1/21/2016 Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office 

### Federal Aviation Administration 800 IndependenceAvenue, SW Washington, DC 20591 U.S. Department ofTransportation, Docket Operation West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE Washington, DC 20590 Kristin S. Blakley, Member Soaring Eagle Views, LLC P.O. Box 309 Murrysville, PA 15668 kristinblakley@gmail.com Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14CFR 21 subpart H; 14 CFR 45.23(b); 14CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14CFR 91.109; 14CFR 91.119(c); 14CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14CFR Part 11, Soaring Eagle Views, LLC (Soaring Eagle) or (applicant), operator ofan Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner: 

# + Aerial photography and/orvideo for public and/or private use including real estate, architecture, land 

### surveying, engineering and other related professional activities. 

# + Aerial video and/or photographyfor public and/or private use including television, public events and cinematography. 

# + Aerial inspection/photography ofresidential/commercial structures under contract with the owners or 

### local government authority, or universities. 

# + Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 

# + Aerial video/photographyor providing Jive video feed to assist with search and rescue operations in cases ofan emergency or natural disaster onlywhen the local authorities orgovernment has requested it by 

### contract or donation.
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# + The abilityto offertrainingto persons individually or belongingto both private and/or public organizations that have interests in the use and application ofa UAS forthe purpose ofthe safe operation ofa UAS to enhance thesafety ofthe National Airspace System (NAS) as well as forthe protection ofthe persons and property. As described fully below, the requested exemption would permitthe operation ofa UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will providesafety enhancementsto the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA 

### Administrator's) responsibilities to "....establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is: Soaring Eagle Views, LLC Attn: Kristin S. Blakley, Member Phone: 412-398-4662 email:jamesblakley@msn.com Regulations from which the exemption is requested:
14 CFR Part 21 subpart H 14CFR 45.23 (b) 14CFR 61.113 (a) & (b) 14CFR 91.7 (a) 14CFR 91.9 (b) (2) 14CFR 91.103 14CFR 91.109 14CFR 91.119 (c) 14CFR 91.121 14CFR 91.151 (a) 14CFR 91.203 (a) & (b) 14CFR 91.405 (a) 14CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b) Soaring Eagle Views, LLC will operate the DJI Phantom 3, with atotal weight of 1280g or 2.831bs. The diagonal dimensions including propellers are 590 mm x 590 mm. Maximum airspeed is no morethan 16m/s or 31Kts with a cruising speed of llm/sor 21Kts. The DJI Phantom 3 Vision has the ability to hover and move along avertical and horizontal plane simultaneously. The DJI Phantom 3 has four brushless electric motors, powered by a 6000mAh LiPo Lithium Polymer battery. There are four propellers, Propeller Model DJI 9450, in use. The DJI Phantom 3 will be controlled with the factory Phantom 3- Remote Controllerwith an operatingfrequency of2.400GHz2.483GHz. The live video feed will have an operating frequency of5.728GHz- 5.850GHz. The applicant will operate the UAS in line ofsightwithin a predetermined area owned and or operated by the property 

### representative.
Page 2 of 10DJI Phantom 

### 3 Specs
Aircraft 

# + Weight (including battery and propellers): 1280 g 

# + Diagonal size (including propellers): 590 mm 

# + MaxAscent Speed: Sm/s, 984 fpm 

# + Max Descent Speed: 3 m/s, 590 fpm 

# + HoverAccuracy o Vertical:+/- 0.1 m (when Vision Positioning is active) or

## +I- 0.5 m o Horizontal:+/- 1.5 m 

# + Max Speed: 16 m/s, 31 kts (ATil mode, no wind) 

# + MaxAltitude Above Sea Level: 6000 m 

# + OperatingTemperature: O'C to 40'C 

# + GPS Mode: GPS/GLONASS Camera 

# + Sensor: Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

# + Lens: FOV 94' 20 mm (35 mm format equivalent) f/2.8, focus

**at~** 

# + ISO Range: 100-3200 (video) 100-1600 (photo) 

# + Shutter Speed: 8s -1/8000s 

# + Image Max Size: 4000 x3000 

# + Still Photography Modes o Single Shot o Burst Shooting: 3/S/7 shots o Auto Exposure Bracketing (AEB): 3/5 o Bracketed Frames at 0.7EV Bias o Time-lapse 

# + Video Recording Modes
- Phantom 3 o UHD: 4096x2160p 24/2S, 3840x2160p 24/2S/30 o FHD: 1920x1080p 24/25/30/48/50/60 o HD: 1280x720p 24/25/30/48/50/60 

