November 20, 2015

David A. Rudich 1525 Mill Gap Rd Lost River, WV 26810 304-897-6135 rudichdk@yahoo.com

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Ave, SE Washington, DC 20590 .. I'

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RE; Exemption request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviatiion Regulations.

Dear Sir orMadam,

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.P.R. Part 11, David A. Rudich hereby applies for an exemption from the listed FederalAviation Regulations "F ARs" listed below, to allow for operations ofa DJI Phantom 3 Professional Quadcopter Aircraft, a small Unmanned Aircraft System (sUAS) to conduct aerial photography and videography for the purpose ofreal estate listing and marketing, agricultural survey, emergency search and rescue and fire observation and control. All exemption requests are for those items that are notpertinent to the proposed vehicle and operations. Special attention is given to safety and security in all proposed operations. As will be demonstrated, an exemption will result in a significantpublic benefit. This request is similar to many ofthe currently granted exemptions. All operations will be conducted within and under the conditions stated herein or
as may be modified by the FAA as required by Section 333.

SYNOPSIS

This request for exemption to allow for the commercial operation of a small UnmannedAircraftSystem (UAS) is similar to but more limited in operations to many of the grantedrequestsfor exemptions. Allcommercial operations will be limited toprivateproperties, at flight altitudes of lessthan 200ftAGL located inpredominately ruralareas. Other operations includingsearch andrescue, and fire observation andcontrol will be offeredto localgovernment as apublicservice without remuneration.

The aircraft, a DJIPhantom 3 Professional, is one of the mostpopular approved for exemptions because of itsfunctionality andsafety features.

DavidA. Rudich, the Pilot in Command (PIC) is a FAA licensed instrument commercialpilot.

Public Benefits include safety, environmental andeconomical benefits.
Safety considerations includes the choice**ofthe~vehicle** itself because ofthe inherentsafety features, strict limits on the area of operation,preflight inspections and protocols, extensive use of checklists andthe use ofa flight andsite observer in verbalcontactwith the PICatall times inpreparation for andduring flight operations.

Because of the foregoing andthe similarities to otherapprovedrequests it is requestedthatan exemption be approved in an expeditious manner.

DISCUSSION

The requested exemption would permit commercial operation by DavidA. Rudich ofa Phantom 3 Professional (UAS), which weighs approximately 3 lbs. andperforms aerial surveys and videography that consists of photographs and vidiography taken by on-board cameras. The applications for which this waiver is sought include real estate listing and marketing, agricultural field survey, emergency search and rescue and fire observation and control. Use ofthe UAS for aerial photography and videography reduce the need to utilize conventional manned aircraft, manned lifting devices or manned climbing for the same purpose and provides a very high quality imagery at a fraction ofthe cost. These savings result in enhance safety, efficiency and productivity for the affected activities, as well as environmental benefits.

The regulations from which the exemption is requested are as follows:

14 C.P.R. Part 21; 14 C.P.R. 45.23(b); 14 C.P.R. 61.101(e)(4);14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 61.23(a) & (c); 14 C.F.R. 61.315(a); '4 C.F.R. 91.7(a) & (b); 14 C.F.R. 91.9(a)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(l) & (2); 14 C.P.R. 91.417(a) & (b).

All operations with the exception ofemergency search and rescue and fire observation and control, would be conducted onprivate property with written approval ofthe property owner. All these flights will be within the "blanket" 200 foot Certificate ofWaiver or Authorization (COA) as issued bythe FAA. This policy pertains to aircraft weighing less than 55 pounds, operate during daytime Visual FlightRules and operate within visual line of sight ofthe pilot. Italso requires staying certain distances away from airports or heliports and/orto comply with any modifications in the future.

