August 18 th , 2015 Page 1 AKFlyin Aerial Photography LLC

Steve Grier

Box 448

Newalla, OK 74857

Steve@LiquidMarine.us

August 18 th , 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for exemption under Section 333 from 14 CRR Part 21, Subpart H; 14 CFR 61.113 (a) and (b);

14 CFR 91.109 ; 14 CRR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409
(a) (1); 14 CFR 91.409 (a) (2); 14 CFR 91.417 (a) and (b).

Attachments:

1. Q500 Typhoon Instruction Manuel v2.1 2014

- 04

- 26.PDF

2. Q500 Typhoon Quick Start Guide v2.1 2014

- 04

- 26.P DF

3. AMA SAFETY CODE.PDF

4. Drone pre

- flight checklist.PDF

5. Request.WordDoc

Dear Sir or Madam:

In accordance with section 333 with FFA Modernization and Reform Act of 2012 (the Reform Act) and 14

CFR Part 11, AKFlyin Aerial Photography LLCAugust 18 th , 2015 Page 2 , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial
use of its Small Unmanned Aircraft Systems (SUASs), so long as such operations are conducted within

, and

under

, the conditions outlined herein or as m ay be established by the FAA as required by Section 333 1

.

An exemption is being requested because (1) exiting regulations will burden AKFlyin Aerial Photography

LLC

(2) AKFlyin Aerial Photography LLC can provide a level of safe ty that is equal (or greater than in ma n y cases) to those prov ided by existing rules, and (3) the request is in the public interest. The FAA’s authority

to issue exemptions from operating rules, and the Secretary’s authority granted by Section 333 of P.L.

112

- 95, Special Rules for Certain Unmanned Aircraft Systems, p rovide an opportunity to authorize certain
SUAS operations in the National Airspace System (NAS) prior to completion of the SUASS rule. This
incremental step will allow NOB to safely and legally enter into the NAS.

As described in detail below, the requested exemption would permit AKFlyin Aerial Photography

to operation SUASs under controlled conditions in airspace that is (1) limited (2) predetermined (3)
controlled as to access and (4) would provide safety enhancements to already safe operations of those

aircraft of similar size, weight, speed, and operation ca pa bility that have been granted entry into the NAS

via the rules in Academy of Model Aeronautics (AMA) National Aircraft Safety.

This document was patterned off the petiti on for exemption filed by **In The Air Imaging**

**.**

Code2. Approval of this exemption would thereby greatly enhance safety and fulfill the Secretary of
Transportation’s (the Secretary) responsibilities to ..”establish requirements for the safe operation of suc h

aircraft systems in the national airspace system” per Section 333 (c ) of the Reform Act.

Akflyin Aerial Photography LLC is requesting exemption from the following regulations

14 CFR Part 21, Subpart H
14 CFR 61.23 (a)
14 CFR 61.113 (a) and (b)

14 C FR 91.109

14 CFR 91.121August 18 th , 2015 Page 3 14 CFR 91.151 (a)
14 CFR 91.405 (a)
14 CFR 91.407 (a) (1)
14 CFR 91.409 (a) (2)
14 CFR 91.417 (a) and (b)
This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a)
through (c) of the Refo rm Act. This law directs the Secretary to consider w hether certain unmanned

aircraft systems may operate safely in the NSA before completion of the rulemaking required under
Section 333 of the Reform Act. In making this determination, the Secretary is requ ired to determine which
types of UASs do not create a hazard to users of the NAS, to the public, or pose a threat to national
security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if unmanned aircraft system,
as result of its size, weight, speed, operational capability, proximity to airports and populated areas , and
operation within visua l line of sight (VLOS) does not create a hazard to users of the NAS or the public or

pose a threat to national security, and (2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under 49 USV 44704 is required for the operation of civil (nongovernmental)
UASs. Therefore, if the S ecretary determines that such vehicles “may operate in the national airspace
system, the Secretary shall establish requirements for the sale of such aircraft in the nation airspace
system”. 3

See attached “AmaSafetyCode.pdf” document.

