Casale Photography 

Sam Casale, Owner (and FAA licensed Private Pilot) 

2210 Autumn Glow Court 

Bel Air, MD 21015 

Cell Phone- 443-643-5928 

email: Sam@CasalePhotography.com 

January 11, 2016 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room wl2-140 

1200 New Jersey Avenue, SE., ·washington, DC 20590 

Dear U.S. Dept. ofTransportation I FAA: 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of2012, Sam Casale, referred to 

as the petitioner, kindly request exemption from the following sections of Title 14, 

Code of Federal Regulations §§ 

14 C.F.R. 61.113(a) 

14 C.F.R. 61.113(b) 

14 C.F.R. 91.119(c) 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.405(a) 

14 C.F.R. 91.407(a)(1) 

14 C.F.R. 91.409 (a)(1) 

14 C.F.R. 91.409(a)(2) 

14 C.F.R. 91.417(a) & (b) 

I the Petitioner seek relief from the listed regulations in order to operate small 

unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) for the purposes of aerial real estate photography, 

videography, cinematography, and other aerial operations that can 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 a manned aircraft. Safe UAS operations 

conducted within FAA guidelines will support local business and create positive 

awareness in tht( community by providing UAS alternatives to previous methods of 

larger, more dangerous aircrafts. Compensated tasks will be conducted only at the 
request of, and with authorization and permission of, clients or their authorized 

agents in compliance with privacy laws and FAA Regulations. In addition, only the 

authorized individual/Operator, Sam Casale, will conduct UAS flights within and 

under the conditions outlined herein or as may be established by the FAA as required 

by Section 333. 

The FARs 

I, the petitioner seek exemption from the above mentioned F ARs for the following 

reasons; 

61.113(a) & (b) 

I, Sam Casale, do hold an FAA PRIVATE PILOTS LICENSE ( cert # 216726190). 

However, this section limits private pilots to non-commercial operations. In addition, I 

will operate the UAS with the addition of a trained observer. All pre-flight inspection, 

maintenance and flight logs will be saved and made available to the FAA for review; 

with the purpose of safely integrating civil UAS operation in the National Airspace 

System. The petitioner will conduct flights as the authorized UAS Operator. The UAS 

controlled by the Operator will perform at altitudes, always below 400 AGL, well 

below the permissible limits for other civil aircrafts, eliminating the risk to other 

aircrafts. 

91.119(c) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted 

closer than 500 feet to the ground may require that the UAS be operated closer than 

500 feet to essential persons, or objects that would not be possible without additional 

relief. The petitioner requests modification, waiver or exemption and clarification 

concerning the terms "congested areas" and "densely populated". The petitioner 

requests waiver for this condition to allow reasonable and responsible operations in 

areas of subdivisions and neighborhoods if required. The petitioner will primarily 

operate the UAS between ground level and 200feet. The UAS will be operated over 

deslgn~teclproperties with the consent of the local municipality or their designated 

agent, and while maintaining a safe distance from persons. In addition, since the 

purpose is photography, the UAS will be operated at a very slow forward speed, and in 

fact will just be hovering the majority of its time in the air. The petitioner will compile 

flight data from the logs. This data may assist the FAA in development of regulations 

for commercial operations in low-risk, controlled environments. 

91.121 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric 

sensor for altitude information. Altitude information is generated by the UAS on 

board computing system, it's then received and displayed at the operators ground 

station. 
91.15l(a) 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar 

UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for 

daytime, VFR conditions. The UAS provides battery power remaining in percent to 

the Pilot In Command. The UAS batteries provide approximately 25 minutes of 

powered flight. Information provided in the· operating documents discusses 

procedures regarding remaining battery power management. Those documents contain 

a condition in which the PIC will initiate a landing procedure when battery remaining 

reaches a specified level. Given the limitations on proposed operations and the 

location of those proposed operations, The FAA found that a reduced minimum power 

reserve for flight in daytime VFR conditions was reasonable. 

