September 24, 2015

Attn:

U.S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12­140

1200 New Jersey Ave SE Washington, DC 20590

Re: Myles Neith

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation

Regulations from 14 CFR Part 21 subpart H, 14 CFR 45.23 (b), 14 CFR 91.7 (a), 14

CFR 91.9 (b) (2), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119 (c), 14 CFR 91.121,

14 CFR 91.203 (a) and (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409

(a) (2), 14 CFR 91.417 (a) and (b)

Myles Neith

Creative Director at Polygon Creative

857 Carpetta Circle

Pittsburg, CA 94565

925­597­0329

mneith88@gmail.com

To whom this may concern,

I, Myles Neith, write this letter pursuant to the FAA Modernization and Reform Act of

2012 and the procedures contained within 14 C.F.R.11, and request that I be exempt

from the Federal Aviation Regulations (“FARs”) listed below and be granted exemption

to operate an unmanned aircraft system (“UAS”) commercially in airspace regulated by

the Federal Aviation Administration (“FAA”).

The Exemption Request would be for a DJI Inspire 1 (UAS) that I own, with intent to

provide aerial photography and videography for real estate, commercial, landscape, and

film work within the NAS. In the public interest, this will enhance real estate listings

offered for sale in today’s competitive market without the high cost of using manned

aircraft for aerial photography and videography. The use of UAS’s in the real estate
industry provides both buyers and sellers a higher level of service for marketing and

advertising appealing to more buyers. Home sales also increase the economy as a

whole. I will be able to provide a high level of service without the use of high cost fuel,

emissions, and loud manned aircraft noise and in less time. Considering size, weight,

speed, and the DJI Inspire 1 UAS will poses much less of a safety concern for the

general public when compared to larger costly manned aircraft.

I, Myles Neith, am experienced in flying remote controlled airplanes, and have operated

drones for the last 4 years with no accidents. I have well over 40 hours of experience on

the DJI Inspire and additional DJI Pilot training for the DJI Inspire 1 UAS. Safety is my

number one priority, therefore pre­flight inspections and post flight inspections are

always performed as recommended by the manufacturer owner’s manual and

documented in a flight log.

The DJI Inspire 1 UAS has a maximum gross weight of 6 pounds 7.5 ounces, a length

of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of

approximately 42 knots. All photography and video of will be taken at levels of approx.

200ft above ground level (AGL), at a speed less than 17 knots, and with a maximum

flight time of 13.5 minutes allowing additional remaining return to home position flight

time. The DJI Inspire 1 UAS meets the definition of "small unmanned aircraft" found in

section 331 "The Reform Act". The DJI Inspire 1 UAS is battery powered there are no

combustible fuels are onboard. Maximum flight time for the DJI Inspire 1 UAS is

approx., 18 minutes with a TB47, 4500mAh, 22.2 V LiPo 6S battery and approx., 22

minutes TB48, 57mAh, 22.8 V LiPo 6S battery. For safe a return, all flights are

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, level of safety to be reached by the Pilot in Command

(PIC).

I, Myles Neith, therefore, as Petitioner, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems,
hereby petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the

National Airspace System (NAS), and for an exemption from the requirements of

Regulations from 14 CFR Part 21 subpart H,14 CFR 45.23 (b),14 CFR 91.7 (a),14 CFR

91.9 (b) (2),14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119 (c), 14 CFR 91.121,

14 CFR 91.203 (a) and (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409

(a) (2), 14 CFR 91.417 (a) and (b).

14 CFR Part 21 subpart H

In consideration of the speed, weight, size, and limited operating area associated

with the UAS and its operation, the DJI Inspire 1 UAS meets the conditions of FMRA

Section 333 and therefore, I request exemption of an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H.

14 CFR 45.23 (b)

The DJI Inspire 1 UAS does not have a cockpit, cabin, or pilot station on which to

market certain words or phrases due its dimensions. However, in compliance with FAA

regulations, the UAS’s fuselage will be marked with lettering and/or “N” numbers as

large as possible to identify the aircraft as required by the FAA ruling to preserve the

equivalent level of safety and compliance.

