Bruce Bowsher dba 

### I Eagle's ViewAerial Photography P.O. Box 343 May 7, 2015

Rochester, Ind. 46975 Cell (765) 513-9782 Email: bkbowsher@comcast.net

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJerseyAve., SE. Washington, DC 20590

RE: Exemption Request Section 333 ofthe FAA Reform Act of2012

Attachments: 1) Inspire 1 User Manual v1.0 2) Inspire 1 Quick Startv1.0 3) Inspire 1 Safety Guidelines

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter ofthe petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter ofthe petition ofADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter ofthe petition of FLYING CAM INC

Dear Sir or Madam, In accordance with the FAA's Guidelines forSubmitting a Petition forExemption under section 333 ofthe FAA Modernization andReform Actof2012, I Bruce Bowsher of Eagle's ViewAerial Photography, referred to hereafterasthe petitioner, request exemption from the following sections ofTitle 14, Code of Federal Regulations 

### §§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & {b); In orderto operate small unmanned aircraft systems (UAS) commercially in airspace regulated bythe Federal Aviation Administration (FAA) forthe purposes ofaerial photography, cinematography, videography, mapping, crop surveying, inspections and otherflight operations that could be performed safely and more cost effectivelywith the

use ofsmall UAS atlow altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only atthe request ofand with the authorization and permission ofclients ortheir authorized agents in orderto facilitate

commerce and raise awareness ofthe beneficial uses ofsmall unmanned air systems. So long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. The conditions identified and proposed bythe petitioner are drawn from references 1-3.

Page1The FARs The petitioner seeks exemption from the above mentioned FARs for the following
reasons; 61.113(a) 

### & (b); The petitioner requests relief in ordertofacilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating underthis exemption would be required to complywith any conditions as setforth and in a similar fashion to the previously granted exemptions. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closerthan 500 feet to the ground may require that the UA be operated closerthan 500 feetto essential persons, orobjects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests waiverforthis condition to allow reasonable and responsible operations in areas ofsubdivisions and neighborhoods ifrequired. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeterand instead utilizes electronic GPS with a barometric sensorfor altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted in Exemption Nos. 8811 , 1 0808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percentto the PIC. The UA batteries provide approximately 25 minutes ofpowered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedurewhen battery remaining reaches a specified level. Given the limitations on proposed operations and the location ofthose proposed operations, The FAA found that a reduced minimum power reserve forflight in daytime VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure thatthe UAS is in a condition for safe flight in accordance with the operating documents. The FAAfound that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficientto ensure that safetywould not be adversely affected. The UAS The DJI Inspire 1 is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of 7.495 lbs. (3400 g max) designed primarily to carry alofta high definition camera. It has an advertised maximum

Page2speed of less than 43 knots (22m/s) and a maximum climb rate of less than 1200feet per minute (5 m/s). It is powered by four electric motors with a distance between motors of less than 17.755 inches (451mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distancefrom PIC, camera imagery, and control camera angle. It hasfailsafe modes ofoperation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed bythe PIC. Battery life limits ffight times to approximately 25 minutes. The onboard flight controllerwill warn the pilotvia telemetry and external lighting cues before reaching a low battery state. An automatic termination offlight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated thatflights will usually last less than 10 minutes. More information is available in attachment 1 or http://www.dji.com/product/inspire1 Risk mitigation The petitioner has reviewed FAA exemptions reference's 1-3 Conditions andLimitations section and believes that the procedures specified therein are reasonable and will be utilized in orderto manage and mitigate risk and ensure public safety. A preflight checklistwill be developed and employed to ensure thatthe UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure-prone components. The petitioner requestthat in a mannersimilarto reference 3, he be allowed to operate within 5 miles ofan airport provided that; "The UA maynotoperate in Class B, C, orD airspace without written approvalfrom the FAA. The UA maynotoperate within 

### 5 nauticalmiles ofthe geographic centerofa nontoweredairportas denotedon a current FAA-publishedaeronauticalchartunless a letterofagreement with thatairport's managementis obtained, andthe operation 

### is conductedin accordance with a NOT AMas requiredbythe operator's GOA. The letterofagreement with the airportmanagementmustbe made available to the Administratorupon request." Operations within 5 miles ofan airport are not anticipated to be routine butthe petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested dueto the lack ofmode C transponder. Public interest Use ofthe UAS in lieu ofa manned aircraftwould enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft ofgreater proportions, carrying a crew and flammable fuel. Additionally, use ofthe UAS

page 3in orderto facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners ortheir designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheir desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased

use ofpesticides and fertilizer and conservation ofwater as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitionerwill provide clients with photographic dataforthese purposes on a 'for hire' basis acting as an independent contractor. A visual observerwill be utilized. liability insurance will be obtained commensurate with the granting ofthis request for exemption. Flight data including UAflight time, Control Unit operation time, incident, accident, and details concerning any devii!\ltions from normal operations will be available to FAAfor use in collecting data regarding the use of UAS as part ofthis application. This data may be submitted to FAAvia traditional means, e.g. COA Monthly Reports, or other means as required. Conclusion The petitioner is requesting this exemption forthe purposes of "aerial photography, cinematography, videography, mapping, crop surveying, inspections and otherflight operations". The reason for such a general and broad based request is thatthe petitionerwishes to utilize a business strategy of horizontal integration and maximize economies ofscope in orderto capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner's business model is based on the idea ofoffering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner's own market research shows pent up demand forthese services currently exists in the real estate market and other markets arejust beginning to emerge. Although videography and photography are included in the request, the primary objective will be aerial survey offarm crops for precision agriculture. The petitioner has identified universities and other agencies that could benefitfrom the operation requested in this application. A quick internet search will showthat many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in commercial use ofthe UAS. The primary purpose ofseeking this exemption isto obtain the capabilityto offerthose services while remaining in compliance. The petitioner has 40 years ofexperience in the radio control,model aircraft hobby, 26 years experience in general aviation and holds a Private Pilot license.

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# c Bowsher Eagle's View Aerial Photography