Paul E. Ott, d/b/aFlintridgeAerial Services 2455 SLeonine Rd Wichita, KS 67217 peott@prodigy.net August 

### 19, 2015 U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Request for Exemption Per PL 112-95 §333 from 14CFR 61.23(a) and (c), 61.101(e) (4) and 

### (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2) and 91.417(a) and (b) Dear Sir or Madam: With that preface, pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 ("FMRA") and 14C.F.R. Part 11, Flintridge Aerial Services, developer and operator of Unmanned Aerial Vehicles ("UAVS'') equipped to conduct aerial photography/Inspection/included but not limited tothefollowing Commercial Operations:

• Real Estate listings • Yacht brokerage/listings • Private events:weddings, parties, etc

... • Commercials/promotionsfor businesses, communities, golfcourses, marinas, etc. • Agriculture: imagingfor crop health and/or productionestimates • Private land owners: pictures/video oftheirproperty • As needed/requested to support law enforcement and/orfirstresponders Petitioner hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAVs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established by the FAA as required by Section 333. Please consider this a request for an exemption ofthe above applicable sections oftitle 14 CFR for Flintridge Aerial Services forthe purpose ofconducting commercial aerial survey and photography operations with its Unmanned Aircraft System (UAS) within controlled access airspace employing a comprehensive safety, training, and planning 

### 1program. The employment of UAS platforms for these missions should provide the FAA with good cause to find thatthese operations enhance safety by eliminatingthe need to use conventional aircraft in the sometimes unique environments where an UAS would be particularly adept, but a conventional aircraft may pose a hazard to its crew and those on theground. Flintridge Aerial Services requests exemption from the following applicable regulations, pursuant to the Administrator's authorityto grant exemptions contained in 49 U.S.C. § 106(f), 40113, and 44701: 14 CFR 61.23(a) and (c), 14 CFR 61.10(e)(4) and (5), 14 CFR 61.113(a) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.119(c), 14 CFR 91.121, 14 CFR 91.151(a)(l), 14CFR 91.405(a), 14 CFR 91.407(a)(1), 14CFR 91.409(a)(1) and (2), 14 CFR 91.417(a) and (b)
tothe extent necessaryto allow Flintridge Aerial Services to operate a UAS to perform aerial data collection. OPERATION OVERVIEW Our operations utilize UAS in a mannerthat provides services notoffered by manned aircraft or enhances the level ofsafety at which thetasks can be completed in manned aircraft Examples ofthe proposed aerial photography operations include both real estate and insurance damage assessment. Both operations restrict the use ofthe UAS to asmall area typically encompassing a limited numberof residential and commercial properties at atime

.The areas in which theflight takes place can readily be protected with secured access by the staffof Flintridge Aerial Services. The structures on these properties provided sufficient protection from the UAS and can be completed with much less risk than what would be assumed in a manned operation at low altitudes with flammable fuel.

2Our intended film production operation would typically include both photography and videographyfor commercial purposes including real estate development and private events as well as promotional video and commercial production for businesses. These events are restricted to onlythe invited participants and are closed tothe general public, providingthe opportunityto operate only in an area where informed, consenting participants and personnel are present. By adhering to the restrictions and exemptions previously granted to other operators by the FAA, Flintridge Aerial Services will be able to provide a level ofsafety equal to or greaterthan the manned aircraft that would typically provide these services. Our survey operation will include the orthomosaic mapping of both agriculture and construction sites utilizing our UAS rot' orcraftflying pre-programmed grids that can be interrupted and returned to a safe landing zone by our FAA certified pilots at any time

. Currentlythese operations are executed by general aviation aircraft carrying hundreds of pounds offuel and equipmentflying at low altitudes and speeds. Our operation would greatly increase the level ofsafety, replacing large aircraft with an UAS under55 pounds including payload and restricted to speeds no greaterthan 87 knots (100 miles per hour) at altitudes no more than 400 feet above ground level (AGL). These sites are areas that can readily be secured by Flintridge Aerial Services personnel and would not provide any additional risk to the general public. These operations are similar in all material respects tothose ofAstraeus Aerial whom the FAA granted exemption number 11062 underthe regulatory docket no. FAA-2014- 0352. This is similar in all material respects to relief previously requested in grant of Exemptions Nos. 11109to Clayco, Inc. (Docket No. FAA-2014-0507), 11112to VDOS Global, LLC (Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (Docket No. FAA-2014
-0642)

. All of Flintridge Aerial Services operations will be performed by FAA licensed pilots with trained Visual Observers and, where necessary, Site Security Coordinators, in controlled and secured environments only after asafety assessment has been completed and risk mitigation practices reviewed. In orderto perform the aerial data collection with a UAS we propose and agree to be bound to the following: 1 UAV's used in the operation will be limited tothe DJI Phantom 3, DJI Phantom 2, and DJI Inspire 1, which will all weigh less than 55 pounds including payload