**Operational Overvie w** 

Akflyin Aerial Photography LLC SUAs are quadcopters, weighing (without battery and payload): 1130g
(40.0 oz) takeo ff w eight (with battery and CGO2

- GB): 1700g (60.0 oz) The SUAS have the capability to
hover and move in the vertical and horizontal planes simultaneously. They will operate only in visual line
of sight (VLOS) and will operate only in tightly controlled and limited airspace. They are capable of
operating at speeds of u p to 30 knots, but will routinely operate at much lower speeds. They will routinely
be operated below 200 feet above ground level (AGL), and never above 400 feet AGL.
Akflyin Aerial Photography exemption request would permit its commercial operation of SUAs for aerial
photography and videography in tightly controlled and limited airspace. Aerial photography andAugust 18 th , 2015 Page 4 videography services will be offered to homeowners , realtors, home builders, land owners, and/or home
inspectors for use in, but not limited to, real estate, marketing

, and safer ins p ections of home exteriors.
All operations will be conducted on priva t e property and with the written and/or oral permis sion of the
property owner(s). O perations will always be conducted in areas that are clear of people exp ect the pilot
in command (PIC) and the PIC’s helper(s). Such operations will ensure that the SUAS will “not create a

hazard to users of the national airspace system or the public” 4

.

**Aircraft**

Akflyin Aerial Photography LLC operates a Q500 (Typhoon) SUASs ma nufactured by Yuneec , a well

- known

leade r in quadcopter technology. Yuneec strives to bring new perspectives to aerial work and help

companies accomplish feats safer, faster, and with greater efficiency. They have an unparalleled
commitment to R&D, a cultu re of constant innovation, and a focus on transforming complex technology

into easy

- to

- use devices.

The standard Q500 (Typhoon) quadcopter package includes the Q500 (Typhoon) itself, st10 transmitter
and Personal Ground Station, ST10 LCD Screen Sun Shade/Shield, ST10 LCD Screen Sun Shade/Shield,
STO10 Neck Strap, AC to DC USB Adapter/Charger, USB to Micro USB Cable, USB Interface/Programmer,
5400mAH 3S 11.1V LiPo Battery, 3S 11.1 V LiPo Balance Connecter Charge Lead, DC 11.1 V LiPo Balancing
Charger, DC Automobile Accessory Socket/Cigarette Light Receptacle Adapter, AC to DC Adapter/Power
Supply, 8G microSD Card with Adapter, Motor Holder/Prop Installation Tool, Propellers/Rotter Blades (2
sets)

. The Q500 (Typhoon) is about 16.5 inches in length and 1 6.5 inches in width.

Akflyin Aerial Photography LLC interprets this provision to the place the duty on the Secretary to not only
process applications for exemptions under Section 333 of the Reform Act, but for the Secretary to craft

condit ions for safe o perations of SUAs , if it should be determined that the conditions set forth herein do

not fulfill the stat utory requirements for approval.

Reform Act Section 333 (b)

www.yuneec.com/download/ 20150209080300.pdf

The Yuneec Q500 is a pro

- sum m er grade small rotorcraft in the quadcopter configuration with a take

off weight of 60 Ounces (1700g) designed specifically to carry aloft a high definition camera. It has anAugust 18 th , 2015 Page 5 advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200
feet per minute (6 m/s). It is powered by four electric brushless motors. The Q500’s dimensions are
16.5X16.5X9.5in (420X420X240mm). It utilizes an internal inertial measuring unit (IMU) with
integrated barometric sensor augmented with global positioning system (GPS) to maintain its
geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC)

unit. Real time video and telemetry information is tran smitted back to a ground control station
allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance
from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss

of RC o r GPS signal. Altitude is limited and preprogramed to not exceed 400ft AGL. Battery life limits
flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry
and external lighting cues before reaching a low battery state. An automatic termination of flight and
landing will be initiated when the battery reaches a predetermined low state. It is anticipated that
flights will usually last less than 10 minutes. More information is available in attachment 1 or http://yuneec.com/products/AerialUAV/q500

- typhoon

. The Q500 (Typhoon) has LED flight indicators beneath each of its four rotor arms. The LEDs illumination
to indicate the status of the fligh t controls s ystem and alert the PIC of any possible issues.

Such highly advanced capabilities will ensure that the SUASs can be safely operated and “not create a
hazard to users of the national airspace system or the public”. Equivalent Level of Safety In and effort to
join the FAA in its mission to provide the safest, most efficient.

**Equivalent Level of Safety**

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the

world and to minimize the risk to the N AS or the persons and property on the ground. AKFlyin Aerial
Photography agrees to be bound by the following limitations and conditions when conducting commercial
operations under an FAA issued exemption:

A. For the purposes of ensuring SUASs will be operated within the standards that the FAA has
allowed in the AMA National Model Aircraft Safety Code.

http://yuneec.com/products/AerialUAV/q500

- typhoon

Reform Act Section 333 (b)

1. SUASs will not be flown:August 18 th , 2015 Page 6 a. In a careless or reckless manner

b. At a location where SUAS activities are prohibited.

2. SUAS pilots will:

a. Yield the right of way to all human

- carrying aircraft.

b. See and avoid all aircraft and a spotter must be used when appropriate 8

.

c. Not fly higher than 400 feet above ground level or within five ( 5 ) miles of an airport without notifying the airport operator.

d. Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement.

e. Not exceed a takeoff weight of 55 pounds (including payload).

f. Ensure the aircraft is identified by affixing the owner’s contact information to the
outside of the SUAS.

g. Not operate SUASs while under the influence of alcohol or while using any drug that could adversely affect the PIC’s ability to safely control the model.

h. Not operate SUASs carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property.

3. SUASs will not be flown unless:

a. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event.

b. An inexperienced pilot is assisted by an experienced pilot.

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.August 18 th , 2015 Page 7 8 AMA Document #540

- D

5. A successful radio equipment ground

- range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model aircraft.

6. SUASs must use the radio

- control frequencies currently allowed by the Federal
Communications Commission (FCC).

7. SUASs will not knowingly operate within three (3 ) miles of any pre

- existing flying site without a
frequency

- management agreement. 9

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to any individual, except for the PIC and the PIC's helper(s) located at the takeoff site.

9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still under power, except to divert it from striking an individual.

10. The PIC of the SUAS shall:

a. Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot.

b. Fly using the assistance of a camera or First

- Person View (FPV) only in accordance with the procedures outlined in AMA Document #550.

c. Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560.

11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown closer than 50 feet to any above

- ground electric utility lines.

12. The flyin g area must be clear before the engine is started, except for PIC and the PIC's helper(s).

A. In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in anAugust 18 th , 2015 Page 8 effort to enhance the safety offered by the already safe operations mentioned above, Singer’s Creations also agrees to be bound by the following limitations and conditions: 1. Flights will be operated within VLOS of the PIC.

9 AMA Documents #922 and #923

2. Maximum total flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit. 3. The SUAS will only operate in tightly controlled and limited airspace. 4. A briefing will be conducted in regard to the planned SUAS operations pr ior to each flight. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS and received u p

- to

date information on the particular SUAS to be operated. 6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice. 7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to return

to a pre

- determined location within the security perimeter and safely land. 8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 9. All flights will be conducted on private property and with the written and/or oral p ermission of the property owner(s). 10. Flights will **always** be conducted in areas that are clear of **all** people, except for the PIC and the PIC's helper(s). 11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during severe weather conditions 12. Flights will not occur in weather conditions that prevent the PIC from operating within visual line

of

- sight (VLOS) at all times or in weather conditions that dramatically affect the UAS’s flight (e.g. high winds). 13. If an operation occurs in an area where people could inadvertently enter the area, an operational
border will be established with traffic cones. If it’s not feasible to use traffic cones due to interference with the photography/videography, the PIC's helper(s) will be res ponsible for keeping a safe perimeter around the operation. The operation will cease immediately and be rescheduled if it’s impossible to establish a safe perimeter around the operation. 14. The PIC will be responsible for logging all flights to ensure the com prehensive preventative maintenance plan can be followed, as described in the “Preventative Maintenance” section below. 15. The SUAS will not be routinely operated in the proximity of any airports. In any cases where the SUAS must be operated within five (5) miles of an airport, the airport operator will be notified before the operation commences.

The operation of SUASs, weighing less than 4.4 lbs., conducted in the strict conditions as outlinedAugust 18 th , 2015 Page 9 above, will provide an equivalent level of safety supporting the grant of exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations.
These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled
environment. A s a result, they offer a much safer way to capture aerial photography and videography. Furthermore, the proposed operations represent a safety enhancement to the already safe operations that have been granted by the FAA for the establishment of the AMA National Model Aircraft Safety
Code.

**Preflight Action Plan** 

The PIC will follow a comprehensive pre

- flight checklist to ensure that the SUAS is in a condition for safe flight. This plan will be improved as needed in order to ensure all known safety precautions and/or safety precautions suggested by the manufacturer are being accounted for.

**Area & Environment** 



## o Hazards / Site Selection



## o Check for wires / cables



## o Animals



## o People / bystanders



## o Property in the vicinity



## o Site is away from nonessential participants



## o Ability to maintain adequate buffer zones between aircraft and
personnel;



## o Minimize departures and landings over populated areas



## o Take into account local topography, ensuring a visible line of sight

towards the UAV at all times. Ensure the telemetry connection is not

obstructed.



## o Investigate potential alternative landing sites in case take

- off site is

obstructed.



