Submitted by:

Kevin Maw Totalorlando LLC 1420 Celebration Blvd. Suite 200 Celebration, FL 34747 kev@totalorlando.com

**Scope: To produce real estate listing photography and videos by using**  **the DJI Inspire 1 Professional Unmanned Aircraft.** UAV DJI Inspire 1 Professional: The DJI Inspire 1 is a quad

- rotor Unmanned Aircraft System (UAS) weighing less than 7 pounds. The DJI Inspire 1 that Totalorlando LLC will be responsible for also utilizes a mobile ground station. The UAS features a safety Return to Home function that in the event of a signal loss, the UAS will return to a preset position and land. The Return to Home feature can also be triggered manually. The re mote controller connects to a phone or tablet, offering additional live observational information at high quality 720p. Although safe operation of the DJI Inspire 1 will be the sole responsibility of the PIC, the advance d system does benefit from the following backup safety systems;

 Clearly visible design with directional indicators

 A low power/lost signal ‘Return To Home’ feature

 The DJI Inspire 1 system prevents navigation within restricted areas of A/B airfields

 The precision controller is aided by GPS for stability and location accuracy and allows the operator to co mb ine line of sight, live feed camera observation, and the emergency ‘return home’ system for a safe and controlled flight.**Request:**

An exemption from 91. 7(a), 91.119, 91.121, 91.151(a), 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) as was granted to Ralph J. Apel in Exemption No. 11410
**Petition:** I request an exemption from TITLE 14 OF THE CO DE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)
The Extent Of Relief that TotalOrlando LLC seeks
**1. Extent of Relief that TotalOrlando**  **LLC seeks regarding**  **Section 61.113 (a) and (b) Private Pilot Privileges and Lim**  **itations** Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command holding a current Private Pilots Certificate to operate the TotalOrlando LLC DJI Inspire 1 . The flight would be
com plimented by a Visual Observer who, along with the pilot, will
ma intain Visual Line of Sight with the DJI Inspire 1 at all times. All operations conducted will be incidental to Totalorlando LLC’s business. The DJI Inspire is not able to carry passengers.
**2. Extent of Relief that TotalOrlando LLC**  **seeks in regards to Section 91.7(a)** 

Civil Aircraft Airworthiness Relief from Section 91.7(a) is requested to allow TotalOrlando LLC to determine airworthiness of the DJI Inspire 1 . As part of this determination the following will be adhered to:
a. Prior to the DJI Inspire 1 's flight the PIC will inspect the UA toensure it is in a condition that will be conducive for a safe flight.

The ground control station will be included in the above inspection.
b. TotalOrlando LLC will follow the DJI Inspire 1 ’s aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements.

c. TotalOrlando LLC will comply with all DJI manufacturer Safety Bulletins.
**3. Exte nt of Relief that**  **TotalOrlando LLC seeks in regards to**  **Section 91.119** Minimum Safe Altitudes General relief from 91.119 is requested to allow TotalOrlando LLC to operate the DJI Inspire 1 at altitudes not to exceed 400’ AGL over private property at a dist ance at or greater than 5NM from the nearest airport as depicted on current Aeronautical Charts. TotalOrlando LLC also wishes to be granted
exem ption to operate at an altitude not greater than 50’ AGL (below tree level) between 1NM and 5NM from the nearest airport as depicted on current Aeronautical Charts.
TotalOrlando LLC will adhere to the following in order to
ma intain an acceptable level of safety associated with operations over private property: ( a) TotalOrlando LLC will display signs in the immediate vicinity of operations stating: “Aerial Photography In Progress. Use Caution.” (b) TotalOrlando LLC will not allow the DJI Inspire 1 to operate at a speed greater than 10kts. (c) TotalOrlando LLC will require the UAS operator (PIC) to be fully trained on the DJI Inspire 1 by adhering to the recommendations contained within the DJI Inspire 1 ’s operating
manual.(d) TotalOrlando LLC will have accumulated and logged, in a

manner consistent with 14 CFR 61.51, 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 m ulti

- rotor UAS. In addition th e operator will have logged a minimum of 5 hours as a UAS pilot operating the make and model UAS that Flying TotalOrlando LLC operates. (e) TotalOrlando LLC will be familiar with and able to manually institute the DJI Inspire 1 ’s Return to Home (RTH) feature. This feature aborts a flight operation and automatically returns the UAS to a predetermined GPS safe point. (f) TotalOrlando LLC will not operate over private property without first finding a suitable alternate landing spot on the property. (g) Tota lOrlando LLC will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. (h) TotalOrlando LLC will utilize a two man flight team consisting of the Pilot in Command (PIC) and a Visual Observer (VO) . This team will maintain visual line of sight with the DJI Inspire 1 at all times and remain within hearing of one another. (i) TotalOrlando LLC will not permit flight around vessels, vehicles and structures without permission from the owner.
**4. Extent of Relief that**  **TotalOrlando LLC seeks in regards to**  **Section 91.121 Altimeter Settings** Relief from 91.121 is requested because the DJI Inspire 1 utilizes electronic GPS with a barometric sensor. In order to maintain an equal level of safety that 91.121 re quires, the PIC of the TotalOrlando LLC’s UAS will abort the flight in the events that the UA loses co mmunications with the GPS signal.**5. Extent of Relief that TotalOrlando LLC**  **seeks in regards to**

**Section 91.151(b) Fuel Requirements for Flight in VF R**  **conditions** Relief from 91.151(b) is requested to the extent that allows TotalOrlando LLC to operate the DJI Inspire 1 up to a point (considering wind and forecast weather conditions) that there is enough power to fly at normal cruising speed to the intend ed landing point and land the UA with 30% battery power remaining.
**6. Extent of Relief that TotalOrlando LLC**  **seeks in regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2),**  **91.417(a) and (b)** These are all associated a with Airworthiness c ertificate Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is requested to the extent that allows TotalOrlando LLC to operate the DJI Inspire 1 Quad

- Copter as necessary. These sections are all related to airworthiness certificates o f aircraft. There is not currently an airworthiness certificate for small UAS’s. TotalOrlando LLC would com ply in full to any conditions and limitations that the Administrator would place in order to receive an approved Grant of Exem ption.
Public Interest : Aerial videography for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, it's expense has been cost

- prohibitive. Granting this exemption to me would allow me to provi de this service at a m

uch lower cost. TotalOrlando LLC’s UAS will pose no threat to the public given its small size and lack of com bustible fuel when com

pared to manned aircraft. The operation of my UAS will mini mize ecological damage and promote economic growth by providing additional occupancy of properties in the Kissimmee area of Central Florida

.**Conclusion:**

As set forth herein, TotalOrlando LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS co mmercially within the Real Estate markets. The Administrator will be assisting
small business by granting this petition. In accordance with the FAA Modernization and Reform Act of 20 12, TotalOrlando LLC respectfully requests that the FAA Administrator grants this petition for exem

ption from

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91. 409 (a) (1) and (2); 91.417 (a) and (b)