U. S. Department of Transportation

Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

June 8, 2015

Dear Administrator,

I, Jonathan M. Petro

, company owner and s UAS pilot, herein referred to as the petitioner , am writing pur suant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, t o request that the petitioner

, owner and operator of three small unmanned aircr aft system (sUAS), request exempti on from the Federal Aviation Regulations listed below and any re gulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations as described.

The r equested exemption would warrant said petitioner to safely and professionally provide for

profit services to both private and public entities within the State of Michigan and neighboring
states , utilizing one to three of the small unmanned aircraft system s for aerial still and video data capture f or, but not limited to the following purpose:

- Ae rial Property Survey (Video and/ or Photo)

- Aerial Resident ial/Commercial Roof /Gutter inspections

- Aerial Flare Stack inspections

- Aerial Agricultural Survey/ Crop Inspection /Crop Loss Inspection

- Aerial Real Estate Videography/Photography (Related to Sales)

- Aerial Videography/ Photography of outdoor recreational activities /events * *

- Fire , Flood and or Natural Weather related Damage Survey

- Construction/Development (Structural Inspection)

- Search Assist to all entities (Private, Local and or Public)

** Disclaimer The petitioner ’ s company, I nnovative Aerial Media, provides aerial cove rage of outdoor recreational activities and events for contracted parties.

Since the creatio n of Innovative Aerial Media (formally Great Lakes Aerial Photography), on 08/26/ 20 14, the petitioner has been dedicated to taking any and all measures necessary to ensure that Innovative Aerial Medi a (I.A.M.) holds the safety of the general public as its highest priority. I

. A

. M

. is committed to conducting all operations in a man ner that sets a positive example for other companies intending to conduct business in a similar market. I

. A

. M

. ’s objective is to encourage other sUAS operations to take the appropriate measures to operate legitimately and in compliance with all regulations set forth by the FAA

. In support of this effort

, the petitioner purchased a 500 thousand do llar liability insurance policy, Certificate #: CL1552000472 , (Included as PDF document attachment “I

. A

. M

. Liability InsuranceDocument.PDF”) from the MRF

- Meadowbrook Insurance Group on 8/29/2014 , currently

effective today.

In addition, the safe i ntegration of s UAS into national airspace

, without out the risk of interference and/ or hazard to manned aircraft

, is paramount in the execution of any and all I

. A

. M

. related activities. I n the very first week of I.A.M. ’s establishment

, the petitioner made it a priority to contact all local law enforcement agencies and off icials (specifically Portage and Kalamazoo County offices in Southwest Michigan ) to discuss the use of (sUAS/UAV) in great detail as part of his ongoing effort to create a positive working relationship with in t he community

. The petitioner

, and all contracted employees , conduct business in a manner that is
courteous , respectful

, and aware of the privacy rights of citizens

. I

. A

. M

. is and has been committed to safely and professionally providing this new and unique service to the Sout h west Michigan region while always operating within the legal guidelines of the law since August of 2014

. Due to the risks and costs involved with manned aircraft, I.A.M. fulfills a service that would otherwise not exist to consumers and entities, big and small . We offer services with the knowledge that current manned aircraft operations pose a much greater risk of personal injury and/ or death and extensive property damage

. I.A.M. provides services with the intent of continuously enhancing the development and safe operation of unmanned aircraft systems.

The first sUAS th at I

. A

. M

. is requesting to operate and utilize in any and all service s stated above is a consumer

- class m ultirotor

, quad

- rotor aircraft. The aircraft is a Bumb l e B ee 550 (less than 10 pounds total in weight ) with all on board components manufactured by DJI. The Bumblebee utilizes the DJI NAZA M

- V2 Flight Controller ( which is controlled by the DX7s 7

- Ch DSMX Radio System with AR8000 Receiver )

. T his system h as advanced settings that allow for extraordinary stability as we l l as automatic GPS cou r se correction , GPS lock, altitude, position hold stabilization, smart mode, follow me mode, emergency land mode

, and land home safe mode

. The state

- of

- the

- art safety features literally re

- track the sUAS ’s exact flight route using the g round station software to guide the machine back to its original take

