May 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations from 14 CFR part 21, subpart H; 14 C.F.R. 45.23(b); 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)

(2); 91.103(b); 91.109; 91.113 (a) & (b); 91.119; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 

91.409(a)(2);91.417(a) & (b).

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, Greenside Energy LLC, a photovoltaic developer, hereby applies for an exemption from

the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned

Aircraft Systems (“sUAS’”) for aerial photography and videography for mapping, inspections of

photovoltaic solar arrays, utilities, construction industries and real estate properties and other flight

operations that could be performed safely and more cost effectively with the use of small UAS at low

altitude within the U.S. National Airspace System as compared to manned aircraft. Operations would be

performed only at the request of and with the authorization and permission of clients or their

authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of sUAS’s

so long as such operations are conducted within and under the conditions outlined herein or as may be

established by the FAA as required by Section 333.

Exhibits:

Due to size of files please go to: http://www.dji.com/product/phantom-2-vision-plus to 

review the following DJI Phantom 2 vision plus 3.0

1 Manuals and Safety Guidelines. Once website opens click on “Downloads”. Then under

Documents and Manuals open the following PDF files to review:

1.) Phantom 2 vision plus 3.0 Quick Start Guide (EN) v1.0

2.) Phantom 2 vision plus 3.0 User Manual (EN) v1.0

3.) Phantom 2 vision plus 3.0 Safety Guidelines v 1.0

4.) Phantom 2 vision plus 3.0 Intelligent Flight Battery Safety Guidelines

5.) 1345 Propeller Locks Quick Start Guide

6.) Phantom 2 vision plus 3.0 Maintenance Manual v 1.0

Other Phantom 2 vision plus 3.0 Informational Data:

Please refer to the following Phantom 2 vision plus 3.0 tutorial videos listed at 

www.dji.com/product/phantom-1/video

1.) Phantom 2 vision plus 3.0– Unboxing and Preparing for Safe Flight

2.) Phantom 2 vision plus 3.0 “Pilot App”

3.) Phantom 2 vision plus 3.0 “Updating the Firmware”

4.) Phantom 2 vision plus 3.0 “How to Fly”

5.) Phantom 2 vision plus 3.0 Quick Start Guide Page 2

6.) Phantom 2 vision plus 3.0 Set Up & Demo Inc. Overview of Features of the App

7.) Phantom 2 vision plus 3.0 Flight Simulator for Apple App introduction
As detailed in this document and the referenced DJI Publications and tutorials, the requested exemption

would permit the operation of sUAS under controlled conditions in airspace that is a.) limited b.)

predetermined c.) controlled to access and d.) would provide safety enhancements to the already

regulated safety practices presently followed by manned aircraft as governed by the FAA. Approval of

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrator’s) responsibility to “...establish requirements for the safe operation of such aircraft

systems in the national airspace system.” Section 333(c) of the Reform Act.

Applicant Contact Information:

Greenside Energy LLC

Kenneth J. Alves Jr (Owner)

825 West Main Road 

Middletown, Rhode Island 02842

PH: 401-626-6378

Email: alves.kenny@gmail.com

Extent of relief I seek, and why

14 CFR Part 21 subpart H

The UAs to be operated carries neither pilot nor passenger and carries no explosive materials or

flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft

to be utilized, I request exception. In the restricted environment and under the conditions proposed

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness

certificate without said restrictions.

14 CFR 45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain

words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions

would need to be smaller than required minimum. Understanding the importance of lettering I will mark

my UAS with the largest possible letters by placing the word "Experimental" or assigned number or

name, based on request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided

by having the UAS marked on its fuselage as required.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for

maintenance and use of safety check list prior to each flight an equivalent level of safety will be

provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is

no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level of safety will

be maintained by keeping the flight manual at ground control point where the pilot wil) have immediate

access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed.

Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing

and takeoff distances, along will all of those found in attachment "DJI Pilot Training". An equivalent level

of safety will be provided by preflight protoco) to properly match the machine.

14 CFR 91.109
UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved

through the use of a control box that communicates with the aircraft via radio communications. The

equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft,

and by the speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not

carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills.

14 CFR 91.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe

an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live

flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS

altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately

such documents. An equivalent level of safety wili be achieved by keeping these documents, to the

extent they are applicable to the UAS, at the ground control point where pilot has immediate access to

them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these section only apply to aircraft with an airworthiness certificate, theses sections do not apply

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in

working condition before initiating each flight.

Seth Hellinga is seeking relief from all FARs above preventing appiicant from conducting aerial

photography and video of real estate taken at levels less than 400ft, at a speed less than 33.5 mph, and

with a maximum flight time of 25 minutes,. The drone to be used is a D1I Phantom 2 Plus. At 2.74

pounds the weight of the UAS meets the definition of "small unmanned aircraft" found in section 331

"The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds

much less than it's top speed of 33.5 mph. Due to the UAS being battery powered there are no

combustible fuels onboard. Maximum flight time for this particular UAS is 25 minutes battery life, flights

to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating

area associated with the aircraft to be utilized i find this exception to be reasonable with an equivalent,

or greater, level of safety to be reached by the operator.

Saftey

*Please see attachment "DJI Pilot Training" for safety precautions I use for every flight. Aside from these

practices I was given a hands on training course when I purchased my UAS.

Additionally:

1) 1 do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport

manager has been made.

2) 1 land my UAS prior to manufacturer recommended minimum level of battery power

3) 1 pilot my UAS through remote control by line of sight

4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and

then slowly lands if communication with the remote control pilot is fost

5) 1 actively analyze flight data and other sources of information to constantly update and enhance

safety protoco ~s

6) 1 conduct extensive pre-flight inspections and protocol, during which safety carries primary

importance

7) 1 always obtain all necessary permissions prior to operation; and,

8) 1 have procedures in place to abort f(ights in the event of safety breaches or potential danger.
9) Public Interest

The use of an UAS in the real estate industry provides both buyers and sellers a higher level of service.

For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting

in a quicker sale of their home. Quicker home sales also helps accelerate the economy as a whole.

Buyers experience the benefit of encompassing a whole property, sometimes several acres, in one

photo or a short video. Not only does this benefit the specific home seller or home buyer, but it benefits

the general public because it is much more efficient than traditional ways of using a plane or helicopter

to achieve the same result. We can now provide this level of service while being conservative with fuel,

time, emissions, noise, and other resources. Considering size, weight, speed, and absence of

combustible fuels, my UAS will poses much less of a safety concern for the general public when

compared to larger manned aircraft.

Thank you for your consideration.

Kenneth J. Alves Jr

Greenside Energy LLC