supporting DJI Phantom Vision 2+ Owner’ s Manual which can be found in Appendix A
. Sincerely,
Dan e Sponberg Raftermen Photography Address Phone Number Email**PROPOSED OPERATIONS**

I, Dane Sponberg , intend to use the UAS for one purpose

– to perform video filming and photographing by air for public and private use. Specifically, I will use the UAS, which is equipped with cameras and sensors, in order to engage in the following commercial activities in various locations in the United States : v ideo filming by air and photographing for public and private purposes, including: television, cinematography, advertising or promotions. Filming and Photography will only be conducted with permission and under contract with registered owners or with any local government authority and only when safe to do so.

**BACKGROUND/E QUIPMENT**  Rafterman Photography seeks an e xem ption to operate the DJI Phantom Vision 2+ system for com pensation within airspace regulated by the FAA . The DJI Phantom Vision 2 + is a vertical takeoff and landing (VTOL) Unmanned Aircraft with a Ground Control Station (GCS) that uses an electron ic tablet or smart phone system
. The DJI Phantom 2 + weigh s approximately two ( 2 ) pounds eleven ( 11 ) ounces and is about sixteen ( 16 ) long and sixteen ( 16 ) wide. It is eight ( 8 ) inches tall and has a maxim um speed of approximately twenty - nine ( 29 ) knots. The DJI Phantom Vision 2+ is a lightweight battery operated 4
- mo tor rotorcraft in the form of a quadcopter with the following equipment: an on
- board flight com puter with GPS navigation and location ability that receives signals for flight controls from a groun d
- based transmitter/controller; an integrated on
- board camera capable of capturing imagery in the form of full color, high definition still photos and video; an on
- board telemetry system that delivers flight data from the on
- board flight computer to the on
- board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site; and a 600mW, 5.8GHz on
- board radio transmitter that transmits live video from the on
- board camera plus all th e flight data from the telemetry system described above. The ground station for this UAS includes a pilot in operational control of the flight from beginning to end; a 100mW, 2.4GHz radio transmitter/controller operated by the pilot to control the UAS whi le in flight; a radio receiver receiving live video and flight data from the on
- board camera and projects it onto a screen for the pilot to view during flight; and an observer to provide a second pair of eyes to visually track the UAS while in flight.The DJI Phantom Vision 2+ UAS is capab le of controlled flight and t hese devices are offered for general sale around the world and have often been used as Model Aircraft in the USA. Furthermore , I, Dane Sponberg, have flown this UAS recreationally since

___ and have practiced safety protocols and controls to avoid and prevent public hazard and manned aircraft disasters
. Lastly, my use of the UAS will act to further safety regulations , as I record flight data during my operations , which can then be shared with the FAA
. (Do you do this? If not, just delete this sentence.)

**RELEVANT STATUTORY AUTHORITY** Petitioner, Rafterman Photography , hereby petitions the Administrator to commercially operate the DJI Phantom 2 + in the National Airspace System (NAS), and for a n exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)( 2 ) , and 91.417(a) and (b), pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act o f 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." 1 Pursuant to Section 333 of the Ref

orm Act, the FAA Administrator is to permit unmanned aircraft system s to operate in the NAS where it is safe to do so based on the following considerations: the UAS’s size, weight, spe ed and operational capability; proximity to airp orts and populated areas; and operation of the UAS within the visual line of sight of the operator. 2 Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption does not create a hazard to users in the NAS, the public, or to national security
. 3 If it is determined that the unmanned aircraft system may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft system s in the national airspace system. 4 A petitioner requesting an exemption mu st explain the reasons why the exemption would benefit the public as a wh ole, and would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). 5

1 Federal Aviation Administration Modernization and Reform Act of 2012 § 332(a)(1) 2 Id. at § 332(b)(1) 3 Id
. 4 Id. at (b)(c) 5 14 C.F.R. §11.81The proposed operations in this Petition for Exemption qualify for expedited

