June 2, 2015

Federal Aviation Administration:

On behalf of Seacoast Aerial View I would like to formally submit for an 

exemption from part 21, subpart H; and Sections 45.23(b),

91.7(a), 91.9(b)(2), 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). This proposed exemption would allow our operation

of unmanned aircraft systems (UAS) for the purpose of aerial videography 

and to augment real estate listing videos in various areas of Northern 

Massachusetts, New Hampshire, and Maine.

As found in Exemption No. 11138 (Trudeau), the FAA recently approved

similar use of a PHANTOM 2 UAS.

We will operate a UAS, the DJI PHANTOM 2 Vision +, which is comprised of

an unmanned aircraft (UA or PHANTOM), including a camera installed by 

the manufacturer and a transportable ground station.

The PHANTOM 2 Vision + is 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 has a maximum airspeed of 30 knots.

We will operate the UA over various areas, primarily around Seabrook, NH,

to enhance academic community/ business awareness and augment real

estate listing videos.

UAS Operating Parameters

We will abide by the following additional operating conditions under this

exemption, which ensures a level of safety at least equal to existing rules:

• Operate UAS below 300 feet and within a radius distance of 1000 feet from

the controller to aid in direct line of sight visual observation;

• Obtain permission from the owner/controller of any vessels, 

vehicles and structures when operations may be conducted 

closer than 500 feet to any such vessels, vehicles or structures;

we will conduct a safety assessment of the risk of operating

closer to those objects and determine that it does not present

an undue hazard;

• Operate the UAS for 5-20 minutes per flight and land the UAS prior to
the manufacturer’srecommendedminimum level of battery power;

• Operate UAS during daylight hours only within visual line of 

sight (VLOS);

• Use the UAS’ global positioning system (GPS) flight safety 

feature whereby it hovers and then slowly lands if 

communicationwith the remote control pilot is lost;

• Conduct all operations under the 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 safety protocols;

• Contact respective airportsif operations will be within 5 

miles to advise them of his estimated flight time, flight 

duration, elevation of flight and other pertinent information;

• Always obtain all necessary permissions prior to operation;

•Have proceduresin place to abort flights in the event of 

safety breaches or potential danger;

• Only operate in safe environmentsthat are strictly

controlled, are away from power lines, elevated lights, airports and

densely populated areas (defined by areas depicted in “yellow” on VFR

charts and through obtaining information regarding congested areas from

the local Flight Standards District Office (FSDO);

• Conduct extensive preflight inspections and protocols, during which

safety carries primary importance (reference PHANTOM Flying Flow

Chart and User Manual).

UAS Pilot in Command (PIC)

Regarding UAS operational training, we have flown numerous

practice flights in remote areas as hobbyists simulating flightsfor

future commercial use to gain familiarization with the characteristics

of the UAS’ performance under different temperature and weather 

conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner
consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft

pilot including at least 10 hours logged as a UAS pilot with a multi-rotor

UAS. The PIC will also have accumulated and logged a minimum of 5 hours

as a UAS pilot operating the same make and model of UAS to be used for

operations. In addition to the hour requirements,the PIC will accomplish 3

takeoffs and landingsin the preceding 90 days (for currency purposes) 

prior to any flight.

Specific Exemptions Requested

Given the size, weight,speed, and limited operating area associated with

the UA, we feel an exemption from 14 CFR part 21, Subpart H

(Airworthiness Certificates) and §

91.203(a) and (b) (Certificationsrequired),subject to certain conditions and

limitations, is warranted and meets the requirementsfor an equivalent

level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section

333).

We request an exemption from § 45.23 Marking of the aircraft because the

UA will not have a cabin, cockpit or pilot station on which to mark certain

words or phrases. Further, the two-inch lettering is difficult to place on such

a small aircraft with dimensionssmaller than the minimal lettering 

requirement. Regardless of this, we can mark the UAS in the largest possible

lettering by placing the word “Experimental” on its fuselage as required by §

45.29(f)so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibitsthe operation of

an aircraft without an airworthiness certificate, since there is currently no

certificate applicable to our operation, this regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1),

91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only

apply to aircraft with an airworthiness certificate. However, as a safety

precaution we will perform a preflight inspection of the UAS before each

flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft

flight manual in the aircraft, howeversince there are no pilots or

passengers on board the aircraft and given its size, this regulation is

inapplicable. We believe an equivalent level of safety will be achieved by

maintaining a safety/flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudesfor
the operation of civil aircraft, but it allows helicoptersto be operated at

lower altitudesin certain conditions. We will not operate our UAS above the

altitude of 300 feet above ground level (AGL) and will also only operate in

safe areas away from the public and traffic, thus “providing a level of safety

at least equivalent to or below those in relation to mini- mum safe

altitudes.” Given the size, weight, maneuverability, and speed of the UAS, an

equivalent or higher level of safety will be achieved.

We request an exemption from § 91.121 Altimetersettings as it is

inapplicable since the UAS utilizes electronic GPS with a barometric

sensor.

We request an exemption from § 91.151(a) Fuel requirementsfor flight in

VFR conditions. The UAV is 100% electric and two low battery alerts are

issued - per the operating documents, the UAV will be landed at the first

alert. Also, our flights will last only 5-10 minutes each, and the UAS has an

automated function which results in immediate landing when a low

battery is detected. The PIC will not begin a flight unless (considering wind

and forecast weather conditions)there is enough power to fly to the first 

point of intended landing and, assuming normal cruising speed, land the

UA with 30% battery power remaining.

