January 22, 2016 Elmer's Aviation, LLC 3600 Rennie School Road Traverse City, MI 49685 U.S. Department

of Transportation Docket Management System 1200 New Jersey Avenue SE Washington,
DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Sir or Madam, Pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Elme r's Aviation, LLC seeks an exemption from Federal Aviation Regulations ("FARs") listed below for one (1) DJI Phantom

2 Professional and one (1) DJI Phantom

3 Advanced, quadcopters manufactured

by DJI-Innovations. The requested summary exemption would support an application for a "blanket" commercial Certificate
of Authorization

to use the system to capture aerial photography and videography. Both DJI Phantom systems consist of a lightweight (2.8 lb) battery operated aircraft,

a tablet-based ground control station and/or RC Controller, and associated communications equipment. The aircraft carrie

s an onboard gimbaled camera that allows

it to obtain photographs and video. The requested exemption would permit Elmer's Aviation, LLC to pursue its commercial interests

in providing services
to clients using
a small advanced UAS in the following areas: • Real Estate/Architecture • Construction Site Inspection • Marketing • Surveying/Mapping • Sporting Events • Special Events/FestivalsThe regulations from which the exemption

is requested areasfollows: -14 CFR Part21 -14 CFR 91.203 -14 CFR 45.10 -14 CFR 45.11 -14 CFR 45.23, and 45.29 -14 CFR 91.9 -14 CFR 61.101(e)4 and (5) -14 CFR 61.113, 61.133 -14 CFR 61.23(a) -14 CFR 61.3 and 61.315(a) -14 CFR 91.109, 91.119 ..14 CFR 91.121, 91.151 -14 CFR 91.203 (a) & (b), 91.205, and 91.21
5 -14 CFR Subpart

E (91.401- 91.417, and 91.7(a), and 91.9 (b)(2)) -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Unmanned Aircraft System UAS areoften seenas superior
to helicopters

asanaerial video gathering platform due tothe smaller size of the devices, lower fuel emissions, more affordable equipment and personnel cost,reduced noise, and amuch smaller environmental impact which promotes public safety. In the unlikely eventof acrash, anUAS systemwould be asmaller risk tothe public at large versusafueled manned aircraft. Elmer's Aviation, LLC is petitioning for an exemption

to operateone (1) DJI Phantom

2and one (1) DJI Phantom

3 Advanced (DJI P2 and DJI P3) with
abuilt-in stabilized HD cameraand the following GPS safety features: •Restricts the height Above Ground Level (AGL) toa specified user generated height. •Restricts the radius of flight from the ground station toa user-generated distance. •Restricts operations within designated Class B, C, andD airspace including

a no-fly zonefeature. The DJI Phantoms also have
afailsafe function that is triggered

in the event communications
arelost between the UAS and the main controller transmitter.

In the unlikely eventthis occurs,the UAS will returntoits point of takeoff and land safety.
If communications

arerestored, the PIC can regain control of flight and land manually. These specifications meetwith the Model Aircraft Operating Standards (AC 91-57) assetbelow: 1.The petitioner will only operateits UAS in

l ine-of-sight

of aPilotin Command (PIC) and/or ground based Visual Observer (VO) andwill operateatsites that are'sufficient distan ce' from populated areaswithin the
s terile area described

in the FOPM. Such operations will ensure that the UAS will "not create

a hazard to users of the national airspace system or the public." The orientation

of flights will be such that the PIC or VO always has a visual on the rear mounted LED flight Indicator. Additional safety features on the DJI Phantom

2 and 3 include an automatic return-to-home featu

r e enacted upon low battery level. 2. When flying the UAS within three (3) mi les of an airport the operator will give the right-of-way

to any manned aircraft. 3. Pre-flight inspection would include checking battery condition/level in the transmitter, control tablet, and UAS;
a visual/operational check of the propellers;

a visual/operational check of the aircraft;

a visual/operational check of the motors;

a visual/operational check of the transmitting radio control unit;
a visual/operational check of the camera and gimbal unit; and a visual/operational check of the vision positioning system.

A check for power-lines, antennas, and other overhead objects would also be performed. Wind and weather conditions would be monitored and be taken into account as a factor for flying. 4 .The radio frequency
of the DJI Phantom

2 and DJI Phantom

3 is in the 2.400 to 2.483 GHz range. Maximum takeoff weight approximately 3000g. Max Ascentjdecent speed

5 m/s. Maximum flight Velocity 16 m/s. The UAS to be operated by the petitioner weighs less than
3 pounds, including
all payload (i.e. battery, camera, lens, and stabilized gimbal). 5. The PIC will have
a minimum
of 15 hour
s flying time with DJI equipmen

t. 6. Flights will be terminated when battery energy levels reach 25°/o, allowing sufficient reserve flight time to safely land the UAS. If battery drops below

a user specified level the UAS will automatically return to its takeoff point and land safely

. 7. The UAS will be programmed

so it will not be operated
at an altitude that exceeds 400 feet AGL, and not more than 200 feet above

a significantly elevated geographic position from which videography/ photography

is planned. 8. The intended use of these DJI Phantoms

2 and 3 is to aide in visual surveys of sites, record development
for m arketing purposes, etc. 9. All photo/video flights would have the date, time, GPS coordinates along with the camera metadata recorded

in an in-app flight log on the mobile device serving as the in-flight monitor/tablet. This flight log record

s flight path, altitude, flight time, number of images shot,amountof video shot, date, time, and total flight distance. Each individual flight has the capability
of playing back (in-app)

in real time and is synced acrossdevices via DJI's in-app User Center. 10. Given th esmall size of the UAS and the restricted sterile environment within which
itwill operate,Elmer's Aviation

,LLC's operations will adhere tothe Reform Act's safety requirements. 11.The DJI Phantom

2and DJI Phantom

3 Advanced will neverbe willingly flown in the flight path of manned aircraft. With the first condition listed, always keeping

avisual line of sight, being of utmost importance

to providing

a significant level of public safety. In summary

,Elmer's Aviation, LLC respectfully request exemption from regulations specified above, under Section 333toenable Elmer

'sAviation, LLC to operate efficient, limited, and low-risk commercial UAS operations for the activities stated above, respecting
atall times the spaceand privacy of citizens and property,while keeping airspace safe. Granting this requestwould bein good public interest by giving an opportunity for real estate photographers
and sporting event photographers

tooffer safer, unique views, and more competitively priced aerial photography

tothe general public. By using

the DJIP2 and P3 UAS to perform aerial acquisitions, the substantial risk tolife and property

in the air and onthe ground, which
is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crewmembers located onboard the aircraft, the DJI P2 and P3 UAS (weighing approximately

3 pounds maximum gross weight with dimensions

of 22 Inches squareeach, and with nofuel on board), has less physical potential for collateral damage tolif eand propertyonthe ground andin the air compared
tothe manned

aircraft that typically conduct similar operations (weighing approximately 3000 pounds with
a wingspan
of approximately

42 feet,
a length of 34 feet, and afuel capacity of 50 gallons). We are willing and able to modify oramend any partof this requestto satisfy the need for an equivalent level of safety. We look forward to working with youroffice. Please feel free tocontactusat anytimeif you require addition
al information

orclarification. Best regards, .,.**--- ~** 

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**-----** Eimer's Aviation, LLC Eric Ritchie 3600 Rennie School Road Traverse City, MI 49685 eritch ie@tea mel mers.com (231) 943-3443