October 27, 2015 U
. S. Department ofTransportation Docket Management System 1200 NewJersey Avenue, SE Washington DC 20590 

### Re: Exemption Request§ 333 ofthe FAA Reform Act ofthe Federal Aviation Regulations from 14 CFR § 21; 61.113 (a) & 

### (b); 61.133 (a); 91.7 {a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 {a); 91.203; 91.405 (a); 91.407 {a) {1); 91.409 (a) (2); 91.417 

### (a) & 

### (b).
Dear Sir or Madam, Pursuant to § 333 ofthe FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 C.F
. R
. Part 11, Maine Aerial Photography Services, LLC, operator ofSmall Unmanned Aircraft Systems (sUAS) equipped to conduct aerial filming and photographingto include: commercial and residential real estate, infrastructure inspections, construction, architecture, scientific research, environmental assessment, land surveying and mapping and other applicable areas for pre-planned, controlled areas, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by§ 333., Maine Aerial Photography Services, LLC operation of its sUAS for commercial purposes awaits a review and the anticipated granting ofthis petition by the FAA before conducting any operation for its clients to fully comply with all federal aviation regulations pertainingto sUAS
. As described more fully below, the requested exemption would permitthe operation of small , unmanned and multi-rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on-site safety personnel controlling access, and 4) would provide increased safety and enhancements to clients business operations. I am prepared to modifyor amend any part ofthis request to satisfy the need for an equivalent level of safety
. I look forward to working with your office. Please contact me at any time ifyou require additional information or clarification
. The name and address of the applicant is: Maine Aerial Photography Services, LLC Tyler S
. Plummer, President Phone: 207-798-1113 Email: tyler
.plummer@gmail. c om Address : 28 WileyWoods Way, Walpole ME, 04573
1

### PUBLISHABLE SUMMARY The following summary is provided for publication in the Federal Register, should it be determined that publication is needed. Maine Aerial Photography Services, LLC seeks an exemption pursuantto 14C.F. R. § 11
.61 and Section 333 ofthe FAA Modernization and Reform Act of 2012 from the requirements of 14 CFR § 21; 61.113 (a) & (b); 61.133 (a) ; 91.7 (a); 91 .9 (b) ; 91.109 (a); 91
. 119 (c); 91.121 ; 91
. 151 (a); 91 .203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); and 91.417 (a) & (b). This exemption request will permit Maine Aerial Photography Services, LLC to operate its sUAS commercially forthe purpose of aerial filming and photographing to include: commercial and residential real estate, infrastructure inspections, construction, architecture, scientific research, environmental assessment, land surveying and mapping. MaineAerial Photography Services, LLC will provide a service that is beneficial to industries and organizations that are already using, and/orseeking to use, sUAS's for these purposes with a legal and safe option. This will benefitthe public with the controlled operation of sUASs and increase their integration into the NAS
. The requested exemption should be granted because the proposed operation of the DJI Inspire 1 , a small UAS (sUAS) weighing 6lbs. 

### 7.52 oz., inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent or better level ofsafety, as Congress intended, while still allowing commercial operations. The lightweight aircraft covered by the exemption is far safer than conventional operations conducted with helicopters and fixed-wing aircraft operating in close proximityto the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line ofsight- each support the request. In particular, the aircraft is small, and will operate at slow speeds, close to the ground, farfrom airports and in a low risk, low and controlled population environments
. Name and address ofpetitioner: Maine Aerial Photography Services, LLC Tyler S. Plummer 28 Wiley Woods Way Walpole Me, 04573

2BACKGROUND OF PETITIONER MaineAerial Photography Services, LLC is a limited liabilitycompany owned and operated by Tyler Plummer. Mr
. Plummer has practiced recreational photography forthe last decade honing his photography skills. He has been flying the 

