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Eagle Eye Photography

June 9, 2015 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform 

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization & Reform Act and 14 C.F.R. Part 11, 

Eagle Eye Photography hereby applies for the grant of 

exemption from certain Federal Aviation Regulations for our 3 separate Unmanned Aircraft 

System UAS quadrotor aircraft owned and operated exclusively by Eagle Eye Photography. 

The requested exemption would support an application for a commercial Certificate(s) of 

Authorization (COA) to use our Yuneec Q500, Yuneec Q500+ and DJI Inspire 1 

aircraft to support real estate photography, videography, and reporting 

for commercial purposes. 

Eagle Eye also wants to provide support for local law enforcement and 

emergency services. 

The Yuneec Q500 and DJI Inspire 1 Unmanned Aircraft Systems (UAS) are lightweight

(less than 6 lb), battery operated, quadcopter aircraft with onboard camera, gimble 

and GPS and are remotely controlled via 2.4ghz communications equipment.

All 3 Aircraft (2 Q500 & 1 Inspire 1) owned and operated by Eagle Eye have

multiple safety features built in. In case of lost communication with it's transmitter,

the UAS will automatically return to it's launch point and land itself if necessary. 

Each UAS also keeps flight record data recorded and stored on SD memory 

cards in the transmitter. Each UAS uses multiple satellites for their GPS signal 

and constantly feeds the PIC location data such as altitude direction and distance 

of travel.

 

The Yuneec and DJI Inspire 1 UAS each carry an onboard high definition video and still 

camera system that allows it to perform aerial photography, videography, and searches. 

By approving the exemption, Eagle Eye's UAS operations will create benefits to

both the economy and the environment which are ultimately in the public interest.
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All Unmanned Aerial Systems will be operated with both a Pilot in Charge

and a Visual observer in accordance with the following restrictions:

All operations will occur at no more than 400' AGL 

- The aircraft will be operated with the permission of the property owner

- When necessary, applicable permits will be acquired from local authorities

- The aircraft will not be operated over urban or populated areas

- The aircraft will not be operated at air shows or over an open-air assembly of people 

- The aircraft will not be operated over heavily trafficked roads

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at

all time 

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- When necessary and applicable, Eagle Eye will file a NOTAM 

providing radial/DME, radius, and a date/time group for each operation 

For certain complex operations, Eagle Eye may assign one or two sensor/software

operators or VO's to assist t he operations. 

We submit that our choices of UAS and knowledge of FAA

Unmanned Aircraft Systems (UAS) Regulations & Policies help to show our 

commitment to safety and compliance while striving to provide a valuable service 

to the public. 

-The DJI Inspire 1 and Yuneec Q500 UAV’s light weight, reliability and historically 

safe operation, while having received multiple approvals for section 333 petitions, 

make these excellent choices for UAS. 

-We maintain a fully qualified and trained flight crew . 

-Eagle Eye will only operate under the guidelines established within the grant and 

our operations will have an equivalent or greater level of safety than manned 

aircraft performing the same mission. 

Email: thewg2000@yahoo.com

Matthew Geissal
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TABLE OF CONTENTS

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .......................Page 4 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH EAGLE EYE 

SEEKS EXEMPTION...................................................................................................Page 4 

THE EXTENT OF RELIEF EAGLE EYE SEEKS AND THE REASONS 

EAGLE EYE SEEKS THE RELIEF ......................................................................Pages 4 to 6

THE REASONS WHY GRANTING EAGLE EYES REQUEST WOULD

 BE IN THE PUBLIC INTEREST .............................................................................. Page 7 

THE REASONS WHY GRANTING EAGLE EYES THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY ........................................................................ Page 8 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...............Page 9 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT EAGLE EYE’S REQUEST.........................................Page 10 & 11 

ACRONYMS............................................................................ Pages 12 & 13 
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NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER 

Matthew Geissal

Eagle Eye Photography 

4828 County Road 1295 

Tyler, Texas 75704 

Tel: 903-316-1549 

Email: thewg2000@yahoo.com 

THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF EAGLE EYE SEEKS AND THE REASONS 

EAGLE EYE SEEKS THE RELIEF 

14 CFR 61.113 Private pilot privileges and limitations: 

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot 

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private

pilot to act as pilot in command of an aircraft in connection with any business or 

employment if; 

(1) flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Since the aircraft cannot carry passengers or property, we request to be relieved from

this regulation if our pilots at minimum, 

(1) hold at least a current private pilot certificate and, 

(2) hold a current third class medical certificate. 

