**Northport Solutions LLC** 1588 Northport Drive Cicero, IN 46034 317

- 984

- 7752

April 27, 2015

To whom it may concern at the FAA: I currently have owned a DJI Phantom 1 for over 2 years and have approximately 200+ hours of accident free flight time as a hobbyist. Additionally I have over 50 years of experience with radio controlled model aircraft. I am a recently retired middle man ager from the Electronics and Safety division of Delphi Automotive. In one of many assignments, I was the leader of the team that brought into high volume production the microprocessor that controlled the airbags used in automobiles . I fully understand t he seriousness of safety. I have been an avid photographer for many years and being able to fly a UAS with a camera has been a natural extension of my photography and videography. All of my work has been in visual line of site. I have no desire nor do I need to ever operate the UAS in any manner than within visual line of site. I have recently upgraded to a larger DJI Inspire that will allow longer flight times and carry a better quality camera for still photos and videos. My plans are to pursue a comme rcial business venture to take still photos of private and commercial real estate along with producing videos of various items and events. In all cases I will receive permission from the land owners prior to any performed work and will always keep safety as the number one consideration when flying the UAS. Michael Berry will be the only Pilot in Command using the UAS.

I will begin the petition for exemption below: To the Federal Aviation Authority (FAA), I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). I support my request with the following information: I plan to operate a UAS, the DJI Inspire 1 , which is comprised of an unmanned aircraft and a transportable ground station. The Inspire 1 is referred to as a quad

- copter with a maximum gross weight of about 3 kilograms . It is equipped with four rotors that are driven by electric motors powered by a**Northport Solutions LLC** 1588 Northport Drive Cicero, IN 46034 317

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- 7752 battery. The UAS has a maximum airspeed of 22 m/s

. The quad has a built in high definition camera. I plan to operate the U AS over various areas in central Indiana to en h ance community awareness and augment real estate listing videos and photographs. I make the following representations of o perational enhancements which I propose to abide by to ensure this exemption will provide a level of safety at least equal to existing rules: • I will only operate in reasonably safe environments that are strictly controlled , and are away from power lines, elevated lights, airports a nd actively populated areas. • I will conduct extensive preflight inspections and protocols, during which safety carries primary importance. I state that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 9 1.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333). I request an exemption from § 45.23 Marking of the aircraft because t his UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, I state that two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, I state that I will mark his UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that he or anyone assisting him as a spotter wil l see the markings. I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However, I state that as a safety precaution I will perform a preflight inspection of his UAS before each flight as outlined in my operating documents.

UAS Pilot in Command (PIC) I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. Further, I stat e that, while helpful, a pilot license will not ensure remote control piloting skills. I further indicate that the risks of operating a UAS are far less than the risk levels**Northport Solutions LLC** 1588 Northport Drive Cicero, IN 46034 317

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- 7752 inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command. Regarding UAS opera tional training, I state I have flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use t o gain familiarization with the characteristics of t his UAS’ performance under different temperature and weather conditions. UAS Operating Parameters I will abide by the following additional operating conditions under this exemption: • O perate my UAS belo w 300 feet and within a radius distance of 1000 feet from the controller to both aid in direct lin e of sight visual observation. • O perate the UAS for 3

- 7 minutes per flight.

• Land my UAS prior to the manufacturer’s recommended minimum level of battery po wer.

• O perate my UAS only wit hin visual line of sight (VLOS).

• U se the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is l ost.

• C onduct all operations und er my own personal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”) contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance my safety protocols. • C ontact respective airports if operations will be within 5 miles to advise them of my estimated flight time, flight duration, elevation of flight and other pe rtinent information. • A lways obt ain all necessary per missions prior to operation

.
• H ave procedures in place to abort flights in the event of safety breaches or potential danger. I state that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that since there is currently no certificate applicable to my operation, this regulation is inapplicable. I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft an d giv en its size, this regulation is inapplicable. I further indicate an equivalent leve l of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.**Northport Solutions LLC** 1588 Northport Drive Cicero, IN 46034 317

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- 7752 I state that § 91.119 prescribes safe altitudes for the operation of ci vil aircraft, but that it allows helicopters to be operated at lower altitudes in certain conditions. I state that I will not operate t his UAS above the altitude of 2 00 feet above ground level (AGL) and will also only operate in safe areas away from the pu blic and traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. I assert that given the size, weight, maneuverability, and speed of my UAS, an equivalent or higher level of safety will be ach ieved. I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS with a barometric sensor. Public Interest I state that aerial videography and photography for geographical awareness and for real estate marketing has b een around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption to myself would allow me to provide this service at a much lower cost. Further, I would like to indicate my small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. I would also like to state that the operation of my UAS will minimize ecological damage and prom ote economic growth by prov iding information to companies or individuals looking to relocate or build in the Central, Indiana region

. (end of petition) Additionally I have contacted my insurance carrier and once these exemption s are approved by the FAA to legally fly the UAS commercially I will be able to purchase damage and liability insurance for the UAS operations.

Best regards, Michael L. Berry