January 27, 2016 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, D.C. 20590



### Re: Petitionfor Exemption underSection 333 of the FM Modernization andReform Actand othercertain FARs to operate UnmannedAircraftSystems (UAS)

Dear Sir or Madam; Pursuantto Section 333 ofthe FAA Modernization and Reform Act ("FMRA") and 14 C.F.R. Part 11, Leading Edge Imagery, Inc. herebypetitions the Federal Aviation Administration for exemption from the following regulations in orderto safely and legally operate UAS's for aerial data collection, aerial videography and photography:

• 14 C.F.R. Part 21 • 14 C.F.R 61.23 (a) and (c) • 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. 91.119(c) • 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. 91.405 (a) • 14 C.F.R. 91.407 (a)(1) • 14 C.F.R. 91.409 (a)(1) &(2) • 14 C.F.R. 91.417 (a) & (b)I. Proposed UAS's Leading Edge Imagery, Inc. requests an exemption to operate the DJI Inspire 1 and DJI Phantom 3 models. These UAS's are well below 55 pounds, including payload and will be operated below 400 feet. They are electricallypowered bylithium ion batteries, carry no combustible fuel orcrew and will always be transported via proper storage to and from all flight zones. As evidenced byrecentExemption numbers, the FAA recently approved similar use ofthe DJI Phantom 3 and DJI Inspire 1. These particular UAS's have been proven reliable and safe flying machines managed bygyroscopically-stabilized flight, ground detection, GPS aided navigation, a builtin compass, blinking LED navigation lights, a manual and automatic failsafe "Return to Home" feature, and propeller guards to protectthe UAS and environment. DJI also has built in a "No Fly Zone" feature for major cities and airspace such as active airports. As a resultthe UAS will not startup ifin these areas and will stop before entering such airspace. These models are widely utilized for similar operations and when flown responsibly and with proper aviation knowledge, they ensure safe operations and limited, easy maintenance.

II. Proposed Operations andApplications The granting ofexemption for commercial operations would allow the petitioner to operatethe proposed UAS's for aerial data collection, videography and photography. As a new company, owned and operated by an ATP MEII, SEll pilot we would like to offer our services to the public and businesses thatrequire aerial photographs and forvideo including butnotlimited to: real-estates, production companies, ground based photographers, not for profit organizations, media stations, local municipalities. In addition itis our goal to offer land surveying and mapping, forest monitoring and management, wetland monitoring and management, topography charting, environmental assessments, visual monitoring ofequipmentand developing areas, thermal mapping and, aid in search and rescue operations. The petitionerbelieves that the use ofUAS's is more economical, safer and environmentallyfriendly for the proposed operations. As a companythat is operated by a licensed pilot, itis our intentto have licensed pilots at the control of the UAS's for commercial use while utilizing a visual observer (V.O.) for all flights. Having an extensive aviation background will aid in good decision-making and utilization ofbasic aviation practices such as but notlimited to: • Preflight checklists • Post flight checklists• Preflight planning • Aircraft inspection and maintenance • VFR weather minimums observances • TFR and No Fly Zone awareness • Airspace awareness • Right ofwayrules • Pilot IMSAFE checklists • Flying "neighborly".

