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U.S. Department ofTransportation DocketManagement System 1200 New Jersey Avenue SE Washington DC 20590 January 8, 2015**~** .:



### RE: Request for Exemption pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CF.R. Part 11 

### Drone Photo and Video Julie van der KroefLLC 88 Taunton Lake Road Newtown, CT 06470-1450 (203) 491-2555 iulievanderkroef@sbcglobal.net,

This petition is being submitted onmy behalfwithout legal counsel or consulting servtces. Pursuantto Section 333 ofthe FAAModernization and Reform Actof2012, and 14 C.F.R. part 11, Drone Photo and Video, a digital imaging service, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed belowto allow operation ofmy Small Unmanned Aircraft System (sUAS) commercially in airspace regulated bythe FAA so long as operations are conducted with andunder the conditions outlined herein or as may be set forth by the FAA as required by Section 333. The requested exemption wouldpermit

### Drone Photo and Video to pursue its commercial interests byproviding services to clients using small advanced sUAS inthe following areas: commercial andresidential real estate, commercial and residential building progressions, bridge, tower and structure inspections, utility inspections, special events, local and national natural and man-made disaster and
rescue servtces. 

### ABOUTDRONEPHOTOAND VIDEO 

### and Julie van der KroefLLC:

### /DronePhoto and 

### Video is based in Newtown, Cf. Julie van der Kroefis 

### the sole ' proprietor ofthis start up business, and is anticipating an abundance ofopportunity and discovery in this new field ofendeavor. Initial focus will be on the Real Estate and Contracting markets, however as the technology quickly proves its value, the business will branch out as needed into inspections, surveys and monitoring. My goal is to serve the needs ofthe public whenever and where ever I 

### am needed. Search and Rescue emergencies will also be important to my business. SAFETY 

### Safety is a fundamental core value in all DronePhoto and Video 

### operations. Julie van der KroefLLC strongly believes the safe integration ofsUAS's into National Air Space (NAS) is ofthe utmost importance and will adhere to any additional regulations imposed by the FAA in order to maintain the safety and security ofthe National Air Space (NAS). Therefore as an ambassador ofthis new technology, I 

### will always strive to be an exemplary representative ofproper sUAS integration into NAS for commercial purposes. PILOT IN COMMAND (PIC) 

### In order to maintain and advance the necessary safety and security protocols ofan emerging industry, I 

### present my qualifications and procedures for safe flight with sUAS: 1) I 

### hold a StudentPilot Certificate and Medical Certificate Third Class GX1691394 dated 09/17/2015. 2) I 

### possess a valid driver's license in Connecticut, and hold a current United States Passport. --3)Ihave logged 25 hours ofin-air flight instructiontime pursuantto a sport pilot certificate, and completed the following maneuvers: pre-flightplanning and procedures, airport operations, take-offs and landings, go-rounds, performance maneuvers, navigation, slow flight and stalls, post-flight procedures. 4) I 

### have studied the following subjects in ground school: FAA regulations, accident reporting to NTSB, use ofaeronautical charts, radio comm procedures, recognition ofweather situations, wind-shear avoidance, weather reports and forecasts, safe and efficient operation ofaircraft, collision avoidance, effects ofdensity altitude, wake turbulence, power-

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plants and aircraft systems, stall awareness, national airspace classifications, controlled versus uncontrolled airspace, and special use airspace. I am committedto operating my sUAS safely within the United States airspace
as a trained student pilot. 

### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY DronePhoto and Video, Julie van der KroefLLC, requests exemption from the following regulations, as well as any additional regulations that may technically apply to the operations ofthe sUAS: 14 CFRPart 21, Sub part H, 14 CFR 21.191, 14 CFR Part 27, 14 CFR sections ./--- 45.23(b), 14 CFR 45.27 (a), 14 CFRPart 61.23(a) & (c), 14 CFRPart 61.101(e)(4)&(5), 14 CFR 61.113(a)&(b), 14 CFR 61.315(a), 14CFR91.7(a), 14 CFR 91.9, 14 CFR 91.103, 14 CFR 91.103, 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203(a)&(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 417(a)&(b). 

### 14 CFRPart21 SubpartH Airworthiness Certificates and Safety This part establishes the procedures for the issuance ofan airworthiness certificate. While the FAAcontinues to work to develop airworthiness standards for UAS, I request an experimental certificate be issued for the DJI Phantom 3 Professional

. Previous exemptions have been granted bythe FAA in the roto-craft UAS Section 333 approval process. The DJI Phantom 3 Professional is the latest model in its class from DJI, a worldwide leader in technologically advanced small roto-craft, and itis equipped withhighly advanced control and navigational features to fit within the prior safety requirements set forth bythe FAA. This aircraft features a built-in stabilized HD camera and GPS safety features which limit not onlythe height atwhich it files but also the radius from the pilot. Itincludes programs that exclude operations within designated Class B, C, and D airspace including a no-fly zone feature. Should the battery level get below safe level, or the communicationbetweenthe pilot and the UAS be lost, the unit has a failsafe feature that returns it to its point oftake-offto safely land without incident. 

### 14 CRFAirworthiness Standards: Normal Category Roto-craft• 

### ..

Since the sUAS is not a normal roto-craft as described inthis regulation, this regulation does not apply, therefore I request an exemption from 14 CFR 27. 

### 14 CFR 45.23 (b) Display ofMarks & 

### 14 CFR45.29 Size ofMarks & 

### 14 CFR 45.27(a) Location ofMarks The UAS will not have an airworthiness certificate, but as required bythe 333 Exemption, it will be registered and have its own "N"number permanently applied
as prominently as possible. 