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied.
**a. Approval is Warranted Based on the UAS Size, Wight, Speed, and**  **Operational Capability** The UAS has a maximum take
- off weight of less than 5 pounds, flight speed is less than 15 miles per hour, and will not be flown at an altitude above 300 feet AGL. All f lights will be flown so that they can be safely terminated with a reserve battery power more than 20
-percent of the battery’s capacity. The UAS does not contain any flammable fuel and has a failsafe mode, prop guards, and GPS system. In consideration of the speed, weight, size, and limited operating area associated with the DJI Phantom Vision 2+ unmanned aircraft and its operation, Rafterman Photography meets the conditions of FMRA Section 333 and therefore, will not require an airwort

hiness certificate in accordance with 14 C.F.R. 21 (h)
. Furthermore, Rafterman Photography requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft s with an airworthiness certificate. The requested relief is proper since an equal level of safety will be guaranteed by Rafterman Photography. Rafterman Photography will use experienced technicians to maintain or alter the UAS, as prescribed in the operating manual, and will retain all maintenance records. **b. Approval is Warranted Based on Public Interest**  The public interest will be served by granting Raftermen Photography a Petition for Exem ption. Congress’ established national policy favors early integration of UASs into the NAS in controlled, safe working environments such as those proposed in this Petition. In addition, the public also has an interest in reducing the hazards associated with alternate methods of conducting similar op erations. The use of the DJI Phantom 2+ will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. This UAS is battery powered is a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Allowing the use of this UAS in the NAS will reduce noise and air pollution, as well as increase safety in the air and on the ground as it has less potential for damage to life and property compared to a manned aircraft . The DJI Phantom 2+ does not require an airport to takeoff or landso operation of this UAS will decrease congestion in and around airports.

Moreover, by using battery power , the DJI Phantom 2 + produce s no air pollution and eliminates noise pollution
. Furthermore, there is also an economical benefit to using UASs as opposed to manned aircrafts to conduct similar aerial operations. Operation of the DJI Phantom 2+ will allow companies, like Raftermen Photography to remain com petitive and contribute to growt h of the United States economy. **S UMMARY**  **FAA M AY**  **P UBLISH IN THE FEDERAL REGISTER**  Raftermen Photography seeks exemption from the requirements of 14 C.F.R. Sections 91.7(a), 91.151(c), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), so as to comme rcially operate an Unmanned Aircraft System for the purpose of conduction aerial photography and videography over certain areas of the United States. a. 14 C.F.R. 91.7(a): I, Dane Sponberg, will ensure the UAS is airworthy prior to each operation based on com pliance with the Phantom Vision 2+ operating manual. Pursuant to 14 C.F.R. §19.121 , Petitioner requests relief considering the limited altitude of the UAS and proposed operations. b. 14 C.F.R. 91.151(c): I, Dane Sponberg, will ensure that each flight will not commence unless there is enough battery power to fly to the first point of intended landing and land the UAS with 30
- percent battery remaining. Furthermore, ea ch flight will last no longer than twenty (20) minutes. c. 14 C.F.R. 91.405(a); 91.407 (a)( 1); 91.409(a)(2); 91.417(a) and (b): These provisions apply only to aircrafts that require an airworthiness certificate. Therefore, these regulations do not apply to my DJI Phantom Vision 2+ UAS. As a precaution, however, I will inspect my UAS before and a fter each operation according to the owner’s manual. **CONCLUSION** As set forth in this petition, Raftermen Photography seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the DJI Phantom 2+ UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be ful filling the Congressional mandate of the FAA Modernization and Reform Act of 2012, whilealso benefitting the interests of the public, by allowing Raftermen Photography to

safely, efficiently, and economically operate a UAS commercially within the NAS. Wh erefore, Dane Sponberg, on behalf of Raftermen Photography , respectfully requests that this petition for exemption from 14 C.F.R. Sections 91.7(a), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) be granted and therefore allow Rafterman Photography to operate a DJI Phantom Vision 2+ commercially for aerial videography and photography. Respectfully submitted on this

__ day of

____ 2015. Dane Sponberg Address Phone Num

ber E ma ilAppendix A

**DJI PHANTOM VISION**  **2 + TECHNICAL SPECIFICATIONS**  1.1 DJI Phantom Vision 2 + 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m ; Horizo ntal: 2.5m 1.1.1.4 Max Yaw Angular Velocity
- 200 0 /s 1.1.1.5 Max Tilt Angel
- 35 0 1.1.1.6 Max Ascent Speed

– 6m /s 1.1.1.7 Max Descent Speed

– 2m /s 1.1.1.8 Max Flight Speed

– 15m /s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dy namic: 900m

A 1.1.2.2 Control Accuracy
- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:
- 90 0

- 0 0 33 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s 1.1.3 Camera 1.1.3.1 Operating Temperature Range
- 32 0 F
- 104 0 F (0 0 C
- 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View
- 110 0 /85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1. 4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)
- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120m A@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 241 2
- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500
- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W