CasalePhotography Sam Casale, Owner (andFAAlicensedPrivatePilot) 2210 Autumn Glow Court BelAir, MD 21015 CellPhone- 443-643-5928 email: Sam@CasalePhotography.com January 11, 2016
U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room wl2-140 1200 New Jersey Avenue, SE., ·washington, DC 20590

Dear U.S. Dept. ofTransportation 

### IFAA: In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 ofthe FAAModernization and ReformAct of2012, Sam Casale, referred to as the petitioner, kindly request exemption from the following sections ofTitle 14, Code ofFederal Regulations 

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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 relieffrom the listed regulations in order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated bythe Federal AviationAdministration (FAA) for the purposes ofaerial real estate photography, videography, cinematography, and other aerial operations that canbe performed safely and more cost effectively withthe use ofsmall 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 byproviding UAS alternatives to previous methods of larger, more dangerous aircrafts. Compensated tasks will be conducted only at therequest of, and with authorization and permission of, clients or their authorized agents in compliance withprivacy laws and FAARegulations. In addition, onlythe authorized individual/Operator, SamCasale, will conduct UAS flights within and underthe conditions outlined herein or as maybe established bythe FAAas required by Section 333.

The FARs I, the petitioner seek exemption from the above mentioned FARs for the following reasons; 61.113(a) & (b) I, SamCasale, do hold anFAAPRIVATE PILOTS LICENSE (cert# 216726190). However, this sectionlimits privatepilotsto non-commercialoperations. In addition, I will operatethe UAS with the addition ofa trained observer. All pre-flight inspection, maintenance and flight logs will be saved and made available to the FAAfor review; with the purpose ofsafely integrating civil UAS operation in the NationalAirspace System. The petitioner will conductflights as the authorized UAS Operator. The UAS controlledbythe Operator will perform at altitudes, alwaysbelow 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 closerthan 500 feet to the ground mayrequire that the UAS be operated closerthan 500 feet to essential persons, or objects that would notbe possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "denselypopulated". The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas ofsubdivisions and neighborhoods ifrequired. The petitioner will primarily operate the UAS between ground level and 200feet. The UAS will be operated over**deslgn~teclproperties** with the consent ofthe local municipality or their designated agent, and while maintaining a safe distance from persons. Inaddition, since the purpose isphotography, the UAS willbe operated at a very slow forward speed, andin fact willjustbehoveringthe majorityofits time inthe air. The petitioner will compile flight data from the logs. This data may assist the FAAin development ofregulations 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 reliefhas been granted for manned aircraft to operate at less than the prescribed minimums, including ExemptionNos. 2689, 5745, and 10650. In addition, similar UAS specific reliefhas been granted in ExemptionNos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining inpercent to the Pilot In Command. The UAS batteries provide approximately 25 minutes of powered flight. Information provided in the·operating documents discusses procedures regardingremaining battery power management. Those documents contain a condition in whichthe PIC will initiate a landing procedure whenbattery remaining reaches a specified level. Given the limitations on proposed operations and the location ofthose proposedoperations, 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 FAAfound 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 ofinterests for UAS commercial use Aerial :videoandorphotography for real estate, architecture, land surveying, engineering, television, and cinematographyare the interests I ampursuingthis exemption. Aerial inspections and or photography ofresidential or commercial structures will be the overwhelmingmajorityofmybusiness. In addition, I plan to offer live streaming aerial video in efforts assist in search and rescue operations ONLY at the request ofand with legal authorization oflocal authorities or government. Local law enforcementhas expressed an interestinthis service inour smalltown.

The UAS
The petitioner seeks exemption to operate UAS Multifunctional Quad-rotor Systems byDJI (DJI Phantom 3, and DJI Inspire 1) for compensation or hire within the NationalAirspace System. The DJI Phantom 3, and Inspire 1 are highly dependable consumer grade small rotor crafts in the quadcopter configuration. They are verticaltakeoffand 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 andposition. 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 "Returnto Home" and assist operations for either loss ofRC 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 capabilityto abort a flight and return to home safely in case ofany unpredicted failures, obstacles or emergencies. Iview theseunits as highly sophisticatedtools. The qualityoftheseunits does well to separatethem 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'slicense Ihave theutmostrespect for the FARs andthe aerial safety that is the intended result ofthose 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 orderto manage and mitigate risk and ensure public safety.
• Apreflight checklist is being developed and employed to ensure that the UAS airworthiness and will be verified before each launch (I calibrate onevery launch). Airworthiness will be maintained by performance ofroutine inspectionsbefore each flight, maintaining flight and maintenance logs. These documents will bemade available upon request to assist in future implementation ofsafety standards andregulations.
• The petitioner will only operate the UAS over designated properties with client andpropertyownerconsent. • Flightplans will be predeterminedto 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 alwaysbe within VLOS ofthe PIC and the observer. The petitioner/Operator will carry suitable insurance for the protection ofthe Operator and the Public thus providingpositive and responsible UAS operations in the community.
PreflightandTake-offCheck List:

1. Onhand 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 takeoffdistance 4. Establish reasonable low altitudes to ensure safety ofcivil aircrafts 5. Obtain consent ofall persons involved in filming including land and property owners Visual Inspection ofaircraft 6. Prepare digital flight logs 7. Flight battery and transmitterbattery at full charge 8. Propellers are inproper 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 controlmovement evaluation. 11. Visually inspect for controlled flight performance along with ground station data. Flights will be operated within line ofsight ofa 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% batterypower reserve• -'i

should that occurprior 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 ofgreaterproportions, carrying a crew and flammable fuel. Additionally, the 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 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 withphotographic 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 ofUAS as part ofthese applications.

Conclusion The petitioner is requesting this exemption for the purposes ofaerial 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 muchneeded 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 ofseeking this exemption is to obtain the capabilityto offer UAS services while remaining in compliance with FAAregulations. The petitioner has 4 years ofexperience inthe UAS and radio control model aircraft hobbies and wishes to move forward in this ever growing industry. Finally, I am aUSAF veteran, Private Pilot, andhave a great deal ofrespect for andknowledge oftheregulations that Ineedto workwithin. Your considerationis greatly appreciated.

# ~~ ' SamCasale