91.405(a); 91.407(a)(l); 91.409 (a)(l) & (2); 91.417(a) & (b) 

As discussed in Exemption, 11138 (DOUGLAS TRUDEAU), The petitioner proposes 

to inspect and ensure that the UAS is in a condition for safe flight in accordance with 

the operating documents. The FAA found that adherence to the petitioner's operating 

documents and the conditions and limitations specified, describing the requirements 

for maintenance, inspection, and record-keeping, were sufficient to ensure that safety 

would not be adversely affected. 

Areas of interests for UAS commercial use 

Aerial :videoandor photography for real estate, architecture, land surveying, 

engineering, television, and cinematography are the interests I am pursuing this 

exemption. Aerial inspections and or photography of residential or commercial 

structures will be the overwhelming majority of my business. In addition, I plan to 

offer live streaming aerial video in efforts assist in search and rescue operations 

ONLY at the request of and with legal authorization of local authorities or 

government. Local law enforcement has expressed an interest in this service in our 

small town. 

The UAS 

The petitioner seeks exemption to operate UAS Multifunctional Quad-rotor Systems 

by DJI (DJI Phantom 3, and DJI Inspire 1) for compensation or hire within the 

National Airspace System. The DJI Phantom 3, and Inspire 1 are highly dependable 

consumer grade small rotor crafts in the quadcopter configuration. They are vertical 
takeoff and landing (VTOL) UAS with a Ground Control Station (GCS) utilizing an 

electronic tablet. Both systems contain inertia measuring units (IMU) with integrated 

barometric sensors, augmented with global positioning systems (GPS) and GLONASS 

to maintain their geospatial orientation and position. Real time video control station 

allows the operator and/or PIC to monitor battery level, GPS signal strength, altitude, 

distance from PIC, camera imagery, and control camera angle. Both units have an 

integrated failsafe mode "Return to Home" and assist operations for either loss of RC 

or GPS signal. The onboard flight controllers will warn the pilot via telemetry and 

external lighting cues before reaching a low battery state. These UASs have the 

capability to abort a flight and return to home safely in case of any unpredicted 

failures, obstacles or emergencies. I view these units as highly sophisticated tools. The 

quality of these units does well to separate them from the lesser "toys". 

DJI Phantom 3 

Dimensions: 203x330x457 mm 

Weight: 1280g I 2.8lb 

Intelligent Flight Battery: 4480mAh 23min Flight time 

Max Flight Speed: 16m/s or 35.7mph 

Operating Frequency: GHz; 2.400~2.483 GHz 

Key Features: 

Live real-time flight data 

Intelligent Orientation Control (IOC), GPS, and Return to home failsafe 

Self-tightening locking Propellers 

DJI Vision Positioning System for improved safety 

Dynamic home point orientation 

Intergraded No Fly Zones prevents inadvertently entering protected air space 

Intelligent Flight Battery includes capacity data, over charge/discharge protection, 

maintenance data. 

DJI Inspire 1 

~· 

Dimensions: 438x451x301mm 

Weight: 2935g I 6.47lb 

Intelligent Flight Battery: 5200mAh 18min Flight time 

Max Flight Speed: 22m/s or 49.2mph 

Operating Frequency: 5.725~5.825 GHz; 2.400~2.483 GHz 

Key Features: 

Live real-time flight data 

Intelligent Orientation Control (IOC), GPS, and Return to home failsafe 

Self-tightening and locking Propellers 

DJI Vision Positiorting System for improved safety 

Dynamic home point orientation 

Intergraded No Fly Zones prevents inadvertently entering protected air space 

Intelligent Flight Battery includes capacity data, over charge/discharge protection, 

maintenance data. 
j ' .• 

Risk Mitigation 

Holding a FAA Private Pilot's license I have the utmost respect for the FARs and the 

aerial safety that is the intended result of those regulations. 