### OJ I Inspire 1 for a few months learning its capabilities, performing the necessary flying skills, and practicing using the sUAS in safe manner. Mr. Plummer has spent countless hours researching the industry and safety protocols
. This will help to ensure a successful safe commercial sUAS business
. The integration ofsUASs into the National Airspace System (NAS) has the prom ise and potential to be equallytransformative in the ways in which the public, educational and research institutions, businesses and non-profits pursues their interests and goals
. MaineAerial Photography Services, LLC will conduct its business using the 

### OJ I Inspire 1 sUAS. The Inspire 1 is a vertical takeoff and landing sUAS with a maximum gross weight of less than 55 pounds and a maximum speed of less than 50 mph
. The Inspire 1 is driven by lithium polymer batteries and powered by electric motors. The aircraft registration application and all required supporting documentation for this sUAS will be forwarded to the FAA Aircraft Registration Branch, AFS-750, P.O
. Box 25504, Oklahoma City, OK 73125- 0504. PUBLIC INTEREST AND HOWTHE PUBLIC WILL BENEFIT This exemption request will permit Maine Aerial Photography Services, LLC to operate its sUAS commercially for the purpose of aerial filming and photographingto include: commercial and residential real estate, infrastructure inspections, construction , architecture, scientific research, environmental assessment, land surveying and mapping and other applicable areas. Maine Aerial Photography Services, LLC will provide a service that is beneficial to industries and organizations that are already using, and seeking to 

### use, sUASs for these purposes with a legal and safe option. This will benefitthe public with the controlled operation ofsUASs and increase integration into the NAS. Granting the present petition will further the public interest by allowing Maine Aerial Photography Services, LLC to perform safely, efficiently, and economically, aerial video and photography of construction sites, real estate, and landscape over certain areas ofthe United States. Additionally, use of the 

### OJ I Inspire 1 sUAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. The integration ofsUASs into the NAS will not only replace traditionally more expensive options or approaches, itwill enable workto be done and decisions to be made in ways thatwere simply impossible to do previously
. The commercial deployment ofsmall unmanned aircraftsystems offers the public a new, highly efficientand relatively inexpensive platform for collecting, analyzing and utilizing data and photographic/video imager y. 

### 3In deploying its sUAS, Maine Aerial Photography Services, LLC has developed specific performance standards, operating requirements, protocols and work processesthat are aligned with the FAA's continuing mission, and result in safe operating practices that are consistently applied and continuously improved. For its part, Maine Aerial Photography Services, LLC recognizes the important role it plays in educating the public and building awareness of both the promise and precautions that accompany the commercial deploymentofthis new and exciting platform. The sUAS utilized by Maine Aerial Photography Services, LLC is battery-powered and serves as a safe, efficient and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. A grant ofexemption would allow Maine Aerial Photography Services, LLC to contribute to the reduction of manned aircraft needed to perform the aerial acquisition ofdata, video and photographic content and subsequently reduce the volume of manned aircraft in the NAS
. Conducting aerial acquisitions with the DJIInspire 1 sUAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photographyflight operations. By using battery power and electric motors, the DJIInspire 1 sUAS produces no air pollution, and is the most viable environmentally conscious alternative tothe cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJIInspire 1 sUAS, while reducing the carbon footprint ofaerial acquisitions, also sharply reduces noise pollution, as the sUAS is propelled by battery powered electric motors, ratherthan an internal combustion engine. By using the DJIInspire 1 sUAS to perform aerial acquisitions, the substantial riskto life and property in the air and on the ground, which is usually associated with traditional manned aircraftflight operations, will be drastically reduced or completely eliminated. The DJI Inspire 1 sUAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross weightwith a length of 17.3 inches and width of 17.7 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraftthat typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). Previously, such services as high-resolution digital aerial real estate photography, surveying and inspections were limited and affordable to a relatively small group ofagencies, companies and organizations with significant operating capital. The granting ofthis exemption will enable Maine Aerial Photography Services, LLC to change this by deploying its sUAS in ways that make aerial photography and other sUAS services accessible and affordable to a significantly larger portion of individuals, organizations and businesses
. The many new forms of aerial content would have immediate and direct benefits to service providers, business owners and consumers alike.


