Robert Frank

R Frank Photography

4320 Miller Ave
Erie, PA 16509

814

- 520

- 3985 rob@rfrankphotography.com

R e: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam I am submitting this petiti on on my own, on the behalf of my company R Frank Photography

, without the aid of legal council.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, R Frank Photography (RFP) which is ow ned and operated by Robert Frank, a sole proprietor LLC , operating in the State of Pennsylvania.

Robert Frank who has been building and operating Small Unmanned Aircraft Systems for the past 5 years, wishes to apply for an exemption from the Federal Aviati on Regulations (FAR) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are

conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit RFP to pursue its commercial interests in providing services to companies interested in aerial data that can only be captured by using newly developed sUAS in the following areas:

 Surveying and 3D aerial mapping  Agriculture crop assessment and growth patterns  Golf course management  Insurance company claim assessment  Special events  Construction site and ecological impact assessment

RFP asserts that all sUAS flights that w ill occur over private or controlled access property will do s o with the property owner’s consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where flight activity is taking place. Additionally, I have extensive flight time logged with sUAS

d evices. Our observers will attend ground school to be taught the rules and regulation as they pertain to operating private aircraft under Visual Flight Rul es (VFR) over civilian population areas as described and set forth in the Aeronautical Information Manual.

The substance of this request is essentially the same as that granted to Falcon

Sk y Cam Regulatory Docket No. FAA

- 2014

- 0884 in that RFP is engaged in aerial photography and videography of land, buildings, and insurance claims, by using remote controlled sUAS to see the condition of fields, crops, ecological impact, and financial

losses do to destructio n by fire and other natural disasters, without the need to driveover or climb on the property being so assessed. RFP has a sUAS equipped with cameras for aerial photography including video and still pictures and special lens adaptation s to make them very accurate in the 3 D mapping activity. In doing so we have the ability to produce high

- resolution photography of remote locations that would be difficult or dangerous to reach on foot. This would be especially problematic while doing los s claim work for insurance companies. RFP ’ s exemption request would permit us to operate lightweight, unmanned (remotely controlled in line of sight) sUAS’s in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation as well as Global Positioning Satellite (GPS) navigation maps which incorporate restricted, no fly zones and control zones of airports, will allow EAI to operate within current safety parameters as well as the new ones being implemented.

The Extent of Relief EAI Seeks and Its Justification for Such Relief: Regulation from EAI request exemption: 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.205(b)

14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)

Unmanned Aircraft System sUASs are seen as a better photographic platform to helicopters because these smaller

devices are less expensive, they produce less noise, and they have much less

e nvironmental impact and are less likely to cause injury to the public and or property.

I am petitioning for exemption to enable EAI to operate DJI Phantom 3

, equipped with a proprietary 3 axis gimbal and camera system . This sUAS has a built in capacity to limit the height it flies above the ground, to limit the radius of the distance it flies from the
operator and to exclude it for Class B, C, and D airspace including No Fly Restricted

Zones. The Phan tom 3 also has the failsafe feature of the Naza

- M autopilot system

which means when the communication between the main controller and the transmitter is lost, the Phantom will return to the home starting point and land safely.

The above specifications meet w ith the Model Aircraft Operating Standards as set

below:

 The petitioner will only operate its sUAS in line of sight of a pilot/observer and will

operate at sites that are sufficient distance from populated areas within the sterile area

described in the F OPM. Such operations will insure that the sUAS will not create a

hazard to users of the national airspace or the public. When flying sUAS within 3 miles of an airport, airport operators will be notified and

the operator will give the right of way to avoi d flying in the proximity of full scale aircraft.

 Maximum flight time for each operational flight will be 25 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the

30 minute limit.

 The sUAS will be programmed so it will not be operated at an altitude of no more than

4 00 feet AGL, and not more than 200 feet above a fixed platform from which operations

are conducted.

 The minimum crew for each operation will consist of the sUAS pilot and the Visual

Observer.

 The sUAS will weigh less than 55 pounds including its payload of camera and gimbal.

 The sUAS will fly no more than 50 knots and can hover plus move horizontall y and vertically.

 Given the small size of the sUAS, and the restricted airspace within which it will operate, I believe our sUAS operations will comply with both the spirit and the rules intended by the Reform Act safety requirements.

As part of this request for exemption, RFP give s personal assurance that all persons

involved in aerial operations have completed sUAS education and trai ning including all applicable regulations and guidance documents.

I respectfully request exemption under Section 333 to enable RFP to operate efficient,
limited, low risk commercial sUAS operations for the activities stated, respecting at all times, the spa ce and privacy of citizens and property as we keep our skies safe.

Sincerely yours,

Robert Frank

R Frank Photography

4320 Miller Ave

Erie, PA 16509

814.520.3985
rob@rfrankphotography.com