- off loc a tion

, while focusing on precise elevations and position waypoints to eliminat e the possibility of collision with obstruction s that could potentially occur with other sUAS models . For example, less advanced automatic safety systems often utilize a “direct return home ” safety feature , which guides the machine directly from its current position to it s initial point of take

- off, neglecting to factor in the potential for collision with tall objects

.
The ground station consists of ground

- breaking features that are vital to the operation, safety , and in

- flight information of t he sUAS

. These features include tele metry sensors that monitor altitude, groundspeed, G PS location

, and battery life for both the transmitter and airc raft

, as well as an audible and vibration alert for aircraft low battery. I n addition, the sUAS features Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. T he s UAS has the ability to link with a smartphone or tablet for video link separate from the on

- board display

, if needed. In addition

, all three sUAS machines are equipped with the DJI Lightbridge HD vide download system, which provides real

- time , wireless HD video display for up t o two miles (in optimal conditions). This is a very advanced video downli nk system that I.A.M. purchased separately and to both the Bumblebee 550 and the Phantom 2, Vision Plus (as it is very expensive and is not i n cluded with the stock models). However, the DJI inspire

- 1 does comewith the DJI Lightbridge HD Video Downlink as its primary stock wireless video transmission

system.

The second sUAS th at I

. A

. M

. is requesting to operate and utilize in any and all service s stated above is a consumer

- class m ultirotor

, quad

- rotor aircraft. The aircraft is a DJI Phantom 2, Vision Plus. The high capacity, high performance 5200mAh Lithium Polymer battery offers up to 25 minutes of flight time. It provides battery capacity data, over charge/discharge protection, as well as maintenance reminders making the battery extremely safe and reliabl e

. The upgraded remote control comes with many new features. A gimbal control dial, trainer port, built

- in rechargeable LiPo battery with a capacity of 2000mAh, battery le vel LED indicators and throttle

- locking feature that holds the throttle stick in plac e when descending are all included. The new remote control is compatible with the Phantom 2 Vision+ and Phantom 2

. A new, anti

- static compass has bee n developed, with a protective shell to hel p shield the sUAS during all flight conditions

. An integrated GPS auto

- pilot system offers position holding, altitude lock and stable hovering to focus attention on capturing video f ootage.

If the Phantom 2 and its controller are disconnected during flight, the system’s failsafe protection will activate, aut omatically alerting the pilot when optimal signal is reached , the Phantom 2 also includes a return

- home and land automatically feature. A one

- key Go

- Home function can be installed to activate this feature manually. In order to increase flight safety and prevent accidental flights in restricted areas, the new firmware for the Phantom 2 series includes a No Fly Zone feature.

The third sUAS th at I

. A

. M

. is requesting to operate and utilize in any and all service s stated above is a consumer

- class m ultirotor

, quad

- rotor aircraft. The aircraft is a DJI Inspire 1

- it is one of the m ost advanced sUAS systems DJI has ever produced weighing in at under seven pounds

. The petitioner requests exemption to operate a BumbleB ee 550 frame e quipped with the DJI NAZA M

- V2 fligh t controller, equipped with a three

- axis H33D Gimbal and GoPro Hero 3 Plus

Black Addition Camera . The DJI Phantom 2 Vision Plus with ground station software and GPS safety systems and l astly , the DJI Inspire

- 1 , which is one of the most advanced multi

- rotor

consumer quadcopters manufactured b y DJI in history. The DJI Inspire

- 1 has all of onboard safety features as the Bumblebee 550 and DJI Pha ntom 2 Vision Plus, with far more advanced upgrades and features

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner will

—
a. Only operate its s UAS in direct visual line of sight of the pilot. b. Never operate at altitudes greater than 400 ft

. c. Always take

- off and land sUAS in a pre

- designated are a that is blocked off with rope, cones, ect. a nd secured by at least two qualified safety crew members. d. Operate over private or public sites only with prior pe rmission from property owner or owner’s agent or legal authorities as allowed by law. e. Termina te or postpone a scheduled flight wh en any unsafe condition exists , such

as high wind speeds and or rain/thunderstorms.f. Operate at a ground speed of no more than 15 mph

.

g. Terminate flight when battery voltage drops to 4 0% of flight time

. h. Operate in accordance with the guidance and standards set forth by the FAA, AMA, the s UAS manu facturer and the administrator. i

. N ever operate any sUAS machine on a contracte d job that is not fully covered under I.A.M. ’ s l iability insurance policy.