Public Interest

Aerial videography for geographical awareness and for real estate

marketing has been around for a long time through manned fixed wing

aircraft and helicopters, but for small business owners, its expense has been

cost-prohibitive. By granting this exemption we would be able to provide

this service at a much lower cost. Further, our small UAS will pose no threat

to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. Additionally,the operation of our UAS will

minimize eco- logical damage and promote economic growth by providing 

information to companieslooking to relocate or build in the metro areas we

service.

Summary

We will comply with all of the following conditions and limitations

should this grant of exemption be provided:

1) Operations will be limited to the following aircraft described in the

operating documents which is a quad-rotor aircraft weighing less than 3

pounds: PHANTOM 2 Vision + Un- manned Aircraft System.
2) The UA will not be flown at an indicated airspeed exceeding

30 knots.

3) The UA will be operated at an altitude of no more than

300 feet above ground level (AGL), as indicated by the procedures

specified in the operating documents. All altitudesreported to ATC

must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot In

Command (PIC) at all times.

5) All operations will utilize a visual observer (VO). The UA will be operated

within the visual line of sight (VLOS) of the VO at all times. The VO and PIC

will be able to communicate verbally at all times. The PIC will be designated

before the flight and will not transfer his or her designation for the duration

of the flight. The PIC will ensure that the VO can perform the functions

prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and

made available to the Administrator upon request. Any revisionsto the

operating documents will be presented to the Administrator upon

request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a

condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the UAS will not be operated until the necessary

maintenance has been performed and the UAS is found to be in a condition

for safe flight. The Ground Control Station will be included in the preflight

inspection. All maintenance and alterations will be properly documented in

the aircraft records.

8) Any UAS maintenance or alterationsthat affect the UAS operation or

flight characteristics, e.g. replacement of a flight critical component, will

undergo a functional test flight. The PIC who conductsthe functional test

flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account

for all discrepancies, i.e. inoperable components, items, or equipment, not

already covered in the relevantsections of the operating documents.

10) We will follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit

requirements.
11) We will carry out maintenance, inspections, and record keeping

requirements, in accordance with the operating documents.

Maintenance, inspection, and alterations will be noted in the aircraft

records, including total flight hours, description of work accomplished,

and the signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between

inspections.

14) UAS operations will be conducted by a PIC possessing at least a private

pilot certificate and at least a current third- class medical certificate. The

PIC will also meet the flight review requirementsspecified in 14 CFR 61.56

in an aircraft in which the PIC is rated on his or her pilot certificate.

15) Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate listing videos (or

similar operations),the PIC will have accumulated and logged, in a manner

consistent with 14 CFR

61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot

including at least 10 hours logged as a UAS pilot with a multi-rotor UAS.

16) Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate listing videos (or

similar operations),the PIC will have accumulated and logged, in a manner

consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot

operating the make and model of the UAS to be used in operations. The

PIC will accomplish 3 takeoffs and landingsin the preceding 90 days (for

currency purposes).

17) The PIC will not operate the UAS for the purpose of aerial

videography/cinematography and augmenting real estate listing videos

(or similar operations), unless the PIC has demonstrated and logged in

a manner consistent with 14 CFR 61.51(b), the ability to safely operate

the UAS in a manner consistent with the operating documents,

including evasive and emergencymaneuvers and maintaining 

appropriate distancesfrom people, vessels, vehicles and structures.

18) UAS operations will not be conducted during night, as defined in 14

CFR 1.1. All operations will be conducted under visual meteorological
conditions(VMC).

19) The UA will not operate within 5 nautical miles of an airport

reference point as denoted on a current FAA- published aeronautical

chart.

20) The UA will not be operated less than 500 feet below or less than

2,000 feet horizontally from a cloud or when visibility is less than 3 statute

miles from the PIC.

21) If a UA loses communications or loses its GPS signal, it will return to a

predetermined location within the planned operating area and land or be

recovered in accordance with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or

emergenciesin accordance with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 30% battery

power remaining.

24) We will obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations, and

also request a Notice to Airman (NOTAM) not more than 72 hours in

advance, but not less than 48 hours prior to the operation.

25) Before conducting operations, the radio frequency spectrum used

for operation and control of the UA will comply with the Federal

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

26) The documentsrequired under 14 CFR 91.9 and 91.203 will be available

to the PIC at the Ground Control Station of the UAS any time the UAS is

operating. These documents will be made available to the Administrator or

any law enforcement official upon request.

27) The UA will remain clear and yield the right of way to all manned

aviation operations and activities at all times.

28) The UAS will not be operated by the PIC from any moving device

or vehicle.

29) The UA will not be operated over congested or densely populated
areas.

30) Flight operations will be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect 

nonparticipating personsfrom the UA and/or debris in the event of an

accident. We will ensure that nonparticipating personsremain under such

protection. If a situation arises where nonparticipating personsleave such

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where

the owner/controller of such vessels, vehicles, or structures has

granted permission and the PIC has made a safety assessment of

the risk of operating closer to those objects and deter- mined that it

does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

31) All operations will be conducted over private or controlled-access

property with permission from the land owner/controller or authorized

representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

32) Any incident, accident, or flight operation that transgressesthe lateral

or vertical boundaries of the operational area as defined by the applicable

COA will be reported tothe FAA's UAS Integration Office (AFS-80) within

24 hours. Accidents will be reported to the National Transportation Safety

Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

Respectfully, 

William D. Angell

Manager

Seacoast Aerial View

Seabrook, New Hampshire 03874