. The aircraft are equipped with failsafe protocols that return the aircraft to a predetermined point and land ifany abnormalities are present. The petitioner's UAS has the capability to operate safely after experiencing certain in-flight contingencies orfailures and uses a failsafe mode to return to home and land when connection is lost. The UAS is also able to respond to a loss ofthe global positioning system (GPS) or a lost-link eventwith precoordinated automated flight maneuvers. These safetyfeatures provide an equivalent 

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### level ofsafety compared to a manned aircraft holding a restricted airworthiness certificate performing asimilar operation. Because ofthe UAS' specifications and flight characteristics, it poses no threatto nationalsecurity. No pilot or passengers will be carriedaboard

. Proposed operations ofany other aircraft will require a new petition to amend the exemption

. a) User manuals, safety guidelines and maintenance manuals forthese UAV's are available on-line at www.dji.com for download and review. In the public interest of conservation of natural resources, we have not printed and included the manuals with this petition.
2 There will be no closed-set motion picture and television filming conducted. 3 The UA will not be operated at a speed exceeding 87 knots (100 miles per hour)

. Either ground speed or calibrated air speed will be used to determinethis limitation. At no time will the UA be operated at a speed exceeding the maximum airspeed recommended by the aircraft manufacturer.
4 At no time will the UA be operated at an altitude exceeding 400 feet above ground level (AGL). Altitude will be reported in feet AGL. 5 The UA will be operated within visual line ofsight (VLOS) ofthe PIC at all times. This means thatthe PIC must use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license. 6 All operations will utilize avisual observer (VO). The UA will be operated within the visual line ofsight (VLOS) ofthe PIC and theVO at all times. The VO may be used to satisfythe VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to communicateverbally at all times; electronic messaging or textingwill not be permitted duringflight operations. The PIC will be designated beforetheflight and cannottransfer his or her designation forthe duration ofthe flight. The PIC will ensure thatthe VO can perform the duties required oftheVO. 7 The UAS will be operated within the limitations and accordingtothe guidelines in the User Manuals, Safety Guidelines and Maintenance Manuals published bythe manufacturerofthe UAS. Any additional operating documentswill be available tothe FAA at any time upon request oftheAdministrator

. 8 After maintenance oralterations that affectthe UAS operation orflight characteristics, afunctional testwill be performed priorto conductingfurther 

### 4operations. Functional flighttests will only be conducted by a PIC with aVO and will remain at least 500 feet from other people. The functional testwill be conducted in such a mannerso as to not pose an undue hazard to persons or property. 

### 9 The operatorwill be responsible for maintaining and inspectingthe UAS to ensure that is in a condition for safe operation. 10 Priorto each flight, the PIC will conduct a pre-flight inspection and determinethatthe UAS is in acondition forsafe flight. The pre-flight inspection will account forall potential discrepancies, e.g., inoperable components, items or equipment. Ifthe inspection reveals acondition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating untilthe necessary maintenance has been performed and the UAS is found to be in acondition forsafe flight. 11 The operatorwill followthe UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirementsforthe aircraft and aircraft components. 12 Each UAS operated underthe proposed exemption will complywith all manufacturer safety bulletins. 13 The PIC will hold either an airlinetransport, commercial, private, recreational or sport pilot certificate. The PIC will also hold acurrent FAA airman medical certificate oravalid U.S. driver's license issued by astate, the District ofColumbia, Puerto Rico, aterritory, a possession orthe Federal Government. The PIC must also meetthe flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 14 The operatorwill not permit any PIC to operate unless the PIC demonstratesthe abilityto safely operate the UAS in a manner consistent with howthe UAS will be operated underthe proposed exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vesssels, vehicles and structures. PIC qualification and flight hours and currency will be logged in a manner consistent with 14 CFR 61.51(b). Training flights will be conducted forthe purpose oftraining PIC's and VOs to safely conduct operations permitted underthe proposed exemption. This training will beforthe purpose of building proficiency and experience to insure the safe operation ofthe UAS

. Training will only be conducted during dedicated training sessions. During training, proficiency, and experience-buildingflights, all persons notessential forflight operations will be condsidered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 91.119. 15 No UAS operations will be conducted during night, as defined in 14 CFR 1.1. All 

### 5operations will be conducted undervisual meteorlogical conditions (VMC). 16 No UA operations will be conducted within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) orfor airports not denotedwitin an ARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letterofagreementwith that airport's management is obtained orotherwise permitted by aCOA issued to Flintridge Aerial Services. Ifsuch a letter is obtained, itwill be made available tothe FAA Administrator or any law enforcement official upon request. 17 The UA will not be operated less than 

### 500 feet below or less than 

### 2,000 feet horizontallyfrom acloud orwhen visibility is less than 3 stature miles from the PIC. 18 Ifthe UAS loses communications or loses its GPS signal, the UAS will have capability toreturn to a pre-determined location within the private or controlled-access property. 19 The PIC will abortthe flight in case of unpredicted obstaclesor emergencies. 