III. Requestfor Exemption, Section 333 ofthe FAA Reform Act: Specific section(s) of 14 CFR, which the petitioner seeks reliefas well as any additional regulations thatmay apply to operations ofUAS's and the FAA, seems fit to grant. 14C.F.R Part 21: Airworthiness Certificates Due to the size and limited operating area associated with the UAS's to be utilized, an exemption from Part 21 meets the requirements ofan equivalentlevel ofsafety under Part 11 and Section 333 ofthe Reform Act. It has been determined by other exemption numbers that similar UAS's do notrequire an airworthiness certificate. 14C.F.R. 61.23 (a) and (c): Medical Certificates Due to the nature ofcommercial operations ofUAS's itis viewed to be acceptable to hold a pilot certificate and second orthird class medical certificate. Considering the operation will notbe carrying passengers, keeping a currentlicense and third class medical certificate should complete the requirement. 14 C.F.R. 61.113 (a) and (b): Private Pilot Privileges The petitionerfeels it's pertinentto hold a pilots license to operate UAS's for compensation orhire. However the commercial operations for this companywould notrequire the need ofa commercial pilot certificate due to the scope offlight operations. Holding a currentpilot certificate and medical would be sufficient for P.I.C. ofour UAS's. 14 C.F.R. 91.7 (a): Civil AircraftAirworthiness: The UAS's for proposed use currentlyto notrequire orhave an airworthiness certificate. Itwill be up to the P.I.C. to determine its airworthiness before each flight by referring to the operation/company manual and performing a visual inspection. The proposed UAS's also have a ('Safe to Fly" message when fully operational. 14 C.F.R. 91.9 (b)(2): Civil Aircraft Flight Manual. Marking. and Placards Considering the UAS's proposed and the obvious absence ofspace for a flight manual orplacards this regulation is inapplicable. The petitionerwill have an accessible flight manual for each operation atthe pointwhere the P.I.C is located.14 C.F.R. 91.119(c): Minimum Safe Altitudes The proposed UAS's will notbe flown over 400 feet AGL. Itis the petitioner's intent to limit proximityto people and congested areas. In all cases local authorities and propertyowners will be notified ofthe flight plan and associated altitudes. Using a dedicated V.O. and keeping the UAS's in line ofsight will lessen any possible interference or safety issues. 14 C.F.R. 91.121: Altimeter Settings The proposed UAS's utilize thelatest GPS/GLONASS technologies as well as a barometric sensor with live data output. The petitionerwill be able to have immediate altitude data on the tablet device connected to the transmitter. 14 C.F.R. 91.151(a): Fuel Requirements for fligh,t in VFR Conditions The proposed UAS's are battery operated and have a batterylife ofless than 23 minutes. While thepetitioner cannotcomplywith the regulation, the UAS's have a countdown feature clearly showing remainingflight time/batterylife. They also are equipped with a "Return to Home" and landing mode thatwill activate when the aircraft senses thatithas only enoughbatterylife to make itto the Home point. The P.I.C. will be conscious ofsurroundings and batterylife in orderto execute a safe and unobstructed landing before loss ofpower. 14 C.F.R. 91.203 (a) & (b): Civil Aircraft Certification Required There are currentlyno airworthiness certificates for the proposed UAS's. The P.I.C. will carryany pertinentdocumentation with her /him to be contained ata home point where the pilot is based and flying the aircraft. 14 C.F.R. 91.405 (a): Maintenance Required The petitionerwill carry outpre and postflight inspections on all UAS's. Each UAS's manufacturer recommendations and operating documents will be reviewed and taken into account. Any actual maintenance orinspections will be documented and kept in a separate maintenance log. 14 C.F.R. 91.407 (a)(1): Operation after Maintenance Any maintenance or manufacturer replacement parts installed by the P.I.C. will be notated in the maintenance log. Ifthe UAS is sentbackto the manufacturer for maintenance, upon return, the invoice and date of"return to service" will be notated in the maintenance log by the P.I.C. 14 C.F.R. 91.409 (a)(1) &(2): Inspections There is currently no guidance for UAS's annual inspection. The petitioner will accomplish an annual check ofcomponents and parts ofeach UAS and the P.I.C. will make a log entry. And firmware or service updates from the manufacturerwill be also complied with and entered into the maintenance log by the P.I.C.14 C.F.R. 91.417 (a) & (b): Maintenance Records The petitionerwill keep a record ofall repairs and modifications completed bythe operator or manufacturer. Date, time, maintenance performed and name will all be recorded.



### IV. Applicant Information Wendy E. Reynolds ChiefPilot/Owner Leading Edge Imagery, Inc. 612 North Sea Mecox Rd. Southampton, NY 11968 Mailing Address: Leading Edge Imagery, Inc. Attn: Wendy E. Reynolds P.O. Box 343 Watermill, NY 11976 Wendy@LeadingEdgeUAV.com V.Summary Leading Edge Imagery, Inc. is seeking exemption from the aforementioned F ARs. With the exemptions ofthe mentioned rules, Leading Edge Imagery, Inc. will be able to operate safely and efficiently in accordance with pertinent FARs and local restrictions. UAS's offer an affordable and environmentallyfriendly option to many businesses and private individuals looking for aerial data. Being thatthe operation is operated by an ATP licensed pilot, with commercial operation experience, the petitioner hopes for timely consideration and an expedientresponse. Please do nothesitate to contact us with any further questions aboutourproposed operations. Thankyou for your consideration. Sincerely,

# \0r_~~·**Wendy~. ~y~olds**  Leading Edge Imagery, Inc. Wendy@LeadingEdgeUAV.com 631.334.3510 mobile