July 16, 2015 U.S. Department ofTra nspor tatio n Docket Management System 1200 N ew Jersey Ave, SE Washington, 

### DC 20590 Re: Exemption req uest p u rsuant to Section 333 of the F M Reform Act and specified parts u nder 14 CFR, t he Fede ral Aviatio n R eg ul ations Dear Sir or Madam: Pursuant to Section 333 of the FAA Mode rnizatio n and Reform Act of 2012 {the "Reform Act") and 14 CFR Part 11 , Kalamazoo Drone Im agery, LLC, an "o perato r" of Unmanned A ircraft Systems {" UAS") fo r aeria l photography and videography , hereby applies fo r an exemption (see list ofexemptio ns below) from the l is

t ed Federal Aviatio n Regulatio ns {" FARs") to allow co mm ercial operation of its UAS platforms i n the Nati onal Ai rspace System ("NAS")
. Th is application is submitted by: Company: Ka lam azoo Drone Imagery, LLC Owne r/ Operators : Joshua S. Iocca, Oavid Frew, Brian Austin Phone: 269 · 598 · 3300 Address: 4021 E. Hilland ale Or. Kalamazoo, M149008 Email: kzood rone i mage ry@gmail.com The following are the sections of 14 CFR from whi ch we seek an exemption: 14 C.F
. R
. 21 14 C.F.R. 91.9{b)(2) 14 C
. F.R
. 91.203 {a) and (b) 14 C
. F
. R
. 45
.23(b) 14 C.F
. R. 91.103 14 C
. F
. R
. 91
. 205 14 C.F.R. 61.113{a) and {b) 14 C.F.R. 9 1. 119 14 C.F
. R. 91.2 15 1 4 C
. F .R
.61.133(a) and (b) 14 C
. F
. R
. 9 1 .121 1 4 C. F.R
. 9 1.405 (a); 407 (a) (1); 409 (a) 1 4 C.F.R. 91 .7(a) 14 C.F.R. 91.151(a) (2); 417(a) 

### & { b)

The extent of relief we seek and the reason w e seek th e relief: Commercia l operation of a sm all UAS, as described herei n, whic h are eq u i pped w it h camera{s) and sensors, would operate in th e follow ing manner: • Aerial p hotography and/or video for public and/or private use inclu ding rea l estate, archi tect u re, land su rveyi ng, engineering an d other related p rofessiona l activiti es. • Aerial vid eo and/or photograp hy for public and/or private use inclu ding tel evision, public e vents, ci nematog rap hy and news gatheri ng. 

## • • • Aerial i nspection/photography o f residential/commercial s tru ct u res under contract with the owners or loca l governme nt authority. Aerial inspection/p hotog raphy of re siden tial/commercial ut ility i nfrastructu re in clud ing but not l imited to electri cal power lines, wind turbines and cell towers . Aerial video/photography or provid ing live video feed to assist with search and resc ue op eratio ns i n cases of an emerge ncy or natura l d isaste r only wh en the loca l authorities or government has req uest ed it by contract or donati on.As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fu lfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to"
.... establish requirements for the safe operation of such aircraft systems in the national airspace system." How our request would benefit the public 

### as a whole : Gra nting Kalamazoo Drone Imagery, LLC our request for exemption will allow for local services such as real estate and marketing, and will allow growth for the local economy. There is a shortage of certified individua l(s) and companies that provide aerial photography and videos in the area, thus driving up the cost for such services- making it cost prohibited. Th e UAS platform for Kalamazoo Drone Imagery, LLC provides a safe and cost effective method for the local economy to showcase its greatest assets. Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule: The high standards and regards to safety of Kalamazoo Drone Imagery, LLC will provide the benchmark for local competition and will drive for safer options to a much - needed service in this geographical area. The selected UAS platform has many safety measures in place that will significantly lower the risk of safety related incidents- from the heightened operator aware ness to the engineered safety features. The operating limitations proposed by Kalamazoo Drone Imagery, LLC provide for a higher level of safety because UAS operation s further enhance safety of aerial photography operations over using conventional aircraft. These limitations and condition s to which Kalamazoo Dro ne Imagery, LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include : Operator Awareness o Pre-flight Checklist • Ensure that you are using only genuine parts and that all parts are in mint condit ion
. • Ensure the remote controller, Intelligent Flight Battery, and mobile device are fully charged. • Ensure that there is no foreign object stuck to the camera lens, t he micro-SD card has been inserted into • The camera, and the gimbal can rotate freely before powering it on. • Ensure the propellers are securely mounted on to the motors, and th e motors can start and function normally. • Follow the on -screen instructions to calibrate the compass. • Ensure the DJI Pilot app and aircraft's firmware have been upgraded to the l atest version. • Ensure that your flight area is outside the No-Fly Zones and flight conditions are suitable for flying the aircraft. • Be sure t hat you are NOT flying under the influence of alcohol, drugs or any substance that may impair your cognitive abilities
. • Be familiar with the selected flight mode and understand all safety functions and warnings. Be sure to observe all local regulations , obtain appropriate authorizations, and understand the risks. 