### 20 The PIC will not begin aflight unless (considering wind and forecast weather conditions) there is enough available powerforthe UA to conductthe intended operation and to operate afterthatfor at lease five minutes orwith the reserve power recommended by the manufacturer ifgreater. 21. All operations will be conducted in accordance with an AirTraffice Organization Certificated ofWaiver orAuthorization. 

### 22. All aircraft operated by Flintridge Aerial Services will be identified by serial number and registered in accordance with 14 CFR part47, and have identification (N-Number) markings in accordance with 14 CFR part45, Subpart C. Markings will be as large as practicable. 

### 23. All documents used by Flintridge Aerial Services to ensure the safe operation and flight ofthe UAS and and documents required under 14 CFR 

### 91.9 and 

### 91.203 will be available tothe PIC atthe Ground Control Station ofthe UAS any time the aircraft is operating. These documents will be avialable tothe FAA Administrator or any law enforcement official upon request. 24. The UA will remain clear and give way to all manned aviation operations and activities at all times. 

### 25. The UAS will not be operated by the PIC from any moving device orvehicle. 26. All flight operations will be conducted at least 

### 500 feet from all nonparticipating 

### 6persons, vessels, vechicle and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operatorwill ensure that nonparticipating persons remain under such protection. Ifthe situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations will cease immediately in a manner ensuringthe safety ofthe nonparticipating persons; and b

. The owner/controller ofanyvessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closer tothose objects and determined that it does not present an undue hazard. Flintridge Aerial Services will establish and maintain a security perimeterforthe purpose of protecting structures and people not associated with the operation. In establishing the security perimeter, Flintridge Aerial Services will receive the permission ofthe owner ofthe property upon which the ground crew will stage and above which the aircraft will operate, and at no time will the UAS be operated directly over a person. Should the flight take place over public lands, Flintridge Aerial Services will obtain the permission ofthe governing body ofjurisdiction

. Obtaining permission to operate will serve as notification tothe propertyowner orgoverning bodythat operations will be taking place. The UAS will be continuously operated at an altitude which will allow a safe descent and recovery should a mechanical issue arise.

The PIC, VO, operatortrainees or essential persons will be considered "crew" and not subject to the above restrictions. 27. All operations will be conducted over private or controlled-access propertywith permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flightto be conducted.

BENEFITTO THE PUBLIC INTEREST Flintridge Aerial Services will be using battery powered UAS for operations that would normally be used by full size aircraft. The battery operated UAS does not release greenhouse gas emissions and have lower noise levels reducing the risk to the public and an overall benefitto the public interest. In addition these aircraft can replace work that is dangerous and difficult atthe same time providing an equivalent orgreater level ofsafetythan alternative manned aircraft. By providing services that would normally be provided by manned aircraft, Flintridge Aerial Services will not only reduce emissions but may eliminate the need for an aircraft carrying flammable aircraftfuel to fly over 

### 7the populated areas which would benefitthe public interest. Manned aircraft conducting aerial photography operations can weigh thousands of pounds or more and are operated by an onboard pilot and may carry other onboard crewmembers, as well as carry large quantities offuel. The petitioner's unmanned aircraft (UA) weighs less than 8 pounds, including payload. The pilot and crewwill be remotely located from the aircraft. The limited weight and construction reduces the potential for harm to the pubic or damage to property in the event ofan incident or accident. Manned aircraft are at risk offuel spillage and fire in the event ofan incident or accident. The UA carries no fuel, and thereforethe risk offire following an incident or accident due to fuel spillage is eliminated which would benefit the public not only by the elimination of a crew but also the public on the ground at the site ofthe incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UAS forthe proposed operation and will benefitthe public. In conclusion, by granting Flintridge Aerial Services an exemption itwould benefitthe pubic as awhole and be in the best interest ofthe public.

PRIVACY All applicable laws and regulations regarding privacy will be adheredto. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 (size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security) provide morethan adequate justification to grant Flintridge Aerial Services requested exemption, allowingfor Flintridge Aerial Services' UAS commercial operations for the purpose of photography, film and survey pursuant to the operating terms, conditions and limitations as detailed in this appliation.

Owner- Flintridge Aerial Services



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