Jesse Lasky

155 Exchange Street Albany, New York 12205 (Phone) 518

- 598

- 2849 jesseclasky@gmail.com

May 1, 2015

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

RE: Request for Exemption Per PL 112

- 95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1 ), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

T he following documents have been included in or der to provide supplement al information for this petition ’s request for exemption:

1. Inspire_1_Safety_Guidelines 2. Inspire_1_User_Manual_v1.2 3. Inspire_1_Maintenance_ManualV1.0

Dear Sir or Madam,

This letter will serve as a request for an exemption of the above sections of title 14 CFR for myself , Jesse Lasky, henceforth referred to as the petitioner, for the purpose of conducting commercial “ aerial photography, videography , and survey operations ” using a small Unmanned Aircraft S ystem (sUAS) in FAA controlled airspace. As described herein , Jesse Lasky, is an e xperienced user of multicopter sUAS for hobby operations , flying multicopters of varying sizes under 55 pounds using both V isual L ine O f S ight (VLOS) and on board camera controls. The following petition provides all necessary information to justify an exemption from the above listed Federal Aviation Regulations. 

## The Unmanned Aircraft System

The petitioner will be flying a DJI Inspire 1 that is equipped with 4 propellers, onboard camera, and onboard flight control systems that utilize both GPS and ground movement to stabilize the aircraft. The Inspire 1 is o p erated via remote control in the 2.4ghz spectrum.

The sUAS has built in fun c tionality that can limit the height it flies above the ground, limit the distance between the aircraft and PIC, and restrict the sUAS fro m flying in class B, C, and D airspace. The aircraft also comes preinstalled with the ability to automatically return to the PIC and land if any of the previous restrictions are violated, or if the connection to the wireless controller is lost.

The sUAS we ighs 2935 grams (just under 6 pounds) while carrying all necessary batteri e s and cameras. It also has a max speed of 22 meters per second (just under 43 knots) that can be limited prior to takeoff.The aircraft is powered via a lithium polymer battery whic h supplies electricity to the 4 brushless onboard

motors.

( For more specifications, please refer to the attached owner’s manual [ Inspire_1_User_Manual_v1.2 ]

. Pre

- flight and post

- flight inspections will be consistent with the attached Safety Gu idelines and Maintenance Manual [ Inspire_1_Safety_Guidelines ] [ Inspire_1_Maintenance_ManualV1.0 ] )



## The Unma nned Aircraft PIC

Jesse Lasky, the PIC of the DJI Inspire 1 is an expe rienced sUAS pilot, especially piloting multi

- rotor aircraft. The petitioner has been a hobbyist sUAS pilot for over 5 years, and has piloted this particular aircraft on numerous occasio ns without incident. To improve safety and comply with the FAA’s requests, a trained observer will be present at all times during the flight. The petitioner is also experienced with maintain ing a controlled area of operations, ensuring the safety of all nearby persons and prope rty. 

## sUAS Operation Overview

The sUAS will be operated to provide aerial photography
, videography , and survey services to the public sector, particularly for the purposes of real estate, weddings, events, and property surveys.

Prior to the operation, flight restrictions will be programmed into to sUAS to prevent it from flying 400 feet above ground level or 1500 away from the PIC. Before takeoff, t he operator and observer will review the pre

- flight checklist (found in Inspire_1_Safety_Guidelines ) and survey the area to determine if weather/cloud conditions are suitable for flight and what the emergency landing sites would be. A ll nearby persons in the operations area will be made aware of the flight in progress. Flights will not take place over densely populated areas or private property without the owner ‘s permission. Once the operation is complete, the sUAS will be inspected to determine if any maintenance will be needed before the next operation.

Compared to traditiona l flights using manned aircraft , flights using sUAS are much less dangerous and therefor would not adversely affect safety :

 The nature of these flights will restrict the use of the sUAS to a small area where all nearby persons can be aware of the ongoing flight

.

 The sUAS carries no explosive materials or combustible liquid fuel.

 The light weight of the sUAS would cause minimal damage in the event of an airborne failure, especially when compared to traditional manned aircraft with airworthiness certificates.

 The small size of the sUAS would allow for all operations to be conducte d within a clearly defined area, including takeoffs and landings.

All flights by the PIC will begin and remain outside of a 5 mile radius of any airport. The sUAS has a mandatory, built

- in fun c tionality to restrict the aircraft from flying within this radius and will automatically land if it inadvertently violates this restriction. Any and all precautions will be taken by the PIC and the accompanying Observer to prevent midair collisions with objects and other aircraft
, even outside the 5km radius of airports.All planned operations utilizing the sUAS will be completed safely. With the combi nation of the preflight

safety risk assessments previously discusse d and the inherently reduced risk of flying a sUAS compared to a traditional manned aircraft, the PIC will be able to provide a level of safety greater than the traditional method of performing aerial ba sed photography, videography
, and survey operations.



## Benefit to Public Interest

The services provided by the petitioner would be a great benefit to the public as a whole. Granting this exemption would reduce the need for traditional forms of aerial photography, videography, and surveys which
, as previously discussed
, are much more dangerous than operations perf ormed by sUAS. The cost of sUAS operations is also significantly lower than traditional aerial photography flights, making these services available to smaller businesses or individuals that otherwise may not be able to afford them. This in turn allows businesses to better serve their clients, increasing the public benefit as a whole

. 

## Conclusion

All commercial sUAS flights by the petitioner shall satisfy the criteria provided in Section 333 of the Reform A ct of 2012, including: size, weight, speed, flight within VLOS, distance f r om PIC, distance from airports, o peration capabilities, maintain ing safety , and the ben efit to the public. In accordance with the FAA ’s announcement on March 23 rd , 2015, the petitioner will apply for a Certificate of Waiver or Authorization for all flights over 200 feet above the ground. These qualifications more than justify granting the petitioner, Jesse Lasky, with an exemption to the stated sections of title 14 CFR

. The requests of this petition are similar to those of Marcus D. Melhus, Ralph J. Apel, and Saratoga Aerial and Video, all of whom have received Section 333 exemptions for use of comparable aircraft for similar operations.

Thank you for your time and consideration.

Sincerely,

Jesse C. Lasky Petitioner