### o Fly the aircraft only within line of sight; p. ilot in command (PIC) and/or visual observer (VO) • The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

## • o Respective airports will be contacted if operating within 5 miles of an airport to be granted permission to enter air space. 

### o Submission to the controller' s safety warnings and alarms. (Such as power warnings, calibration needs and connection errors) 

### o Flights will be operated at an altitude of no more than 400ft. above ground level. o Under still air tbe maximum speed is no more than 3Smph with a cruising speed of 25m 

### ph. The DJI Phantom 3 Professional's Engineered Safety Features: 

### (Thefollowing isfrom the Phantom 3 Professional User Manual) o Maximum Speed of 35m ph o Weight of< 31bs. o Maximum flight altitude limit capabil ity. o Maximum flight range limit capability. 

### • If 

### you fl y out of the limit, you can still control the Phantom 3 , but cannot fly it any farther. If 

### tl1e Phantom 3 flie s out of the max radius in R eady to Fly (non

GPS) mode , it will fly back within range automatically . • If the Phantom 3 fl ies out of Lhe max radius in Ready to Fly (non-GPS) mode , it will fl y back within range automatically . • The software prohibit<; flight in " no-fly zones "
. Motors will not start and warning will notif y pilot that take off is prohibited. o Return t o Home (RTH) function

- brings the aircraft to the last recorded home point. • Smart RTH - 

### button on controller t o bring aircraft horne • Low Batter y RTH- 

### the RTH 

### fea t ure is automatically triggered when the D.H Intelligent Flight Battery is depleted t o a point that may affect the safe return of the aircraft. • Failsafe RTH - 

### the RTH 

### feature is automatically activated 

### ifthe remote controller signal is lost for more than 3 seconds.
o Vision Pos itioning System (VPS) • With the use of ultrasound and image data, the ai rcraft is ab le to maintain its current position. This will allow for the aircraft to hover in place more precisely where a GPS signal is not available. o DJI Intelligent Flight Battery Functions • Battery level display • Battery life display • DJI Phantom 3 Professional (same UAS as in Granted Exception No. 11911) o General Features • Ready to fly 

## • 

## • • 

## • • 

## • • • • 

## • • 3-axis camera stab ilization Precision flight and stable hovering GPS/GLONASS position i ng 

### & auto return home Onscreen rea l-time f light parameters High Definition 4k Camera Camera tilt control F

ilm straight down Supports Adobe DNG RAW Adobe lens profile support Camera parameter settings Album synchronization FAA no-fly zones locked out via installed software o Transmitter Operating Frequency: 2.400 GHz - 2.483 GHz • Communicat ion Distance (open area): CE: 2000m; FCC: 2000m • Receiver Sensitivity (1%PER): - lOldBm 

### +/- 2dBm

## • • 

## • o Cam era Transmitter Power: CE: 16dBm; FCC: 20dBm Working Voltage: 1.2A@ 7.4V Battery: 6000 mAh liPo 2s
• Operating Environment Temperature: 0° ( -40° ( • Max Resolution: 4096 x 2162p @ 24/25fps • Sensor size: 1/2.3" • HD Recording : 4k p 24/25fps 

## I 720p 60fps 

### o DJI V i si on 

### App System Requirement of Mobile Device: iOS version 6
.0 or above/ Android system version 4.0 or above • Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, iPod Touch5; Given the specifications of the UAS platform , engineered safety features and operator awareness check list, the app roval of this application pres ents no national security issues. Regarding the impact to the public and the safety protocols in-place, Kalamazoo Drone Imagery, LLC requests your approval with minimum delay. Explanations of Requested Exemptions • 14 C.F
. R. 21: Certification Procedures for Products and Parts. o This regulation is designed for manned aircraft. It is not suitable for the UAS Platform of Ka lamazoo Drone Imagery, LLC. Thi s regulation is designed for manned aircraft. It is not suitabl e for off-the-shelf or production UAS. All parts come from the manufacturer
. Substantive replacement pa rts (i.e. motors, propeller blades, radio transmitters, etc.) also come from the manufacturer or an authorized vendor with approved after- market compon ents and will ensure correct equipment is used to replace substantive parts of the UAS craft.
• 14 C.F
. R. 45.23(b): Disp lay of Marks; general. o Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed
. Given the size of the UAS, two- inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45
.29 (f)
. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working with the UAS wi ll see the identification of the UAS as "Experimental."
• 14 C.F.R.61.113(a) and (b): Private pilot privileges and limitations: Pilot in command
. o Kalamazoo Drone Imagery, LLC can achieve an equivalent level of safety as achieved by current regulations because our UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F
. R. 61, et seq. Thus, allowing us to operate our UAS to meet and exceed current safety levels in relation to 14 C.F.R. 61.113 (a) 