### 14 CFR 61.23 (a) (c) Medical Certificates: Requirements and Duration I, Julie van der KroefLLC, possess a valid FAA studentpilot medical certificate,**~~---** and current Connecticut driver's license, as well as a United States Passport. 

### 14 CFR 61.101 Recreational PilotPrivileges & 

### Limitations, 14 CFR61.113 (a) 

### & (b) PrivatePilot Privileges 

### & Limitations: Pilot in Command, 61.133 Commercial Pilot Privileges & 

### Limitations. The PIC requirements stated inthe 333 Exemption state the UAS PIC must hold eitheraprivate, commercial or sport pilot's license to operate the sUAS for commercialpurposes. Because the sUAS will not carrypilot orpassengers, is remotely controlled, andthe area ofoperation is controlled and limited, the level of risk is greatly diminished from a traditional aircraft. Therefore I, Julie van der KroefLLC, request an exemption from these regulatory requirements. 

### 14 CFR61.315 (a) (c) (2) (3) Privileges & 

### Limits ofMy SportPilotCertificate Drone Photo and Video, Julie van der KroefLLC, requests exemption from these parts ofthis regulation. 

### 14 CFR91.7 Civil AircraftAirworthiness Drone Photo and Video, Julie van der KroefLLC, requests exemption from this regulation since no such certificate will be necessary for the DllPhantom 3 Professional Drone. The sUAS will be inspected and tested prior to each flight. 

### 14 CFR 91.9 Civil Aircraft Flight Manual, Marking and Placard

. Requirements AND 14 CFR91.203 (a) & 

### (b) Civil Aircraft: Certifications RequiredDrone Photo and Video, Julie van der KroefLLC, request exemption from these regulations, as the manual for the 

### DllPhantom 

### 3 Professional will bewith the PIC at the ground control station 14 CFR 91.103 PreflightAction As the PIC in command ofthe sUAS, the following will apply to all flight plans: Pre and post-flight checklists will include inspection ofall ofthe sUAS parts and systems. Preflight safety assessments including weather conditions and other areas of
concern regarding environment offlight. Obtainproper clearance ofNational 

### Air Space, and properpermission of landuse. Manage spectator safety at all times. Keep proper documentation available. Follow manufacturer's recommendations for maintenance, overhaul, replacement, inspection, and life limitrequirements for aircraft and parts. Drone Photo and Video will only conduct operational flights under ideal visual meteorological conditions (VMC) and within visual line ofsight (VLOS) only. No flights to exceed 87 knots (100 miles an hour). No flights over 400 AGL. No flights at night. No flights within five miles ofan airport. No flights ifvisibility is less than 

### 3 statute miles. No flights in or overpopulated areas. Maximum flight times will be determined bythe battery life, landing with 

### 20% reserve. The sUAS will weigh less than 55lbs. fully loaded with cameras, lens

# and gimbal. The minimum crew will include PIC and sUAS visual observer.

14 CFR Flight Crew Members at Stations This regulation does not apply, so Drone Photo and Video requests exemption.

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### 14 CFR Flight Instruction; Simulated instrumentlight and certain flight tests The sUAS ground-based control station consists ofa hand-held radio transmitter which canbe operated by both student and instructor for a "hands-on'' learning experience. This technique meets the intent of91.109 andprovides an equivalent level ofsafety. 

### 14 CFR 91.119 Minimum Safe Altitudes: General This regulation states that over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to a person, vessel or structure. Exemption is requested because the typical mission ofthe sUAS would be photography or survey and itwouldbe necessary to operate closerthan the 500 feet listed. 

### 14 CFR 91.121 Altimeter Settings This regulationrequires the aircraft shall maintain cruising altitudes byreference to an altimeter setting available within 1OONM ofthe aircraft. Since the sUAS will always fly below 400 feet AGL and will notbe cruising in airspace with conventional**aircra~** a collisionhazard does not exist. 

### An AGL altimeter is transmitted viaradio from the sUAS on-board computer

### to the display screen held bythe PIC, which provides a constantly updated AGL readout. 

### 14 CFR 91.151 (a) Fuel Requirements 

### Drone Photo and Video requests exemption to the word "fuel'' and ask instead for the word "energy" (i.e. battery power). As PIC, I will ensure proper batterypower reserve as recommended bythe manufacturer. 

### 14 CFR SubpartE 91.401

- 91.417- Maintenance, Preventive Maintenance, Alterations As the PIC, I will ensure thatroutine maintenance andinspections ofthe aircraft will beperformed before the aircraft is returned to service. I will ensure airworthy condition prior to each flight, and at two hour intervals during use. I will perform routine repairs byreplacing worn propellers, checking electrical connections, updating software and firmware for the on-board computer, and other recommended procedures from the manufacturer. Additional work will be performed by a certifiedrepair center, orthe manufacturer itself. A writtenpilot's log will be kept ofall such maintenance.IMP ACT ON THEPUBLIC

- The use ofthe unmanned aircraft system in lieu ofa manned aircraft will enhance safety andreduce environmental impact comparedto similar operations conductedwithmuch larger, fuel ladenmanned aircraft. The use ofUAS to facilitate commerce canhelp encourage economic growth. Itis in the interest ofthe public to grant exemptiontoDrone Photo and Video, Julie van der KroefLLC.



### PROPOSED UAS 

### FOR EXEMPTION Drone Photo and Video, Julie van der KroefLLC, proposes to use the DJI __.-- Phantom 3 Professional for commercial photography and videography. It is at this time I formally ask for exemption. I request approval to update the DJI series systems software andhardware within the parameters ofimposedFAAregulations. Thank you for your consideration,

Julie van der KroefLLC Drone Photo and Video 88 TauntonLake Road Newtown, CT 06470 (203) 491-2555