Ramin Haghighi President Millennium Property Investment Group 24910 Las Brisas Rd. Suite 112 Murrieta, CA 92562 Cel1951-264-6400 Email: 4ramin@gmail.com

U.S. Department ofTransportation DocketManagement System 1200NewJersey Ave; SE Washington, DC. 20590

RE: Exemption Request Section 333 ofthe FAAReformAct of2012

Attachments: 1) DJI Inspire 1 Quick Start Guide.Vl.4 2) DJI Inspire 1 User Manual Vl.8 3) DJI Inspire 1 Safety Guide LinesVl.O 4) DJI Inspire 1 Maintenance Manual Vl.O

References: 1) FAAExemptionNo. 11138, Regulatory DocketNo. FAA-2014-0481 in the matter ofthe petition ofDOUGLAS TRUDEAU. 2) FAAExemptionNo. 11136, Regulatory DocketNo. FAA-2014-0508 in

the matter ofthe petition of ADVANCED AVIATION S()LUTITIONS LLC. 3) FAAExemptionNo. 11080, Regulatory DocketNo. FAA- 2014-0355 in the matter ofthe petition ofFLYING CAM INC. 4) FAAExemptionNo. 11405, Regulatory DocketNo. FAA-2015-0118 in

# ~'""·''-'"~~~~.....:....---------------------------·······The matter ofthe petition ofBRIAN CHERRY.

Dear Sir or Madam,

In accordance withthe FAA's Guidelines for Submitting a Petition for Exemptionunder Section 333 ofthe FAA Modernization and ReformAct of2012, Millennium Property Investment Group referred to hereafter as the petitioner, request exemption from the following sections ofTitle 14, Code ofFederal Regulations§§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.15l(a); 91.405(a); 91.407(a); 91.409(a); 91.409(a) (2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated bythe FederalAviationAgency (FAA) for the purposes ofaerial photography, cinematography, Videography, mapping, crop surveying, inspections and other flight operations that could be Performed safely and more cost effectively with the use ofsmall UAS at low altitude withinthe U.S. national airspace system as compared to a manned aircraft. Operations will be performed only atthe request ofand withthe authorization and permission ofclients ortheir authorized agents in order to facilitate commerce and raise awareness ofthe beneficial uses ofsmall unmanned air systems. So long as such operations are conducted within andunder the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1-3.


### TheFARS

The petitioner seeks exemption from the above mentioned F ARs for the following reasons; 61.113(a) & 9b); The petitioner requests reliefin order to facilitate the utilizationof pilots who hold a Private Pilots (or greater) certificate. Any pilots operating under this exemption



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# .........would berequired to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions.
91.119(c) As discussed inExemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UAbe 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 conditionto allowreasonable operations in areas ofsubdivisions and neighborhoods ifrequired.

91.121 As discussed in Exemption 1138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter butinstead utilizes electronic GPS with barometric sensors for altitude information.
91.15l(a) As discussed inExemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior reliefhas been granted for manned aircraft to operate at less than the prescribedminimums, including ExemptionNos, 2689, 5745, and 10650. In addition, similar VAS-specific reliefhas been granted inExemptionNos, 8811, 10808, and 10673 for day time VFR conditions. The 

### VAS provides battery power reaming inpercent to the PIC. The UAbatteries provide approximately 18 minutes ofpowered flight. Information provided inthe operating documents discuss procedures regarding remaining battery power management. Those documents contain a condition inwhich the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations onproposed operations and the location ofthose proposed operations, the FAAfound that a reduced minimumreserve for flight in day time VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & 

### (b) As discussed in Exemption 1138 (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 FAAfound that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

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TheUAS

The DJI Inspire 1 is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of2935 g designed primarily to carry aloft a high definition camera. Ithas an advertised maximum speed oflessthan 30 knots (22m/s) and a maximum climb rate ofless than 1200 feet per minute (5rnls) Itis powered by four electric motors. Itutilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. Itis controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted backto a ground control station allowing the operator and I orPIC to monitor battery levels, GPS signal strength, altitude (AGL), distance from PIC, camera imagery and camera control angle. Ithas failsafe modes ofoperation for either loss ofRC or GPS SIGNAL. Altitude canbe limited by the onboard flight controller and maximum altitude can 