• I the petitioner have reviewed FAA exemptions reference's 1-3 Conditions and 

Limitations section and believe that the procedures specified therein are 

reasonable and will be utilized in order to manage and mitigate risk and ensure 

public safety. 

• A preflight checklist is being developed and employed to ensure that the UAS 

airworthiness and will be verified before each launch ( I calibrate on every 

launch). Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs. These 

documents will be made available upon request to assist in future 

implementation of safety standards and regulations. 

• The petitioner will only operate the UAS over designated properties with 

client and property owner consent. 

• Flight plans will be predetermined to limit the UASs flight time and limit 

safety concerns. The petitioner will take into account distance from persons 

and potential flight obstacles prior to operating the UAS. I will utilize the 

same practices, such as referring to VFR Sectional Aeronautical 

Charts to ensure I understand the area and any airspace limitations. 

• UAS operations will always be within VLOS of the PIC and the observer. The 

petitioner/Operator will carry suitable insurance for the protection of the 

Operator and the Public thus providing positive and responsible UAS 

operations in the community. 

Preflight and Take-off Check List: 

1. On hand DJI Phantom3 and DJI Inspire 1 official Manuals and procedures 

Reference B4UFL Y Smartphone App 

2. Optimal weather conditions have been verified 

s~ -Location scouting including landing and takeoff distance 

4. Establish reasonable low altitudes to ensure safety of civil aircrafts 

5. Obtain consent of all persons involved in filming including land and property 

owners Visual Inspection of aircraft 

6. Prepare digital flight logs 

7. Flight battery and transmitter battery at full charge 

8. Propellers are in proper airworthy conditions and are securely locked and 

mounted. Perform sensor and compass calibration 

9. DJI Ground Station activated 

10. Visually inspect and ensure all motors are running properly and rotate 

evenly. Ascend 1Oft for control movement evaluation. 

11. Visually inspect for controlled flight performance along with ground station 

data. Flights will be operated within line of sight of a pilot and/or observer. 

12. Maximum flight time for each operational flight will be no more than 30 

minutes. Flights will be terminated at not less than 25% battery power reserve 
• -'i 

should that occur prior to the 30 minute limit. 

13. Flights will be operated at an altitude below 400 feet AGL, 

14. Record all flight data into the Flight Logs 

15. Perform regular scheduled maintenance 

Public interest 

Choice ofUAS over a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned 

aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, the 

use of the UAS in order to facilitate commerce could lead to economic growth. 

Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their 

desired photographic subjects that cannot be displayed through ground level 

videography/photography. Aerial surveying and inspections can increase planning 

efficiency, improve resource estimations, and reduce risks to personnel and property. 

The petitioner will provide clients with photographic data for these purposes on a 'for 

hire' basis acting as an independent contractor. Flight data including UAS flight time, 

Control Unit operation time, incident, accident, and details concerning any deviations 

from normal operations will be available upon request for use in collecting data 

regarding the use of UAS as part of these applications. 

Conclusion 

The petitioner is requesting this exemption for the purposes of aerial photography, 

cinematography, and videography. The petitioner wishes to provide safe and reliable 

services for businesses such as but not limited to, real estate, architecture, land 

surveying, engineering, television, cinematography, and news gathering. By 

providing safe deployments and cost effective operations through UAS the petitioner 

offering a much needed and desired service in the community. The petitioner can 

ensure adherence to standards and protocols and can develop and refine generally 

applicable safety guidelines and processes. The primary purpose of seeking this 

exemption is to obtain the capability to offer UAS services while remaining in 

compliance with FAA regulations. The petitioner has 4 years of experience in the 

UAS and radio control model aircraft hobbies and wishes to move forward in this 

ever growing industry. Finally, I am a USAF veteran, Private Pilot, and have a great 

deal of respect for and knowledge of the regulations that I need to work within. Your 

consideration is greatly appreciated. 

' 

~~ Sam Casale