### 4PUBLIC SAFETY With safety as its primary operational requirement, MaineAerial Photography Services, LLC will plan, conduct and manage itsflight operations within very specific and well-defined operating limitations and standards detailed in its flight checklists and operating protocol (see Attachment G). These protocols also clearly define the roles and responsibilities ofthe pilot in charge (PIC), visual observer (VO) and the client representative working with Maine Aerial Photography Services, LLC. In seeking this exemption, Maine Aerial Photography Services, LLC submits thatthe DJIInspire 1 sUAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by the characteristics of the DJIInspire 1 sUAS, the pilot certification requirements, and the specific operating limitations. The specifications ofthe DJIInspire 1 sUAS (see Attachments A and B) demonstrate its safe characteristics. The DJIInspire 1 sUAS does not create a hazard to users ofthe NAS or the public, orotherwise pose a threatto national security considering its size, weight, speed, and operational capability. Many ofthe functional capabilities and features ofthe DJIInspire 1 sUAS enable itto be operated in a highly controlled, precise and safe manner. The DJIInspire 1 sUAS autonomousflight and navigation modes enable itto remain within a defined operational area. Also, the DJI Inspire 1 sUAS may be operated in both manual and fully autonomous flight modes. A complete description oftheflight and navigational modes ofthe DJIInspire 1 sUAS is provided on pages 12-16 and 45-50 ofthe DJIInspire 1 User Manual (see Attachment B)
. The DJIInspire 1 sUAS includes automatic return-to-home-point or hover functionality inthe event of loss ofthe control link or navigation. When the control link is lost, the DJIInspire 1 sUAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJIInspire 1 sUAS does not reacquire control link data from the ground control station/remote controller, the sUAS will assume that the control link is lost and will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description ofthe failsafe functions ofthe DJIInspire 1 is provided on pages 13-15 ofthe DJJ Inspire 1 User Manual (see Attachment B)
. Whether helping to protectthe public, inspecting infrastructure, conducting site and land surveys or acquiring aerial imagery and video, Maine Aerial Photography Services, LLC will be providing its customers with more accurate and timely information
. The real -time situational awareness and improved decision-making this achieves will enable Maine Aerial Photography Services, LLC's customers and clients to communicate with and more safely serve and support their respective constituents. Strict adherence to specific flight operations protocols (see Attachment G), the use ofthe DJIInspire 1 sUAS configured with significant safety functionality, the acquisition of an accurate understanding of both the flight operations area and its adjacencies using Maine Aerial Photography Services LLC's Pre-Flight Safety Briefing and On-Site Flight Plan(see AttachmentJ), and the use of Maine will provide a level ofsafety and oversightthat is in complete alignmentwith the FAA's mission to "provide the safest, mostefficient aerospace system in the world." [FAA online document, Public Guidance for Petitions for Exemption Filed under Section 333. Rev. 9/25/2014] 

### 5

### PRIVACY All flights will occur over private or

**controlled~access** property with the property owner's or controlling authority's prior consent and knowledge. Aerial photography and video capture will be of people who have provided their written consent (see Attachment K) to being photographed or have been authorized to be in the area where flight operations aretaking place. Establishing and maintaining tight controls over access to theflight operations area will minimize privacy issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Maine Aerial Photography Services, LLC's proposed operation ofthe DJI Inspire 1 sUAS will not implicate any privacy issues. Specifically, the OJI Inspire 1 sUAS will be operated under detailed operational protocols designed to ensure client or property owner involvement as well as local law enforcement notification
. Flight operations will be conducted in accordance with Federal Aviation Regulations, including the minimum altitude requirements of 14C.F
.R. § 91.119
. Maine Aerial Photography Services, LLC has developed a Pre-Flight Safety Briefing and

**On~Sight** Flight Plan protocol template (see AttachmentJ) that will be completed and reviewed with the client's onsite representative priorto the commencement ofany operation or project. This detailed diagram ofthe operational environment will providethe PIC}, VO(s), and any other designated support and security personnel with a full understanding ofthe site orsubject's structural characteristics, layout, topography, adjacencies, and all significant and relevant natural and

**man made**  features within the operational area. This will enable Maine Aerial Photography Services, LLC to acquire a detailed understanding ofthe larger geographical context surrounding the flight operations area and review relevant factors with the client before the commencement ofany work or service. 