By meeting conditions (1) and (2), we believe that equivalent level of safety can be

achieved by complying with 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 91.7 (a) states,

“No person may operate a civil aircraft unless it is in an airworthy condition.”

This rule prohibits the operation of an aircraft without an airworthiness certificate. 

Since there is no such existing certificate that is applicable for the Phantom UAS to

properly comply with the FARs, we request that Crosstimbers to be relieved from this 

regulation.

To provide equivalent level of safety, we will ensure that the Yuneec and DJI Inspire

UAS are in 
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airworthy condition prior to every flight by following safety procedures described 

in our operating documents. 

14 CFR 91.119 Minimum safe altitudes: General 

This regulation provides that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this

requirement.

To provide an equivalent level of safety we will only fly over private property with the 

permission of the land owner. The land owner will be briefed of the expected route of

flight and the associated risks to persons and property on the ground. We maintain that 

due to the small size of our UAS, t he hazard to persons, vessels, vehicles, and 

structures is not comparable to manned aircraft and should be considered in granting 

the exemption. 

14 CFR 91.121 Altimeter Settings 

This regulation provides that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 nautical miles of the aircraft.

The Yuneec and DJI Inspire aircraft will fly below 400 feet AGL and will not need to maintain 

hemispherical cruising altitudes in order to de-conflict with other aircraft. 

 

To provide an equivalent level of safety, the PIC will check and confirm the UAS’s 

GPS altitude read out before each flight.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended landing 

and to fly after that for at least 30 minutes. We believe the intention of this rule is to 

provide a reserve of energy as a safety buffer for go-arounds and other delays to 

landing.

The 3 petitioned UAS we submit are battery operated and the maximum duration of 

flight with full payload, from a single battery charge is approximately 

20 to 25 minutes. 

We believe that equivalent level of safety can be achieved by limiting our flight time to 

15 minutes with reserve energy 20 % ( 5 to 10 minutes) on the battery.
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14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 ) 

Maintenance, Preventive Maintenance, and Alterations

 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a

person authorized under 43.7" after maintenance and inspection. It is our intention that 

the PIC, VO or authorized personnel to perform maintenance and inspection of the

aircraft and "be authorized to approve the aircraft for return to service."

Eagle Eye requests that exemptions to the regulations under conditions below;

(1) Eagle Eye will follow DJI and Yuneec’s manufacturer maintenance instructions, 

techniques and procedures for the 2 models of aircraft we will operate.

(2) Eagle Eye will designate, train, and document the personnel who will be 

authorized to perform Inspection, Maintenance and Alterations by means of above 

stated maintenance instructions. 

Such designated personnel may include PIC, VO or other equivalent trained persons 

(3) To ensure equivalent level of safety, PIC will inspect the UA before each flight 

looking for any structural or mechanical malfunctions

Due to the small size, light weight and simplicity of the UAS, we believe that 

the equivalent safety will be achieved by permitting any of the PIC, VO or equivalent 

trained personnel, to perform maintenance, inspection and alterations of the aircraft 

and " be authorized to approve the aircraft for return to service. "
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THE REASONS WHY GRANTING EAGLE EYES’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST

We believe that granting our exemption request from,

14 CFR Part 21.191 

14 CFR Part 45.23, 45.29 

14 CFR 61.113, 61.133

14 CFR 91.9, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the public’s interest and 

will benefit the public as a whole for the following reasons.

1- Eagle Eye's UAS are battery operated and free from the harmful emissions associated 

with the manned aircraft that are currently used for aerial photography and 

videography.

As recently proven by several grants of section 333 petitions, UASs offer 

equivalent level of safety while reducing environmental impacts, which is in the 

public interest. 

2- Eagle Eye’s UAS operations will contribute to a positive aggregate economic 

impact resulting in creation of jobs both direct and indirectly. Economic 

Research estimates that the UAS market will grow from $6 billion to $ 94 billion 

over the next decade resulting in a new workforce development. 

Because Eagle Eye’s operations will create new jobs such as pilots, flight 

operation staff, and administrative supporting staff, it will directly cause positive

economic impact, hence granting Eagle Eye's petition will benefit the public 

as a whole. 

3- Congress has already proclaimed that it is in the public’s interest to integrate

Commercially flown UAS(s) into the national airspace system, hence the passing 

of the FAA Modernization and Reform Act of 2012. 