. The petitioner requests exemption from 14 CFR part 61.113 Priv ate Pilot Privileges, Pilot in Command Section (a). Although the pe titioner is a current certified comm ercial pilot the petitioner may elect to utilize certified privat e pilots with class III medical to conduct ope rations with the sUAS. In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determ ine d that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect oper ations in the NAS or present a hazard to persons or property on the ground. The petitioner requests the same consideration and limitations as previousl y granted.

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthines s Certificate is available for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the manufacturer’s documents for determining compliance of the sUAS airworthin ess. The petitioner warrants compliance to part 91.7(b) in that the operation will only be conducted aft er a thorough preflight and pre

- m ission planning inspection is completed, to include current and forecast weat her, ai rspace, notams, area of operations, and notice issued to

non

- participating persons in local proximity. T he petitioner will utilize the Yuneec, Q500 Instruction M anual, quick start guide and the petitioner ’ s own pre

- flight checklist included in the attached supplements to determine the sUAS airworthiness.

The petitioner requests exemption from 14 CFR part 91.1 19(c) Minimum Safe Altitudes

. The petitioner requests exemption from Section (c) with the following co nditions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate below 400 feet AGL. The Petitioner ’ s primary mission would be to record data or survey of persons, property or structures as listed above. The sUAS size, weight,
spe ed and limited operating times and area, as well as the soft materials used in the construction of the sUAS, would provide an equivalent or greater level of safety as intended under this part. The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, genera l definitions. The sUAS has a 4 vertical to near vertical descent in the event of a power failure. Fly

- a

- ways wo uld be the greatest or most dangerous risk to non

- participating persons. The Q500 has no documen ted (fly

awa y), while operated under GPS lock within the parameters of the Q500 operating instructions. The Q500 is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compare d to similar sized s UAS. In an emergency the sUAS would be q uickly brought down per the loss of control procedure as described in the emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 15 mph operational groundspeed of the Q500. The risk to persons 100 feet aw ay woul d be at no greater risk than persons located 500 feet away. The petitioner requests exemp tion from the 500

- foot altitude

res triction and the 500

- foot stand off restriction from persons, property or ves sel applied to previous grants of exemptions.The petitioner requests exemption from 14 CFR Part 91.121, Altimet er settings . The s UAS

will not have a typical barometric altimeter onboard the aircraft, the petitioner in tends to operate the s UA S within VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the s UAS, has been previously ruled to be a sufficient method for ensur ing the s UAS operations do not adversely affect safety. The altitude in formation will be generated by GPS equipment installed onboard the aircraft, and/or a static pressure sen sor (barometer), which aids in estimating the altitude.

The petitioner requests e xemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions, prior relief has been granted for manned aircraft to opera te at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, s imilar

s UAS

- sp ecific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that ind icate the PIC must command the UA’s return to the launch point when low ba ttery capacity voltage is reached. The UAS also provides 2 and 3 rd increased intensity critical low battery warnings through audio and vi bration indicating that the UA must be landed immediately, additionally a failsafe automatic landing wil l occur when t he battery is at absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon battery alert or no longer than 1 2 minutes whichever occurs first. The petitioner will not initiate a flight unless (conside ring wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 4 0% battery power remaining.

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401

- 417),) Maint enance required, 91.407(a ) ( 1) Operation after maintenance, preventive maintenanc e, rebuilding, or alteration, 5 91.409(a ) ( 1) and (2) Inspections, and 91.417(a) and (b) Maint enance records.

Sincerely, Jonathan M. Petro Innovative Aerial Media 10911 Cressey Road Plainwell, MI 49080