### CONDITIONS AND LIMITATIONS As set forth in Maine Aerial Photography Services, LLC Flight Operations and Procedures Manual (FOPM), which includes: All manufacturer documentation forthe Inspire 1 sUAS and Maine Aerial Photography Services, LLC proprietary operations documentation for all sUAS operations (e.g., Flight Checklists and Operations Protocols, Pilot Flight Log, sUAS Flight Log, Monthly Maintenance Log, PreFlight Safety Briefing and On-Site flight plan, and Permission to Conduct Onsite Flight Operations Consent Form), the applicant proposes the following limitations and conditions: 1 . UAS must weigh less than 55 pounds; 2. UAS airspeed is notto exceed 50 knots; 3. UAS flights may not operate at more than 400 AGL. Altitudes reported toATC must be in feet AGL; 4. UAS must be operated within Visual Line ofSight (VLOS) ofthe PIC and VO; 5. All operations will utilize aVO. The VO may be utilized as long as the PIC maintains VLOS capability and can communicate with the VO at all times; 6. The operator's manuals and flight operations protocols will be amended to and revised as new conditions and/or limitations become known; 67. The PIC will conduct a full inspection ofthe sUAS (including remote controllers) to ensure it is in full working order and safe for flight prior to every takeoff; 8. A functional testflight must be performed followingthe maintenance, alteration or repair ofany sUAS
. Tes t flights will be performed by the PIC prior to the sUAS's return to service. All such test flights will be noted and logged in the Monthly Maintenance log(see Attachment 

### 1), the PIC's personal Pilot Flight Log (s ee Attachment L) and the sUAS Flight Log (see Attachment H)
. 9. The operator mustfollow the manufacturer's sUAS aircraft/component, maintenance, overhaul, replacement inspection and life limit requirements
. The following must be included in the operator's manual ; a. Actuators /Servos; b
. Power plant (motors) ; c. Propellers; d
. Electronic speed controller; e. Batteries ; f
. Mechanical or dynamic components; g. Remote command and controller(s); h. Navigational screen/interface; and any other component(s) as determined bythe operator. 10. The PIC must possess at minimum a light sport pilot certificate and a val id U.S
. driver's license. Additionally, the PIC must meetthe flight review requirements specified in 14 CFR § 61.56; 11. A PIC mus t have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight hour s and 25 hours as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar sUAS type; 12. A PIC mus t have accumulated and logged, in a manner consis tentwith 14CFR § 61.51(b), a minimum offive hours as a sUAS pilot operating the make and model ofsUAS to be utilized for operations under the exemption and threetakeoffs and three landings in the preceding 90 days
. The PIC must operate the sUAS w ith appropriate distance from nonparticipants in accordance with 14 CFR § 91
. 119; 13. The PIC and VO must have completed a qualification process; 14. A flight demons tration, adminis tered by an operator and a qualified pilot must be completed and documented in accordance with the operator's manual; 15. The sUAS may not be operated directly over any person, except authorized and consenting inspection and/or operations personnel, below an altitude that is hazardous to persons or property; 16. All participating persons mus t be essential and consentto the sUAS operation which should require nofurther FSDO or ASI approval; 17. The operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and who are neces sary for the on-going operation ofthe entity being inspected or photographed; 18. Ifthe sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location within the security perimeter ofthe flight operations area and land or be recovered in accordance w ith the operator's manual; 1 9. The PIC mus t abortthe sUAS flight in the event of unpredicted obs tacles or emergencies in accordance with the operator's manual;