14 CFR 91.7 (a)

The DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with

14 C.F.R. Part 21, Subpart H. Accordingly, I, Myles Neith, will submit and ensure that

the DJI Inspire 1 UAS is always in airworthy condition, prior to every flight, by

determining that the UAS is compliance with the operating documents for the DJI

Inspire 1 UAS, and pre­flight and maintenance logs for the aircraft’s safe flight

conditions.

14 CFR 91.9 (b) (2)

Due to the dimension and configuration the DJI Inspire 1 UAS, the UAS does not have

the means of to carry a flight manual on board. I, Myles Neith, consequently request
exempt from 14 CFR 91.9 (b) (2) because the flight manuals, are maintained within my

reach at all times on the ground, both in print format and electronic “pdf “ format with

immediate access should it be necessary.

14 CFR 91.103

The DJI Inspire 1 UAS does not have an FAA approved flight manual. However, I

request exemption 14 CFR 91.103 because procedures for weather check, GPS

satellites, flight battery levels, landing and take­off measurements, compass calibrations

and other flight telemetry are found in the DJI Pilot App and provide an equivalent level

of pre­flight protocols.

14 CFR 91.109

The DJI Inspire 1 UAS does not have fully functional dual controls since it is remotely

piloted via radio communications from the aircraft to a hand held transmitter. Since the

DJI Inspire 1 UAS does not carry a pilot or passengers the comparable level of safety

and control is retained by the Pilot in Command (PIC).

14 CFR 91.119 (c)

In compliance with 14CFR 91.119, I, Myles Neith as Pilot in Command (PIC), fly only

within visual line­of­sight (VLOS) or the VLOS of a visual observer (VO) when required.

The UAS remains at least 500 feet from other people in order to not pose an

unwarranted hazard to persons and property. All flights are conducted during

daylight­only hours (sunrise to sunset). Flights are never conducted from a moving

vehicle. No flights are ever conducted within 5 miles of an airport. No flights are ever

over 400 feet above ground level (AGL). No flights are ever less than 3 miles visibility

from the home point.

14 CFR 91.121

The DJI Inspire 1 UAS does not have a typical barometric altimeter onboard. However,

altitude information is provided via Global Positioning System (GPS) equipment and

radio communications telemetry data link, which is downlinked from the DJI Inspire 1

UAS to the PIC’s remote control screen actively monitoring the flight path. This altitude

information, combined with other flight telemetry and flying the DJI Inspire 1 UAS only

within visual line of sight, and below 400 feet AGL, will ensure an equivalent level of

safety. In addition should communications be lost at any point, the DJI Inspire 1 UAS
will automatically return to the home position (failsafe mode) via GPS, and will descend

to the takeoff position and shutdown.

14 CFR 91.203 (a) and (b)

Given the similarities of, 14 CFR 91.9 (b) (2) Due to the dimension and configuration the

DJI Inspire 1 UAS, the UAS does not have the means of to carry a flight manual on

board. An equivalent level of safety is maintained within my reach at all times on the

ground by having the flight manuals in print format and electronic “pdf” format with

immediate access should it be necessary.

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

Furthermore, I, Myles Neith request relief from Sections 91.405(a),91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

I, Myles Neith, submit that the requested relief is appropriate since an equivalent level of

safety will be ensured by performing preventive maintenance on the DJI Inspire 1 UAS

using the methods, techniques, and practices prescribed in the operating documents for

the DJI Inspire 1. Furthermore, I document and maintain all flights and maintenance

records for the DJI Inspire 1 UAS and will made available for inspection by the FAA at

any time upon request.

In consideration of the FAA grating me the above Section 333 Exemption Petition, I

thank the FAA in advance for the efforts to establish proper regulations and protocols

for the use of UAS’s within the national airspace. I further standby to support and

cooperate with the FAA with any request regarding the public safety.

Thank you. Sincerely,

Myles Neith

Attachments: DJI Maintenance Manual, DJI Safety Guidelines