Jeremy Salo 26652 Wilton Court New Hudson, MI 48165 (248) 207

- 3056 jsalo@clvpro.com

October 29, 2015

US Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 ( Submitted electronically to the Federal Docket Management System )

Re : Request for Exemption under section 333 of the FAA Reform Act

I am seeking relief from these sections in order to operat e a Phantom 2 unmanned aerial system for purposes of capturing photography and video for commercial purposes. I am seeking complete or partial exemption s from the following sections of 14 CFR as you seem appropriate :

Part 21 Airworthiness Certification 21, Subpart H

- Certification procedures for products and parts, Airworthiness Certificates

Part 61 Certification: Pilot s, Light Instructors, and Ground Instructors

Part 91 General Operating and Flight Rules 91.103(b)(2)

- Preflight action 91.105

- Flight crewmembers at stations 91.109

- Flight instruction 91.119

- Minimum safe altitudes 91.121

- Altimeter settings 91.151

- Fuel requirements for flights in VFR conditions 91.405

- Maintenance required 91.407

- Operation after maintenance 91.409

- Inspections 91.417

- Maintenance records

The public will benefit from this exemption as I will be able to provide a service for them in a safe manner instead of them purchas ing a cheaper unmanned aircraft and operating it them selves. For example, perhaps a local golf course would like a promotional video that shows their landscape. Currently minimal options exist in my area for them to hire a local freelance company to get these images within a reasonable fee. So instead they may go t o the local shopping mall and purchase a cheapquad chopper to fly and record the footage themselves. They will most likely not know the regulations of the FAA and general conditions of operating a Unmanned Aircraft System

- UA S . For example, they may not understand wind direction s and that a UA S can increase it’s speed over 10 times when changing
direct ion s according to the wind masses and speed. This m a y not allow them enough time to safely land
the UA S before their battery runs out of charge. I have studied the FAA rules and guidelines for
maintain ing a safe airspace and understand them . Furthermore, I have over 8 months of experience and
2 5 0 hours of flight time operating my UA S as a hobbyist and unde rstand it’s capabilities and limitations. Also, my Phantom 2 has many safety features built in, such as returning home when the battery is low using GPS, GPS stabilization, and will not fly in to restricted areas. These cheaper models that some store

owners may use now typically do not have these functions . The unmanned aircraft system I fly, my experience and knowledge will make the processing a nd capturing low altitude aerial footage much safer than the current process of each person buying their own cheaper model and flying it themselves.

It is also less dangerous for this small unmanned light weight UAS to record the footage than putting a
live crew in a smaller aircraft with combustible fuel into the air.

The exemptions w ould not adversely affect safety. In fact, I will be an advocate for having an unmanned vehicle registered, learning the FAA rules and guidelines and teaching these to others

. I am a college professo r at a community college that teaches photog raph and video production. We do not have any current plans to include UAS directly in our curriculum, but students seek guidance from me about current and emerging technology . I provide them with the information they need or direct th em to the appropriate areas to learn more

. I am attaching the Phantom 2’s aircraft flight manual along with my
other accessories for detailed specifications and design of the unit s and how they help maintain a safe airspace

.

I understand national airspac e and would not fly above 200 feet for commercial purposes without a
Certificate of Waiver for Authorization . Most of the time the UA S will be traveling a slow speed in order to capture a nice smooth video image. At no point would the UA S exceed 100 Miles per hour. I will keep
the UAV under the recommended maximum speed as mentioned in the aircrafts manual attached.

I will maintain a safe distance from all aircraft and avoid collision with them. I will also not fly dir ectly over people

. Most photography and flights will be over less populated a reas including nature landscapes. I will keep the UAS wi th in the direct line of sight or have a spotter that can see the UAS and
communicate with me at all times. Here is an example of what a spotter would do . There is a tree that may temporally be in my line of site as the operator (pilot in command) . The spotter would be on the

oppo site side of the tree so they can see it directly when I can only see the video signal

. They would verbally tell me if any obstructions or other situations are an issue that I cannot see on the live video
feed.