### 720. Each operation must be completed within 20 minutes flighttime or with no less than 25% battery power remaining, whichever occurs first; 21 . The operator must contain an AirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting any operations under this grantof exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but no less than 48 hours priorto the operation; 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14CFR part 47 and have identification (NNumber) markings in accordance with 14CFR part 45, Subpart 

### C. Markings must be as large as possible; 23. The operator must develop procedures to document and maintain a record ofthe sUAS maintenance, alterations, status of replacement/overhaul component parts and the total time in service of the sUAS; 24. Each sUAS operated under this exemption will comply with all manufacturing safety bulletins; 25. The operator will develop sUAS technician qualification criteria. 26. The pre-flight inspections section ofthe operator's manual will include the requirement that the pre-flight inspection will account for all discrepancies, e.g. , inoperable components, items, or equipment; 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe sUAS will comply with the FCC or other appropriate government oversight agency requirements; 28. At leastthree days before a scheduled aerial filming flight operation the operator of the sUAS affected by this exemption will submit a written plan ofactivity to the local FSDO with jurisdiction over the area ofthe proposed inspection
. The 3-day notification may be waived with the concurrence ofthe FSDO. The plan ofactivities will include the following : a. Dates and times for all flights b
. Name and phone number ofthe operatorfor the sUAS flight operation conducted

underthis grant ofexemption c. Name and phone number ofthe person responsible for the on-site operation of the sUAS d
. Make, model, and serial and N-number of sUAS to be used e. Name and certificate number ofsUAS PIC(s) involved in theflight operation f
. A statementthat the operator has obtained permission from property owners and/or

local officials to conduct the flight operation; the list ofthose who gave permission shall be made available to the inspector upon request g. Signature of exemption-holder or representative h. The description oftheflight activity, including maps or diagrams ofany area, city, town, county, and/or state overwhich the flight operation will be conducted and the altitudes essential to accomplish the operation i. The documents required under 14 CFR §§91.9 and 91
.203 must be available to the

PIC atthe ground control station ofthe sUAS any time the aircraft is operating
. These documents must be made available to the Administrator or any law enforcement official upon request. 

### 829. The sUAS must remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to ultra-lightvehicles, parachute activities, parasailing activities, hand gliding, etc.); 30. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1 31 . All operations mustbe conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized; 32. The sUAS cannot be operated by the PIC from any moving device or vehicle; 33. The sUAS may not be operated less than 500 feet below or less than 2000 feet horizontallyfrom a cloud or when visibility is less than 3 statute miles from the PIC; 34. The sUAS may not be operated in class B, C, or D airspace withoutwritten approval from the FAA. The sUAS may not operate within 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on a current FAA- published aeronautical chart unless a letter ofagreement with the airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA
. The letter of agreement with the airport management must be made available to the administrator upon request; 35. Any 1) Incident, 2) Accident, or3) Flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined bythe applicable COA must be reported to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS-80) within 24 hour. Accidents must be reported to the National Transportation Safety Board (NTSB) per instruction contained on the NTSB website: www.ntsb.gov. Furtherflight operations may not be conducted until the incident, accident or transgression is reviewed by theAFS-80 and authorization to resume operations is provided; 36. The sUAS, PIC and operator will comply with all applicable parts of 14CFR including, but not limited to, parts 45, 47, 61, and 91 .



### LIST OF PROPRIETARY FliGHT OPERATIONS, STANDARDS, PROTOCOLS AND PROCEDURES DOCUMENTATION As noted earlier, Maine Aerial Photography Services LLC's FOPM includes all manufacturers' documentation for the OJI Inspire 1 sUAS, as well as a number offlight operations protocols, requirements and procedures Maine Aerial Photography Services, LLC considers proprietary
. Together, these documents governing the planning, management and execution ofall Maine Aerial Photography Services, LLC flight operations. The FOPM is reviewed and updated on a regular basis to ensure it is accurate, current and reflects any new FAA requirement, change ofstandard and any improvement or addition to its flight operations Maine Aerial Photography Services, LLC considers to be in its clients' and the public' s best interest.