### be programmed bythe PIC. Battery life limits flight times to approximately 18 minutes. The onboard flight controller will warnthe pilotviatelemetry and external lighting cues before reaching a lowbattery state. An automatic termination offlight and landing will be initiated when the battery reaches a predetermined low state (see Phantom Quick StartManual V1.4).



### Risk Mitigation

The petitioner has reviewed FAAexemptions reference's 1-3 (Conditions and Limitations) and believes that the procedures specified are reasonable and will be utilized in orderto manage risk and ensure the public's safety. A preflight checklist will be employed based on manufactures recommendations and operating manual. A preflight check list will be used before each flight (based onmanufactures recommendations and operating manual) to ensure the UAis airworthy before every flight. Airworthiness will be maintained through routine inspections before each flight and maintaining both flight and maintenance logs providing UAtotal time, along with maintenance issues and trends.

The petitioner requests that in a manner similarto reference 3, he be allowed to operate within 5 miles ofan airportprovided that;



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# .....the UAmay not operate in Class B, C, or D airspace without first obtaining written approval from the FAA. The UAmay not operate within 5 nautical miles ofthe geographical center ofa towered airport as denoted on a current FAApublished aeronautical chart, unless a letter of agreement with the airport's management is first obtained and the operations are conducted in compliance with any NOTAMS. The letter ofagreement with the airport management will be available to the Administratorupon request.
Operations within 5 miles ofan airport are not anticipated to be routine, butthe petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s), should need arise. Operations within class B airspace are requested due to the lack ofmode C transponder. 

### Public interest

Use oftheUAS inlieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft ofgreaterproportions, carrying a crew and flammable fuel. Additionally, use ofthe UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners ortheir designees seeking an enhanced perspective for characteristics, amenities and benefits oftheir desired photographic subjects that cannotbe displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use ofpesticides and fertilizer and conservation ofwater as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risk. The petitioner will provide clients with photographic data for these purposes on a "forhire" basis acting as an independent contractor. A visual observer will be utilized. Liability insurance will be obtained commensurate withthe granting ofthis request for exemption. Flight data including UAflight time, Control Unit operation time, incident, accident and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use ofthe UAS as part ofthis application. This data may be submitted to FAA viatraditional means (COAmonthly reports), or other means as the Administrator may require.



### Conclusion

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The petitioner is requesting this exemption for the purposes of"aerial photography, cinematography, videography, mapping, crop surveying, inspections and other flight operations. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy ofhorizontal integration and maximize economies ofscope in order to capitalize on opportunities as they may arise inthe future, without the long turnaround time associated with additional exemptions. The petitioner'sbusiness model is based onthe ideaof offering ad hoc small UAS services to individuals or companies, who wish to employ these services as a safe, effective and legal option to enhance their business or hobby. The petitioner's own marketresearch shows pentup demand for these services currently exist, inthe real estate market and other markets arejustbeginning to emerge. Although videography and photography are included inthe request, the primary objective will be aerial survey offarm crops for precision agriculture. The petitionerhas identified university's and other agencies that could benefit from the operation requested in this application. A quick internet search will show that many are currently operating similar UAS in exactly the same fashion without, it is assumed FAA authorization. The petitioner has refrained from engaging incommercial use ofthe UAS. The primary purpose ofseeking this exemption is to obtainthe capability to offerthose services while remaining in compliance. Only PIC's holding a currentAirline Transport, Commercial, Private, or Sport Pilots Certificate will be utilized as PIC's for operations in reference to the requested exemption

.. The pic must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC must also meetthe flight review requirements specified in CFR 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate.

Respectively submitted,

President Millennium Property Investments Group