# + Supported SD Card Types o Micro SD Max capacity: 64GB. Class 10 or UHS-1 rating required 

# + Max Bitrate ofVideo Storage Phantom 3: 60 Mbps 

# + Supported File Formats o FAT32/exFAT o Photo: JPEG, DNG o Video: MP4, MOV (MPEG-4 AVC/H.264) 

# + OperatingTemperature o 

# o·c to 40'C Gimbal 

# + Controllable Range: Pitch -90' to +30' 

# + Stabilization: 3-axis (pitch, roll, yaw) Vision Positioning 

# + MaxVelocity: Less than 8 m/s (when 2m above ground) 

# + Altitude Range: 30 cm-300 em 

# + Operating Range: 30 cm-300 em 

# + Operating Environment: Surface with clear pattern and adequate lighting (Lux> 1S)

Page 3 of 10Remote Controller 

# + Operating Frequency: 2.400 GHz-2.483 GHz 

# + Max Distance: 2000m (outdoors and unobstructed) 

# + Video Output Port: USB 

# + OperatingTemperature: 0°C- 40°C 

# + Battery: 6000 mAh LiPo 25 

# + Mobile Device Holder: Fortablet or phone 

# + Receiver Sensitivity (1%PER): -101 dBm ±2 dBm 

# + Transmitter Power (EIRP) o FCC: 20 dBm o CE: 16 dBm 

# + WorkingVoltage: 1.2 A @7.4 v Battery Charger 

# + Voltage: 17.4V 

# + Rated Power: 100 W Intelligent Flight Battery 

# + Capacity: 4480 mAh 

# + Voltage: 15.2 V 

# + BatteryType: LiPo 45 

# + Energy: 68 Wh 

# + Net Weight: 365 g 

# + Max FlightTime: Approximately 23 minutes 

# + OperatingTemperature: -10°C to 40°C 

# + Max Charging Power: 100 W App 

## I Live View 

# + MobileApp: DJI Pilot 

# + EIRP: 100mW 

# + Live View Working Frequency: 2.4GHz ISM 

# + Live View Quality: 720P@ 30fps (depending on conditions and mobile device) 

# + Latency: 220ms (depending on conditions and mobile device) 

# + Required Operating Systems o OS 8.0 or later o Android 4.1.2 or later 

# + Recommended Devices o iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi +Cellular, iPad mini 2, iPad mini 2 Wi-Fi +Cellular, iPad Air 2, iPad Air 2Wi-Fi +Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone Ss, iPhone 6, and iPhone 6 Plus o Android: Samsung 55, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini o *Supportfor additional Android devices available as testing and development continues Given the small size ofthe UAS and the controlled environment provided the proposed operations will adhere to the Reform Act's safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested

Page 4 of 10exemption is in the public interest. Accordingly the applicant requests thatthe FAAgrantthe requested exemption with minimum delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhereto when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: The UAS will weigh less than 55 lbs. {DJ/Phantom 3 weighs 1280G or2.83 fbs.) The UAS wHI have a maximum operatingairspeed ofno morethan 50 Kts. (DJI Phantom 3 maximum speed ·,s 

### 31 Kts.) 

# + Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and Visual Observer (VO) if utilized.


# + Maximum flighttimefor each operational flightwill be 30 minutes. Flights will be terminated at 

### 25% battery power reserve or30 minutes offlighttime whichever occurs first. 

# + Flights will be operated at an alf1tude ofno morethan 400 feet Above Ground Level (AGL) and not more than 

### 200 feet above an elevated platform from which filming is planned. 

# + Minimum crew for each operation will consist ofthe UAS Pilot, and may include, depended on mission requirements, aVisual Observer (VO). 

# + The UAS pilot will be a designated Pilot in Command (PIC) and wHI take and pass all necessary certifications currently being approved by the FAA administration for commercial use. 

# + A briefingwill be performed regarding the planned UAS operations priorto each day'sflight consisting of all the days' production activities. 

# + All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 

# + The flights will occur no closer than a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) ofatower controlled or uncontrolled airport. The DJI Phantom 3 has built in softwarefor all FAA regulated 'No Fly Zones' and was uploaded by DJI (July 

### 2015 Firmware) forall DJI drones to download and prevent any possible flights occurring within no-fly zones. DJI Phantom 3 has installed software (code) that denies flights within the FAA no-fly zones. 

# + Ifoperations will be within a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) ofa tower controlled or uncontrolled airportthe respective airports will be contacted advising them ofthe estimated flighttime, flight duration, elevation offlight and other pertinent information.

Page 5 of 

### 10

# + The operatorwill file FAA Form 7711-1, orits equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no morethan 72 hours but no less than 48 hours from planned operation. 

# + The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensurethat only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 

# + The PIC, and VO ifutilized, will have been trained in operation of UAS and receive up-to-date information forthe particular UAS to be operated. 

# + The PIC and VO, if utilized, will be able to communicate by voice, radio, and/ortext at all times. 

# + Written and/orverbal permission and permits will be obtained from territorial, state, county or city 

### jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

# + Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to apre-determined location within adesignated location and land autonomously. 