9

### REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED: 14CFR Part 21 14 CFR 61.113 (a) & (b) 14CFR 61.133 (a) 14 CFR 91.7 (a) 14CFR 91.9 (b) (2) 14 CFR 91.109 (a) 14CFR 91.119 14 CFR 91.121 14CFR 91 .15 1 (a) 14CFR 91.203 (a) 

### & (b) 14 CFR 91.405 

### (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) 

### 14 C.F.R. 21: Certification Procedures for Products and Parts This section outlines requirements for the issue ofdesign and production approvals, airworthiness certificates, and other airworthiness approvals
. Maine Aerial Photography Services, LLC is aware that if an exemption is granted as per Section 333, an airworthiness certificate would be issued and a request for exemption from Part 21 is unnecessary. However, as outlined in the List of Limitations and Conditions in this application, as well as all ofthe Attachments to this application, comprising the FOPM, Maine Aerial Photography Services, LLC seeks to uphold the same level or exceeded level ofsafety as described in Part 21 of 14C.F.R
. 

### 14 C.F.R. § 

### 61.113 (a) 

### & (b), 61 .133 (a): Private Pilot Privileges and Limitations: Pilot in Command. Commercial Pilot Privileges and Limitations. Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Becaus e the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraftto have a private pilot's license ratherthan a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilotand passengers, the sUAS is remotely controlled with no living being on board. The area ofoperation is controlled and res tricted, and all flights are planned and coordinated in advance as set forth in the FOPM. The level ofsafety provided by the requirements included in the FOPM exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft
. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14C.F
.R. §61.113 (a) & (b)
.


### 1014C.F.R. § 91.7 (a): Civil aircraftairworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition
. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the FOPM for maintenance and use of safety checklists priorto each flight, an equivalent level ofsafety will be provided
. 14C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S. -registered civil aircraft
... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in theaircrafta current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof
. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft
. 14C.F.R. § 91.109 (a): Flight Instruction Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls
. Flight control is accomplished through the use of a control box that communicates with the aircraftvia radio communications. The FAA has approved exemptionsfor flighttraining without fullyfunctional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. 14C.F.R. § 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA
. As this exemption isfor a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or notmorethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations
. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higherthan 400 AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight and speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the activity, all affected individuals will be aware ofthe planned flight operations as setforth in the FOPM
. 14C.F
. R. § 91.121 Altimeter Settings This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeter that is set "
...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS 11altitude read out, an exemption is needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the FOPM, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning " a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed- {1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes
." The battery powering the sUAS provides approximately 18 minutes of powered flight
. To meetthe 30-minute reserve requirement in 14 CFR § 91
. 151 , sUASs flights would be limited to approximately 10 minutes in length
. Given the limitations on the sUAS proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame forflight in daylight or nightVFR conditions is reasonable
. Limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. An equivalent level ofsafety can be achieved by limiting flights to 20 minutes or 25% of battery power whichever is reached first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.
14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: {1) An appropriate and current airworthiness certificate
.

. . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91
.715 is displayed atthe cabin or cockpit entrance so that it is legibleto passengers orcrew. The sUAS, fully loaded, weighs no more than SSibs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the PIC flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. 14C.F.R. § 91.405 (a); 407 (a) {1); 409 (a) (2); 417 {a) 