Granting EagleEye's petition furthers the public’s interest as a demonstrated 

progression of integrating Unmanned Aircraft Systems into National Air Space, 

thus it will benefit public as a whole. 
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THE REASONS WHY GRANTING EAGLE EYE PHOTOGRAPHY THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY

Eagle Eye Photography believes that the grant of exemption from, 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of the reasons listed below.

(a) We have stated in the above section “ THE EXTENT OF RELIEF

EAGLE EYE SEEKS AND THE REASONS EAGLE EYE SEEKS THE 

RELIEF ” by describing how we intend to mitigate risk and accomplish FAA 

equivalent and acceptable level of safety for each 14 CFR part.

 

(b) As a result of our UAV unmanned aircraft’s size, weight, speed, operational

capability, proximity to airports and populated areas, operation within visual line

of sight combined with the implementation of Eagle Eye’s safety procedures, 

we believe that granting Eagle Eye’s exemption request will not adversely 

affect the safety of our personnel or the public. 

(c) DJI Inspire 1 has demonstrated it possesses the necessary safety features and 

 risk mitigation to the FAA resulting in multiple grants of section 333 petitions. 

With the combination of DJI Inspire’s proven success, the inherent 

 safety features of the Yuneec Q500 UAS, and the conditions 

and limitations of our operations, we believe granting Eagle Eye's request will

not adversely affect safety of our personnel or the public. 

.
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SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Eagle Eye Photography

Petition of exemption from sections of ; 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought; 

Eagle Eye seeks an exemption for commercial operation of the Q500 and Inspire 1 

unmanned aircraft manufactured by Yuneec and DJI Co, Ltd. respectively. 

The Q500 and Inspire 1 unmanne d aircraft systems have an onboard camera

system capable of acquiring high resolution data. 

Proposed operations will offer real estate aerial photography, videography and aerial 

services for other commercial industries. 
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ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT EAGLE EYE’S REQUEST

 Yuneec Q 500 Unmanned Aircraft System 

General Features

 Ready to Fly, Multifunctional Quad-rotor System 

 Customized H3 -3D Gimbal Support

 Precision Flight and Stable Hovering

 25min Flight Time & Smart Battery

 Auto Return-to-Home & Landing

 Advanced Power Management

 Intelligent Orientation Control (IOC)

 Easy Battery Replacement 

 Self-tightening Propeller

 Video Downlink Support

 CAN-Bus Expansion Module 

 Control Link radio operating frequency 2.4 GHz ISM

 Operating Distance 800 meters 

Aircraft Performance 

Empty Weight 2.5 lbs

Max Take-off Weight 4 lbs

Max Flight Speed 30 Knots 

Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s 

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

Diagonal Length 510mm 

Flight Time 25 minutes
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 DJI Inspire 1 Unma nned Aircraft System 

General Features

 Ready to Fly, Multifunctional Quad-rotor System 

 Customized H3-2D and H3-3D Gimbal Support

 Precision Flight and Stable Hovering

 18-20 m in Flight Time & Smart Battery

 Auto Return-to-Home & Landing

 Advanced Power Management

 Intelligent Orientation Control (IOC)

 Easy Battery Replacement 

 Self-tightening Propeller

 Video Downlink Support

 CAN-Bus Expansion Module 

 Control Link radio operating frequency 2.4 GHz ISM

 Operating Distance 2 km 

Aircraft Performance 

Empty Weight 5.5 lbs

Max Take-off Weight 6.5 lbs

Max Flight Speed 22m/s 

Hover Accuracy (Ready to Fly) Vertical: 0.5m; Horizontal: 2.5m 

Max Yaw Angular Velocity 150°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 5m/s; Descent: 4m/s 

Diagonal Length 559mm 

Flight Time 18-20 m inutes

No Privacy Issues

Eagle Eye’s proposed operations will create no privacy issues because the 

aforementioned UAS will be operating in rural areas within the

boundaries of the properties with the land owner’s permission. 

Eagle Eye w ill also obtain any permits or authorizations from local authorities when

necessary. 
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ACRONYMS 

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATCAA Air Traffic Control Assigned Airspace

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency Point

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FARs Federal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management 

System

FTP Flight Termination Point

FTS Flight Termination System

Eagle Eye Eagle Eye Photography

GHz Gigahertz

GCS Ground Control Station

MHz Megahertz

MTOW Maximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

NOTAM Notice To Airman 

OPA Optionally Piloted Aircraft

PIC Pilot in Command

Q500 Yuneec Q500 Un manned Aircraft System

Inspire 1 DJI Inspire 1 Unmanned Aircraft

R&D Research and Development

RF Radio Frequency
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RM Risk Management

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System(s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer