PhytosRx:

R oger Northrop

E xemption request to section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

I n regar ds to section 333 of the FAA R eform Act of 2012 and C

. F.R Part 11

. My registered busin ess PhytosRx , owner and operator . PhytosRx would like to move into
the Small Unman n ed Aircraft Systems (UAS s ) , requests to be exempt ed from the
Feder al Av iation Regulations ( FAR s) listed below so that PhytosRx may operat e UAS s commercially in airspace regulated by Federal Aviation Administ ration ; as long as su ch

o pe rations are conducted under the con di tions of the F AA that are required by section
333.

Phytos Rx is owned by Roger Northrop , a nd is the busin ess name that I use when building software, as well as graphic des ign work. Phytos R x h as been moving into aerial phot ography and the aerial video ph otography market. I Roger Northrop
have over 150 hours of flight time with the DJI Phantom series d rones , and all of the
work that I ha ve done to da te has been for pers on al enjoyment and education of ho w to properly and safely fly a drone. A ll of my flights will adhere to the FAA ’ s Flight Photography S tandard Operat ing Procedures (SOPs)

.

My contact info:
Atten: Roger Northro p Address: 14 South George Street, Mount Prospect IL, 60056
Phone: 847

- 530

- 2510
Email: rogerpn@phytosrx.com
Drone registration number : FA3MTECXY9Th e exemption that I am asking for would per mit the operation o f any of the DJI
Phantom 3 Series drones , as well as the DJI Inspire series drones under controlled
conditions for commercial use b y Roger Northrop. PhytosRx requests with re spect to the FAA to grant an exemption to th e following speci fic sections of the Title 14 Code
of fed eral Regulations allowing it t o operate the DJI Phantom 3 s er ies as well a s the DJI Insp ire seri es drones which are light weight UAS ’ s for commercial use.

14 CFR 21, subpart H, 14 CFR 45.23 (b), 14 CFR 91.7(a ), 14 CFR 91.9 (b)(2), 14 C FR 91.103(b), 14 CFR 91.109, 14 CFR 91 .119, 14 CFR 91.121, 1 4 CRF 91. 151(a), 14 CFR 91.203(a)&(b), 14 CFR 91.405(a), 14 CFR 91.407(a) (1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a)&(b) , 14 CFR 61.113(a)&(b)

Phy tosRx submits this application in accordance wit h the Reform Act, 112 P.L. 95 331

- 334, seeking relief from any currently applicable FARs operating to prevent commercial cinematic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems in to our national airspace system as it is in the public’s interest to do so. PhytosRx , uses the DJI Phantom 3 series as well as DJI Inspire series UAS s tha t meet the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of the
ultra

- light weight UAS is expressly contemplated by the Reform Act. PhytosRx would like to operate its ultra

- light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS will be operated near airports or heavily populated areas; and , Whether the UAS will be operated by line of sight. 112 P.L. 95 333 (a). Each of these items are in favor of an exemption for PhytosRx

. PhytosRx UAS s utilizes four (4) counter

- rotating propellers for balance, control and stability. Their UAS is eq uipped with GPS and auto return safety technology. Weighing less than ten (10) pounds (far below the maximum 55 pound limit); including camera.Conside rations when Operat ing
Starting the spring of 2016 PhytosRx would be taking aerial photography / v ideo of

• Car dealerships

• Golf courses

• Industrial Business Parks

• Business real estate

• Landscapes

• Rea l estate property

• Indoor Auditoriums / Stadiums (Not occupied by people)

• Indoor large open spaces (Not occupied by people)

Consideration of Risk Management

• A ll flights are operated with in line of sight

• Flights will take place during the daytime

• Flights will termin ated once the battery reaches 20 %

• Flights will be operated below 400 feet

• Full site surve ys will be conducted prior to the flight

• All photography and video will obtain a verbal and written consent prior to flights

• I f the UAS loses sight or GPS signal is lost , it will automatically return to the
home location and land

• If the UAS Battery reaches 2 0 % it will auto matically return to the home location
and land

• UASs are e quipped with ‘ First

- Person

- View ’ (FPV)

• Fights will be canceled due to high winds, rain, and snow

• UAS ’ s will have a pre

- flight check on all parts, as well as the most recent
firmware loaded
T he DJI Phantom 3 series and DJI Inspire are equipped with sensors for indoor flight for safety and control. Any indoor flights wi ll hav e written permission as well as no people are to be in the indoor area where the flight is taking place, except for the pilot

.About Roger Northrop
I have been a recreational photographer for the past 15 years traveling to many destinations world wide. At this point in my life, I have the opportunity to begin to make a business of it. As I g row older, I need have a way to sustain myself and my wife when i am ready for retirement. I have been flying drones now for the past 3 years with over 200+ ours of flying time , and I am being asked to contract out aerial photography, thus the need to request for an exemption. This request of exemption will allow me to build a supplementary income once I am at my retirement age.

Benefits for the Businesses and community

• PhytosRx will allow for competition in this growing market, giving businesses a choice

• Opportunity for PhytosRx to possibly employ others

• Allow Businesses to present their products with a much better experience to the

consumer

• H elp to push technology of this type forward

Impact on PhytosRx

• If PhytosrRx does not get the exemption, it is possible that it could miss a marke t that is growing, and not allow for a new business to be built with the possibility of employing others

• S incerely

Roger P. Northrop PhytosRx 14 South George Street Mount Prospect IL, 60056