### & {b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter
..." and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part43 apply onlyto aircraftwith an airworthiness certificate, these sections will not apply to the applicant. The operator pursuantto the FOPM will accomplish maintenance. An equivalent level of safety will be achieved because this sUAS is very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the sUAS can land immediately and will be operating from no higherthan 400 feet AGL. As provided in the FOPM, the operator will ensure thatthe sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most 12familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Maine Aerial Photography Services, LLC submits that grantofthis exemption application advances the Congressional mandate in Section 333 of the Reform Actto accelerate the introduction ofsUASs into the NAS if it can be accomplished safely. This law directs the Secretary ofTransportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section 332 ofthe Reform Act
. In making this determination, the Secretary is required to determine whichtypes ofsUASs do notcreate a hazard to users ofthe NAS, the public, or pose a threat to national security in light ofthe following: • The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximity toairports and populated areas; and • Operation ofthe UAS within visual line ofsight of the PIC. Reform Act§ 333 (a) (1)
. Ifthe Secretary determines that such vehicles " may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ld. § 333 (c). The Federal Aviation Act expressly grantsthe FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, from the requirementthat all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any of sections 4470244716 of this title ifthe Administrator finds the exemption is in the public interest. The grant ofthe requested exemption is in the public interest based on the clear direction in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with use of UASs for aerial videography/photography, the reduction or elimination of unregulated operators, and the safe integration of UASs
. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. CONCLUSION As set forth herein, Maine Aerial Photography Services, LLC seeks an exemption pursuant to 14 C.F
. R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of 2012 from the requirements of 14 CFR § 21; 61
. 113 (a) 

### & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119 (c); 91 .12 1; 91.151 (a); 91.203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) 

### & (b), which will perm it safe operation ofthe 13sUAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial imagery over small, defined operational areas of the United States
. Approval ofthe exemption allowing commercial operations of Maine Aerial Photography Services, LLC sUAS will increase safety by permitting an operatorto conduct a service safely by adhering to the prescribed guidelines. The exemption will also encourage the education of sUAS operators and the adoption of FAA guidelines and approval for commercial sUAS operations as pertainsto Maine Aerial Photography Services, LLC employees and contractors. Itwill allow MaineAerial Photography Services, LLC to provide a service that benefits the public and local businesses. It benefits the publicthrough a higher level ofsafety ofsUAS operations and through a smooth integration ofsUASs into the NAS. This will assist the FAA with its mission of promoting aviation while preserving safety ofaviators, the public and property. The sUAS operated by Maine Aerial Photography Services, LLC satisfies the criteria set forth in § 333 of the Reform Act- size, weight, speed, operating capabilities, operation within visual line ofsight, and national security - and showing an equivalent level ofsafety to manned aircraftflights through appropriate pilotcertification and safety-focused standards ofoperation
. This provides more than adequatejustification forthe grant of the requested exemptions allowing commercial operations. By grantingthis Petition, the FAA Administratorwill be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of 2012, while also advancing the interests ofthe public by allowing Maine Aerial Photography Services, LLC to safely, efficiently and economically operatethe sUAS commercially within the NAS.



# Res~ **rz_**

# __ Tyler S. Plummer Maine Aerial Photography Services, LLC

(Written with referenceto exemption letters retrieved from www. faa.gov) 

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### ATTACHMENTS DJIInspire 1 Manufacturer Documentation A
. DJIInspire 1 Overview and Specifications Data Sheet B. DJIInspire 1 User Manual_v1.2.pdf 

### C. DJI Inspire 1 Safety Guidelines
.pdf D. DJIInspire 1 Quick Start Guide.pdf E. DJIInspire 1 Maintenance Manual_vl
.O.pdf F
. DJIInspire !Intelligent Flight Battery Safety Guidelines.pdf MaineAerial Photography Services, LLC Proprietary Documentation G
. Maine Aerial Photography Services, LLC Flight Checklists and Operating Protocol H. Maine Aerial Photography Services, LLC sUAS Flight Log 

### I. MaineAerial Photography Services, LLC Monthly Maintenance log J. Maine Aerial Photography Services, LLC Pre-Flight Safety Briefing and On-Site Flight Plan K. MaineAerial Photography Services, LLC Permission to Conduct Onsite Flight Operations

Consent Form l. Maine Aerial Photography Services, LLC Pilot Flight Log



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