August 27, 2015

U.S. Department of Transpiration Docket Management System 1200 New Jersey Ave. Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Refor m Act and Part 11 of the Federal Aviation Regulations

Dear Sir or madam:

Pursuant to the Section 333 of the FAA Modernizatio n and Reform Act of 2012 (the “Reform Act”), Jason Vanacker (the “applicant”), operator of an Unmanned Aircraft Systems (“UAS”) seeks an exemption from the Federal Aviation Regulations (“FARs”) to allow for commercial operation for aerial imaging and vid eo of real property (listed real estate, private prope rties, golf courses, resort properties) and events (weddings, festivals, receptions, parties & concert s).

Applicant:

Jason Vanacker
114 Briarwood Dr. Prudenville, MI 48651

Aircraft Type & Specifications:

Make: DJI
Model: Phantom 2 Vision+ Weight: 1242g Diagonal motor-motor distance: 350mm

Regulation from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2)

14 CFR 91.103
14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) and (b)Extent of relief and purpose:

14 CFR Part 21 subpart H

The USA to be operated carried neither pilot nor pa ssenger and carries no explosive materials or flammable liquids. Given the size, weight, speed a nd limited operating area associated with the aircr aft to be utilized, I request exception. In the restri cted environment and under the conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthi ness certificate without said restrictions.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for t he aircraft, should this exemption be granted, no F AA regulatory standard will exist for determining airw orthiness. Given the size of the aircraft for maintenance and use of safety check list prior to e ach flight an equivalent level of safety will be provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the USA has no ab ility to carry a flight manual on the aircraft. Th ere is no room, capacity or pilot on board to adequately c arry flight manual. An equivalent level of safety will be maintained by keeping the flight manual at groun d control point where the pilot will have immediate
access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal procedures including but not limited to; rev iewing weather, flight battery requirement, landing and takeoff distances, along with all of those foun d in attachment “DJI Pilot Training”. An equivalen t level of safety will be provided by preflight proto col to properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achie ved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircr aft, and by the speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

I can achieve an equivalent level of safety as achi eved by current regulations because my UAS does not carry pilot nor passenger. While helpful, a pilots ’ license will not ensure remote control piloting s kills.14 CFR 91.121

The USA may not have a barometric altimeter, but in stead does have a GPS altitude read out. I believe an exemption may be needed. An equivalent level of safety is achieved by the operator receiving live flight data monitoring and confirming current altit ude along with altitude of launch site shown on GPS
altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to 14 CFR 91.9 (b) (2), given the size and configuration, the USA has no ability to carry cert ificate and registration documents on the aircraft. There is no room, capacity or pilot on board to adequatel y carry such documents. An equivalent level of safet y will be achieved by keeping these documents, to the extent they are applicable to the USA, at the g round control point where pilot has immediate acces s to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91 .409 (a) (2) and 14 CFR 91.417 (a) and (b)

Given these section only apply to an aircraft with an airworthiness certificate, these sections do not apply to this applicant. As a safety precaution, o perator will perform preflight inspection and ensur e UAS is in working condition before initiating each flight.

Jason Vanacker is seeking relief from all FARs abov e preventing applicant from conducting aerial photography and video of real property and events t aken at levels less than 400 feet. The UAS to be used is a DJI Phantom 2 Vision+. At 1242g, the wei ght of the UAS meets the definition of “small
unmanned aircraft” found in Section 331 of “The Ref orm Act”. The maximum speed of the UAS is 15m/s. The UAS is battery powered with no combusti ble fuels on board. Maximum flight time for this particular UAS is 25 minutes battery life and all f lights to be terminated with 25% battery life remai ning. Given the size, weight, speed and limited operating area associated with the aircraft to be utilized, I find this exception to be reasonable with an equivalent, or greater, level of safety to be reached by the
operator.

Safety:

Please see attachment “DJI Pilot Training” for safe ty precaution I use for every flight.

Additionally:

• I do not operate within 5 miles of an airport unles s prior contact to the Air Traffic Control of the airport manager has been made.

• I land my UAS prior to manufacturer recommended min imum level of battery power.

• I pilot my UAS through remote control by line of si ght.• My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position

and then slowly lands if communication with the rem ote control pilot is lost.

• I actively analyze flight data and other sources of information to constantly update and enhance safety protocols

• I conduct extensive pre-flight inspections to ensur e aircraft functionality.

• I always obtain all necessary permission prior to o peration and I have procedures in place to abort flights in the event of potential danger.

Public Interest:

The use of aerial imagery made possible with the us e of a UAS is a dynamic marketing resource for real estate, hospitality and event clientele. It allows them to provide their customer viewpoints only available from an elevated position. This type of imagery when combined with a great marketing strategy boosts revenues and stimulates local, regi onal and national economies. It can also indirectl y benefit other businesses in the area by encouraging tourism. Through the use of a UAS, aerial imagery can now be capture much more efficiently and cost e ffectively than traditional aviation methods. Savi ng time, fuel, emissions and possibly even human life in the event of a mechanical failure.

Thank you for your consideration

Jason Vanacker