I, David A. Rudich, am an FAA licensed instrument commercial pilot, License Number 3151096. Mybackground includes being an operations analyst and systems engineer in the aerospace industry. This has given me
an intimate knowledge ofaircraft and satellite system control, operations and technology. Currently Iama Licensed RealEstate Broker-inbothVirginia and West Virginia.
Specifically, this exemption is to operate a DJI Phantom 3 Quadcopter which is comprised ofan unmanned aircraft and a transportable ground station. The DJI Phantom 3 is referred to as a Quadcopter with a maximum gross weight ofabout 3 pounds. Itis equipped with four rotors that are driven by electric motors poweredbybatteries. The UAS has a maximum airspeed of22m/s. This aircraft is one ofthe most popularUASs to receive exemptions underthe currentregulations due to its operating characteristics and safety features. The system complies with Part 15 ofthe FCC rules.Full details concerning the description, safety features and operations ofthe DJI Phantom 3 are available in the User Manual by scanning the following.

Granting this exemption would result in a number ofPublic Benefits including but not limited to the following. The DJI Phantom Professional is battery powered and is a safe, efficient and economical alternative to manned aircrafttraditionally utilized to obtain aerial imagery. An exemption allowing the use ofa sUAS would reduce the amount ofmanned aircraft, reducing noise and air pollution as well as increase the safety oflife and property in the air and onthe ground. Furthermore the use ofa sUAS in real estate photography would benefitbothbuyer and seller ofreal estate alike by providing an affordable way ofdisplaying and viewing various properties. Agricultural surveys provide an economical way ofexamining crop fields. Emergency search and rescue and fire observation and control wouldbe preformed as a public service without remuneration.

A critical element ofthis exemption application involves evidence ofthe safety ofoperations priorto, during and following all flight operations. All UAS operations will be conducted in a mannerto minimize risk to persons and property and to insure that all regulation and requirements are complied with. The Phantom 3 Professional was selected as the flight vehicle because of all it's built in safety features and operational characteristics. All operations inregard to Real Estate and Agriculture will be conducted over private land with owners approval. All operations willoccur during daylight, Visual Flight Conditions and remain within Visual Line ofSight of the Pilot in Command. Above Ground Level (AGL) will be restricted to less than 200ft. Operations will be prohibited within 1 Onm ofany airport.

With respect to each individual flight I, David A. Rudich as Pilot in Command will be responsible for;

All Pre-flight activities including pre-approval documentation, site inspection, secureing flight operations area, Pre-flight vehicle inspection utilizing a detailed checklist and following the manufacturers specified powerup procedures.All flight operations to insure that the vehicle remains withinthe prescribed

area ofoperations, and is operated in accordance to manufacturer's specifications. Highest priority will be given to providing for the safety of all persons and property.

PostFlight Requirements including vehicle shutdown, final site inspection, and completion ofFlight and Maintenance logs. Special attention will be given to documentation ofany problems encountered.
Following all flights a comprehensive inspection andpreventative maintenance plan will be followed in accordance with the manufacturer's specifications to ensure the sUAS vehicle and software is up to date, the batteries are in good health and recharged and that the aircraft itselfis ready for it's next safe flight.

In addition to the previous, a Flight Observer will also be present and a participant for all flights. The Observermust have the visual acuity to observe the sUAS at all times and remain in verbal communication with the PIC at all times. Duties ofthe Observer include but are not necessarily limited to assisting the Pilot in Command in the following;
Securingthe flight area to insure that it is clear ofany potential interfering obstacles andpersonnel.
Warning the PIC ofany impending obstacles in the flight path ofthe sUAS
Warning the PIC ofany deviations in the planned flight path ofthe sUAS.
Warning the PIC ofany unauthorized personnel appearing in the area of planned flight.

In conclusion, this request is similar in all material respects to Grant of ExemptionNos. 11062, 11109,11112, 11213, and 12645 and as such I request that an exemptionbe granted in an expeditious manner. Ifnecessary I am prepared to amend any part ofthis request to satisfy the need for an equivalent orhigher level ofsafety.