U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12

‐ 140

Washington, DC 20590



### RE: Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and

Part 11.81 of the Federal Aviation Regulations

Docket ID:_________

___________

September 15, 2015

Petitioner:

Rocky Mountain Aerial Studio

Zachary Hammett

34838 Forest Estates Rd

Evergreen, CO 80439

Tel:(214)537

‐ 8964

Email: zachhammett@mac.com

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and

14 C.F.R. Part 11.81, Rocky Mountain Aerial Studio, hereby applies for an exemption from the listed

Federal Aviation Regulations (“FARs”) to allow commercial operation of its small, unmanned aircraft for

general photography and real estate applications. All operations shall be conducted within and under

the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted

in compliance with the attached operator’s manuals. No commercial operations have been conducted

thus far and will not be conducted until a petition is granted.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFR Part 91:

i. 91.103

ii. 91.105

iii. 91.109(a)

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.203(a) and (b)

viii. 91.405

ix. 91.407

x. 91.409

xi. 91.4172. Relief Sought:

a. Rocky Mountain Aerial Studio wishes to operate small Unmanned Aircraft Systems (sUAS) for

commercial purposes to include (but not be limited to) general photography and real estate.

This relief is sought because commercial use of sUAS is currently prohibited by law unless

performed under an exemption.

b. This exemption will cover use of the following airframes, all of which weigh less than 55 lbs

including payload and energy sources:

i. DJI Inspire 1 (see www.dji.com/inspire

‐ 1 )

ii. Other models to be added by future amendment to this exemption

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by use of

manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure

inspections) and due to other dangerous activities that can be avoided.

ii. Reduces cost of obtaining such information, which benefits consumers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from

manned aircraft

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and part

45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All

repair and maintenance work will be conducted or approved by qualified personnel such as

those approved by DJI (or equivalent), and will require a test flight after such work. Records of

all maintenance and repair work will be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will

maintain verbal communication capability with each other at all times during the flight, and who

will remain stationary on the ground during flight operations:

i. A pilot in command(PIC) who possesses the following credentials

1. An Airman Certificate issued under 14 CFR 61

2. A third Class Medical Certificate issued under 14 CFR 67

3. A bi

‐ annual flight review under 14 CFR 61.56

4. At least 25 hours of flight experience in a UAS rotorcraft. Such hours may be gained

during flights under this exemption if a safe distance is maintained from persons in

accordance with 14 CFR 91.119

5. At least 5 hours of flight experience and 3 take off and landings in make and model

being flown in the past 90 days. Such cycles and hours may be gained during flights

under this exemption if a safe distance is maintained from persons in accordance

with 14 CFR 91.119

ii. A visual observer

iii. A sensor operator as necessaryd. All flight operations will be conducted in accordance with valid Certificates of Authorization

e. All flight operations will comply with the following

i. The manufacturers’ user manual

ii. Rocky Mountain Aerial Studio’s Flight Operations Manual (FOPM) and manufacturers

Aircraft Flight Manuals (AFM) which include lost communication and other emergency

and safety precautions

iii. Conducted in VMC conditions during daylight hours

iv. PIC and VO will maintain VLOS at all times

v. Pre

‐ flight inspections and safety risk assessments will be conducted prior to each flight

vi. Flight altitudes will remain below 400 feet AGL

vii. Flight ground speeds will not exceed 50 knots

viii. Not intrude into class B, C or D airspace, or published approach, SID or STAR, or take

place within 5 nautical miles of an airport

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the

ground without their prior permission

x. Each Flight will be logged in both the PIC’s logbook and the aircraft logbook

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 20 minutes, whichever

occurs first

xii. Any incidents will be reported immediately

xiii. Any applicable local FSDO requirements

xiv. All other applicable regulations concerned with the operation of aircraft

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well

‐ defined

and tested lost link procedures

Please advise us of any additional information or changes that may be required.

Sincerely,

Zach Hammett

Rocky Mountain Aerial Studio