Petition for Exemption/Rulemaking Ikust LLC, Yoshino Sugita

I. The specific section or sections of 14 CFR fr om which you seek an exemption

This r equest adds the Petition for Exemption ( FAA

- 2015

- 0353 ) submitted on Feb. 10, 2015 by Yoshino Sugita, Ikust LLC.
A application of 91.119 ( d ) (1) of Title 14, Code of Federal Regulations to PHANTOM 2 Vision+ quad

- copter unmanned aircraft system (UAS)
An exemption of of 91.119 (b) (c) of Title 14, Code of Federal Regulations to PHANTOM 2 Vision+ quad

- copter unmanned a ircraft system (UAS)

II. The extent of relief you seek, and the reason you seek the relief
The proposed exemption is to operate the PHANTOM 2 Vision+ quad

- copter unmanned aircraft system (UAS) to conduct aerial videography and cinematography including real estate listing picture and videos under 91.119 (d) (1)

. Request below is added to FAA

2015

- 0353 due to the FAA new proposal, DOT and FAA Propose New Rules for Small Unmanned Aircraft Systems, published on the FAA website on February 15, 2015.

Realtor s have always looked for new tools to advertise properties. Online listings have included photo galleries, then satellite images and Google Street View. Many Realtors believe that drone photography is the logical next step. The drone will help not only Rea ltors also to home buyers to make a right decision for their future homes.

FAR 91.119 discuss es about minimum safe altitude. A application of 91.119 ( d ) (1) of Title 14, Code of Federal Regulations to PHANTOM 2 Vision+ quad

- copter unmanned aircraft system (UAS) is requested here.

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitu de of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA.PHANTOM 2 Vision+ is quad

- copter unmanned aircraft system (UAS). It takes off and

lands vertically, hovers, and flies forward, backward, and laterally. According to DIJ, the hover accuracy of the PHANTOM 2 Vision+ is 0.8meter (2.6 feet) vertically and 2.5 meters (8.2 feet) horizontally. Therefore, 91.119 (d)(1) is applicable for PHANTOM 2 Vision+ , and it can maintain less than the minimums prescribed in paragraph (b) or (c) of FAR 91.119.

PHANTOM 2 Vision+ (DJI user’s manual, 2015)
DIJ developed the safety systems that allow PHANTOM 2 Vision+ to fly safely. First, DIJ develop ed a flight limitation system to prohibit the UAV to fly into airport. For detail, please see the attached pdf file.

No Fly Zone defined (DIJ, 2015)

Another safety system is the altitude and distance limit s

. By creating a small boundary o n a property, PHANTOM 2 Vision+ remains in the pre

- programmed zone and fly safely in the zone. It automatically a descent vertically when a GPS signal is lost. In addition, DIJ states that the PHANTOM 2 Vision+ can come back to home with one click command (“go home” function)

.
III. The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a whole;Exempt ion Case #11138 is approved because FAA found that public benefit from the

UAV technology to conduct aerial videography and cinematography including real estate listing picture and videos

. In Exemption Case #11138, the FAA notes that avoidance of areas whi ch are depicted in “yellow” on VFR charts is a practicable step in assuring that operations are not conducted over congested or densely populated areas. However, the use of UAV for the real estate listing picture and videos is unique because it only flies very limited space within the property boundary with a home owner’s consent . The UAV remains on the property boundary, instead of crossing and flying over people and other buildings. As long as the UAV stays close to the house that is photographed, it is s afely operated by a PIC.

Proposed UAV operation area in property boundary

IV. The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek the exemption
Exemption Case #11138 is already approved by FAA on January 5, 2015. All conditions and limitations (item #1

- 29 and 31

- 33) listed in the Regulatory Docket No. FAA

- 2014

- 0481 will be followed.

V. A summary we can publish in the Federal Register, stating:
The proposed exemption follows Case #11138 is approved on January 5, 2015. The PHANTOM 2 Vision+ quad

- copter unmanned aircraft system (UAS) is used to conduct aerial videography. Using Case #11138 as a base, an application of 91.119 (b) (1) of Title 14, Code of Federal Regulations to PHANTOM 2 Vision+ quad

- cop ter unmanned aircraft system (UAS) is requested.

VI. A brief description of the n ature of the exemption you seekThere are two requests in addition to the Petition for Exemption submitted on Feb. 10,

2015 ( FAA

- 2015

- 0353 )

. (1) A application of 91.119 (d) (1) of Title 14, Code of Federal Regulations to PHANTOM 2 Vision+ quad

- copter unmanned aircraft system (UAS) (2) An exemption of of 91.119 (b) (c) of Title 14, Code of Federal Regulations to PHANTOM 2 Vision+ quad

- copter unmanned aircraft system (UAS)
Yoshino Sugita is CFI, CFII and MEI. She is also a member of Houston Association of REALTORS®. She meets all PIC requirements mentioned in item #16 of the conditions and limitations in the Regulatory Docket No. FAA

- 2014

- 0481.

Item #16 of the conditions and limitations P rior to operations conducted for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations under the exemption; 5 hours make and model time may be included in the 10 hours of multi

- rotor time prescribed above. The PIC must accomplish 3 take

- offs and landings in the pr eceding 90 days (for currency purposes). Training, proficiency, experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119.

It will not be used outside of USA at this time.
Yoshino Sugita Ysugita.aerospace@gmail.com 832

- 691

- 17 9 6