As an operator, I will still see the video signal which shows me ultra

- wide angle of view at approximately
a 15

- mm equivalent as compared to a 35 mm lens format

. The spotter will either be in talking distance or will be communicating through a cellphone or similar communication device. As an operator of the UAS
,I was have an earpiece for communication or speaker if necessary but will always have both hands
availab le to control the UAS

.
I will not fly the aircraft in restricted areas and within close proximity of an airport. This aircraft has built in GPS controls that automatically restrict flight into these restricted areas. I will inspect the UAS before
each fli ght to make sure it is flight ready. The Phantom 2’s aircraft flight manual details the preflight
routine I follow in more detail.

I also make sure the firmware of the aircraft and it’s individual components are up to date by plugging in the device to my computer, scanning all components, and having the software check online to make sure they are all up to date. The program is called DJI Phantom 2 Vision Assistant_3.8. It also digitally verifies the integrity of the components of the aircraft. I can calib rate the aircrafts controller using this software or make other changes needed before a flight. I do this once a month or more if I receive an email notification about updates or if I visually notice anything that appears abnormal about the aircraft.
This software also updates restricted areas or air space heights that the FAA and other governing bodies enter into the system.

I will make sure I have enough battery charge for the duration of the intended flight plus a reserve

amount as recommended in the manual

.
The operating Frequency of the aircraft’s controller is 2.4GHz ISM

. The unit is approved for such use by the FCC.

An Immersion RC Tr ansmitter installed on the aircraft to send a live video signal to me. This shows a video stream from the aircraft and other information about the flight as listed below and on the attached documents. The transmitter operates on a 600mw 5.8 GHz frequency. The unit is approved for such use by the FCC.

I have a DJI iOSD Mini On

- Screen Display for real

- time flight i nformation installed in the aircraft. This provides me the information while I’m controlling the aircraft such as its pitch, yaw, and roll amounts, velocity, height and distance from take

- off point, plus amount of battery power The User Manual is attached for full details

.

I use a GoPro Hero 4 Black Edition camera to see a live stream from the UAV and record the aerial footage

. The camera with battery and memory card weighs about 3 ounces. I attached the user manual for detailed information about the unit. I do not turn on the Bluetooth signal during flights. I start the recording of the camera before I start the aircraf t. The camera both records to the internal card and sends a signal for live preview simultaneously.

I use a Zenmuse H4

- 3D gimbal that stabilizes the camera during flight. This gives me a more stable image during flight that aids with control of the aircraf t and also provides a much smoother video recording. The manual is attached for detailed specifications of the unit.

I use a monitor on the ground to see the signal sent from the transmitter of the aircraft. Currently the model of monitor I use is the Fly Sight 32 Ch Black Pearl 5.8 Ghz 7” Diversity monitor.

I would like to exercise my privileges t o fly outside the United States of America . I am a US citizen and
have been since I was born in the USA

. One reason I would like permission to fly outside the US is that I live in Michigan close to the great lakes such as Lake Erie

. Sometimes I record footage of the lakes. One
side of the lake is US waters and the other side is Canadian waters. It would make sense to have theoption to fly from the safest positon of the lake. I have crossed the border into Windsor to take photographs and video of Michigan from th e other side in Canada from the ground but have not yet recorded any aerial images out of the country

.

Al so, I currently distribute some other videos internationally. There is a possibility that I may travel to other countries to promote video s , record new footage or whatever needs a client requests

. The exemption would be in compliance with the Standards of the International Civil Aviation Organization (ICAO) and I would make sure to follow those standards and other rules of the country.

I am i n the process of having my unmanned aircraft registered according to the Aircraft Registration requirements and directions provided in 14 Code of Federal Regulations Part 47

.

If I intend to conduct operations such as motion picture and television filming which have existing requirements , I will notify Flight Standards District Offices (FSDOs) pri or to operations to describe the intended coordination in this regard for the proposed operation(s).

Please let me know if I have left anything out in this request. A timely response and approval of this exemption will be the safe st solution to the amateurs not as familiar with UAS and FAA rules currently flying and recording footage around my area. I would follow any modifications, additions or subtracts you send with the approval of this request along with what is already stated

.

Sincerely,

Jeremy salo