July 29, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

**RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act and**  **Part 11 of the Federal Aviation**  **Regulations from: 14 CFR 21 subpart H** 
14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (1) and (2) 14 CFR 91.417(a) and (b)
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11 , Scott Donovan, Private Pilot Cert i ficate #3443493 , operator of Unmanned Aircraft Syste ms (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations are conducted within an d under the conditions outlined herein or as may be established by the FAA as required by Section 333.
Commercial operation of an UAS, as described herein, wh ich are equipped with camera(s) and sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and newsgathering. 3. Aerial i nspection/photography/data collection of residential/commercial structures under contract with the owners or local government authority. 4. Aerial inspection/photography/data collection of residential/commercial utility infrastructure including but not limite d to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has req uested it by contract or donation.As described fully below, the requested exemption would per mit the operation of designated UAS as set

forth in this document under controlled conditi ons in the NAS that would be a) l imited b) controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness of UA operations and enhance safety to aid in fulfilling the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operat ion of such aircraft systems in the national airspace system.”
I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a quad

- copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA ha s a maximum airspeed of 16 m/s. I also plan to operate a UAS, the DJI Vision which is comprised of an u n manned aircraft and a transportable ground station. The Vision is referred to as a quad

-copter with a maximum gross weight of about 6.5 pounds. It is equipped with four rotors tha t are driven by electric motors powered by batteries. The UA ha s a maximum airspeed of 22 m/s.
Also, given the small size of the UAS’s involved and the restricte d controlled environment within which they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress env isioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the U ASs and the controlled areas in which the relevant UASs will operate, approval of the applicatio n presents no national securi ty issue. Given the following, the grant of the requested exemptions is clearly in the public interest: Scott Donovan proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations l isted herein. T hese limitations provide for an exceptional level of safety to operations. These limitations and conditions to which Scott Donovan agrees to be bound when conducting commercial operation s under an FAA issued exemption including:

1. Operate onl y in VFR conditions 2. 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure 3. The UAS will weigh less than 55 lbs. 4. Flights will be operated within line of sight of operator. 5. Maximum total flight time for each operational flight will be 30 minutes. 6. Flights will be terminated at 15% battery power reserve. 7. Flights will be operated at an altitude of no more than 2 00 feet AGL 8. UAS operator will be trained and certified in the proper safety and operations of the UAS. 9. The UAS will only o perate within a controlled area as defined in the Procedures. 10. The operator will post advisor notice around the controlled area. 11. The operator will have been trained in operation of UAS generally and received up

to

- date information on the particular UAS to b e operated as required. 12. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location within the Security Perimeter and land.13. The UAS will have the capability to abort a flight in case of unpre dicted obstacles or emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are prepared to modify or amend any part of this request to sat isfy the need for an equivalent level of safety. We look forwa rd to working with your office. P lease contact us at any time if additional information or clarifications are needed.
Sincerely,

Scott Donovan , Digitally 730 East Kingston Avenue Charlotte, NC (704)344

-0733

FAA Certificate #3443493 Private Pilot

NC Drivers License #6236252 Expires 03/17/2023