### & (b).
• 14 C.F.R
.61.133(a) and (b): Commercial pilot privileges and limitations. o Kalamazoo Drone Imagery, LLC can achieve an equivalent level of safety as achieved by current regulations because our small UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my smallUAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 61, et seq. Thus, allowing us to operate our small UAS to meet and exceed current safety levels i n relation to 14 C.F
. R. 61
. 133 (a) 

### & (b). 14 C.F.R
. 91.7(a) : Civil Aircraft Airworthiness. o The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. o Given the size of the aircraft for maintenance and use of safety checklists prior to each flight an equivalent level of safety will be provided.
• 14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Man ual in the Aircraft. o The need to have an aircraft manual on board does not apply. UAS aircraft information manuals will be kept by the operator.
• 14 C.F.R. 91.103: Preflight action. o This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
• 14 C.F.R. 91.119: Minimum Safe Altitud es. o Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 {d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter comp lies with any route or altitudes prescribed for helicopters by the FAA
. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their preobtained consent.
• 14 C.F.R. 91.121: o This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "
...to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitud e read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions.o Section 91.151 {a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions} there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed, (1) During the day, to fly after that for at least 30 minutes
..." o The battery powering the OJI Phantom 3 Professiona l UAS provides approximately 20 minutes of powered f light. Operations would be impossib le to conduct in order to meet the 30- minute reserve requirement in 14 CFR 91.151. Given the limitations on the UAS' s proposed flight area, its proposed flight time , and proposed operations within a predetermined location , 14 CFR 91.151 is inapplicable. Furthermore, operating the UASs in a tightly controlled area where only peop le, property owners, and/or official representatives will be allowed, less than 30 minutes of reserve fuel does not endanger the type of risk that 91.151 was intended to address
. o The owner/operator of Kalamazoo Drone Imagery, LLC affirms that safety can be achieved by limiting flights to end with a 25% battery reserve as indicated on the PIC's controller mounted monitor
. This restriction would be more than adequate to return the UAS to its predetermined landing area . • 14 C.F.R. 91.203 (a) and (b) : Carrying Civil Aircraft Certification and Registration
. o The UAS fully loaded weighs no more than 55 lbs
. and is operated without an on board pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS wi l l have immediate access to them; to the extent they are applicable to the UAS.
• 14 C.F.R. 91.205 : Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements. o Section 91.205 pertains to cockpit instruments for manned aircraft occupied by at least one pilot
. This is not applicabl e to UAS. However, to ensure an equivalent level of safety and information, transmitted telemetry will be sent to the PIC and displayed on a video screen indicating various parameters including, but not limited to, GPS altitude, GPS signal, battery power remaining, time in flight, UAS ground speed, etc.
• 14 C.F.R. 91.215: ATC transponder and altitude reporting equipment and use. o The UAS craft will have insufficient useful load and power supply to operate a transponder. Furthermore, operations offered by the blanket COA will occur below ATC radar coverage . To ensure an equivalent level of safety, when operations exist near a public airport, the operator will notify the local airport or ATC facility to advise them of the operation. If operations exist in an area not covered by the blanket COA, then a specific COA for that operation will be obtained by the local FSDO and specific case-by-case coordination with ATC will be made for the UAS flight.
• 14 C.F
. R
. 91.405 (a) ; 407 (a) (1); 409 (a} (2); 417(a) & (b): Maintenance Inspections. o These regulations require that an aircraft operator or owner " shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section , have discrepancies repaired as prescribed in part 43 of this chapter
... ," and others sha l l inspect or maintain the aircraft in compliance with Part 43
.

### o Given th at th ese section and Par t 43 app ly only to aircraft with an air

w ort h in ess certificate, these sections will not apply to the applicants. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The ope rator will ensure that t he UAS is in worki ng o rder prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy cond ition to provide the equivalent level of safety. o An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manua l. As provided in t h e Fl ig ht Operating Ma nua l, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed
. In summary, Kalamazoo Drone Imagery, LLC seeks exemptions from the regulations stated above to commercially operate our small UAS in aerial photography, real estate operation, videography and other opportunities whi ch may present itself
. Granting Kalamazoo Drone Imagery, LLC's request for exemption will reduce current risk levels and thereby enhance safety
. Our UAS aircraft does not contain potentially explosive fuel , i s smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time
. Furthermore, we operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. Sincerely,

Joshua S. Iocca



# ~ David Frew



# ~AL Brian Austi n Kalamazoo Drone Imagery, LLC 4021 E. Hillandale Dr. Kalamazoo, Ml 49008 kzoodroneimagery@gmail.com 269-598-3300