# + The UAS will have the capability to abort aflight in case ofunpredicted obstacles, weather, or 

### emergencies.
14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given thesize and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both author1ze the FAA to exempt aircraftfrom the 

### requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wingor rotorcraft) operating with an airworthiness certificatewithoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local publicsafety requirements. The FAA will have advance notice ofall operations. These safety enhancements provide agreater degree ofsafetyto the public and property ownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load.
14C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: Page 6 of 10When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance tothe cabin, cockpit, or pilotstation, in letters not less than 2 

### inches nor more than 6 inches high, the words "limited," "restricted," "light-sport/1 11

### experimental," or 11

### provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrancetothe cabin, cockpit or pilotstation on which theword "Experimental" can be placed. Given the size ofthe UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by havingthe UAS marked on its fuselage as required by §45.29 (f) wherethe pilot, observer and others workingwith the UAS will see the identification ofthe UAS as 

### "Experimental."
14C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and limitations: Pilot in Command. Pursuantto 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyforcompensation or hire. An equivalent level ofsafety can be achieved by current Regulations because the applicant's UAS do notcarry any pilots or passengers nor property. The risks attendanttothe operation ofUAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC ofthe UAS will have aCommercial Pilot's License along with acurrent Second Class or higher Medical exceeding the currentsafety levels in relation to 14 CFR 61.113 (a) & (b).
Ifeel the operation and limitations set forth in the FOM will equateto thesafe operation ofthe UAS. 14C.F.R. §91.7(a): Civil AircraftAirworthiness. The regulation requires that no person may operate acivil aircraft unless it is in airworthy condition. As therewill be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determiningairworthiness. Given the size ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equivalent level of safety will be provided.

Page 7 of 1014C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft acurrent 

### approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such aflight manual 

### on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping theflight manual at the ground control point where the pilotflyingthe UAS will have immediate access to it. 14C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command to take certain actions beforeflightto insurethe safety offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the DJI Phantom 3 Flight Section ofthe User Manual including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.
14C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fullyfunctioning dual controls. UAS and remotely piloted aircraft, by theirdesign do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control box that communicateswith the aircraftvia radio communications. The FAA has approved exemptions for flighttrainingwithoutfully functional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety provided by thefactthat neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.
14C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudesfor operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the UAS will neveroperate at higherthan 400 AGL with the exception that in circumstances wherethe UAS is used to survey or photograph astructure whose height exceeds 400 feet AGL, the UAS will not be operated morethan 200 feet abovethe highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and peoplewill not be exposed to operations withouttheir pre-obtained 

### consent. The equivalent level ofsafetywill be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individualswill be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must complywith Section 91.119.

Page 8 of 1014C.F.R. §91.121 AltimeterSettings. This regulation requires each person operating an aircraft to maintain cruising altitude 

### by reference to an altimeter that is set u... 

### to the elevation ofthe departure airport or an appropriate altimeter setting available before departure.'' As the UAS may not have a barometric altimeter, but Instead aGPS altitude read out, an exemption may be needed. An equivalent level ofsafetywill be achieved by the operator, pursuantto thesafety check list and liveflight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight.
14 C.F.R. § 91.151(a): Fuel Requirementsfor Flight inVFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflyto thefirst point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthatforat least 30 minutes; or (2) At night, tofly afterthatforat least 45 minutes." The battery powering the UAS provides approximately 30 minutes ofpowered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limitedto approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertimeframe forflight in daylight ortwilight VFR conditions is reasonable. Applicant believes that an exemption from 14CFR §91.151(a) falls within the scope ofprior exemptions. Operatingthe UAS, in atightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthetype of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utilityforwhich the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% of battery power- whichever happensfirst. This restriction would be morethan adequateto return the UAS to its planned landing zone from anywhere in its limited operating area. 14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or aspecial flight authorization issued under §91.715 is displayed at the cabin orcockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control pointwhere the pilotflying the UAS will have immediate access to them; to the extentthey are applicable to the UAS.

Page 9 of 1014C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

### These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepanc"les repaired as prescribed in part 43 ofthis chapter.

..," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applytothe applicant. Maintenancewill be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level ofsafety will be ach"1eved because the UAS is very limited in size and will carry asmall payload and operate only in restricted areas for a limited period oftime. If mechanical issues arise the UAS can land immediately and will be operatingfrom no higherthan 400feet AGL. The operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the a1rcraft ·,nan airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure that the UAS is in working order priorto initiatingflight and perform required maintenance needed. Regards, ,} , /} 17



# li)!u<J~

# s.

**'-'Oljl~** I Kristin S. Blakley, Member 

# U Soaring Eagle Views, LLC 1/21/2016

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