## o Psychological consideration (are you well rested, rushed, are you being pressured by client)August 18 th , 2015 Page 10 

## o Weather considerations



## o Temperature



## o Vis ibility



## o Precipitation



## o Wind Speed



## o Upper winds / at altitude



## o Rotor (lee side of large objects)



## o Notify any bystanders or nearby property owners of your intentions
(permission)



## o Discuss flight plan with your co

- pilot or spotter



## o If flying in controlled airspace, have you notified airspace authority



## o NOTAMs



## o Can you reach authorities



## o Do you need to maintain communication?



##  First Aid Kit stocked, readily accessible and visible to anyone in the area.

**Equipment / UAV / Drone** 

Drone Serial

Number

.



## o Walk

- around



## o Crack in joints and structural members



## o Loose or damaged screws, ties, fasteners, straps



## o Loose or damaged wiring



## o Loose or damaged connections (solder, plugs, etc.)



## o Inspect prop mounts and screws and apply slight counter pressure on arms

to check for loosened compone nts



## o FPV , inspect / clean FPV (Camera) Lens and insure it is secured and
connects are firmly attached



## o Camera settings are correct (still images, video, framerate)



## o Battery / Batteries are fully charged, properly seated and SecuredAugust 18 th , 2015 Page 11 

## o Fail

- safe equipment functioning



## o RTH (return to home)



## o Recovery chute



## o Firmware Airport Proximity Detection Functioning



## o Props are smooth and free of damage / defect (check blade, surface and hub)



## o Prop adapters are tight / secure



## o Ensure voltage alarm is connected



## o Ensure arming / idle timeout is properly configured



## o Correct model is selected in transmitter (if applicable)



## o Check RC transmitter shows the right range and centering for all sticks



##  Perform range test

**Mission Plan** 

All actions and contingencies for the mission planned.
Contingency planning should include safe routes in the event of a system failure, degraded
performance, or lost communication link, if such a failsafe exists. Mission plans and flight plans should
be shared with other operators in the vicinity.

**Public Awareness** 

**Be courteous and polite** 
You are an ambassador and your actions will affect other pilots and the industry in general

Be professional / appear professional

**Pre**

**- flight /**  **Run**

**- up** 

o Verifying all transmitter, on

- board aircraft and camera batteries are fully
charged; (confirm voltages)

o Ensure no frequency conflicts with both video and transmitter / receiver

o Checking all control surfaces for signs of damage, loose hinges, and overall
condition; Looking over the wing/rotors to ensure they are in good struc tural
condition and properly secured;August 18 th , 2015 Page 12 o Check motor/engine and mounting attached to the airframe;

o Study propellers / mounting hardware (tight) / rotor blades for chips and
deformation;

o Check the landing gear for damage and function

o Test electrical connections, plugged in and secure

o Ensure photo / video equipment mounting system is secure and
operational.

o Check location of GPS equipment controlling the autopilot.

o Check the IMU movements in the ground control software.

o UAV in stabilization mode, ensure control surfaces move towards the correct
positions

o UAV / Drone is in a level location safe for takeoff

o FPV / Power up ground station

o FPV / Power up Video receiver / goggles

o If using Video recorder turn on camera system

o Camera settings are correct (still images, video, framerate)

o SD camera memory clear and inserted into the camera

o Action / Start filming

o All transmitter controls move freely in all directions

o All transmitter trims in neutral position

o All transmitter switches in correct position( typic ally away)

o Transmitter throttle to zero

o Radio transmitter on

o Connect / power on battery to airframe

o Ensure led indicators and audible tones are correct

o Timer on (if applicable)

o FPV, confirm video is in monitor / goggles

o Scan for nearby cars / people / animals

o Say “CLEAR!”

o Arm flight controller

o Increase throttle slightly listening for any abnormalities

o Short 20

- 30 second hover at 3

- 5 feet (listen for vibrations / loose items)August 18 th , 2015 Page 13 

##  Confirm Voltage levels are correct

**In**

**- Flight** 

Not to Exceed 200ft AGL

– and forw ard speed of 10mph

o Basics: If flying manually, always keep your fingers on the
controller/transmitter.

o Never let the UAV out of your sight even for a second.

o Climb to a safe altitude away from potential hazards and to reduce noise
pollution.

o Keep aircraft at a safe operating distance from people, electric utility lines and
buildings.

o If the UAV must be flown over buildings or people, use a lightweight UAV and
maintain a safe altitude for recovery and make every effort to minimize exposure.

o Spotter: Use a spotter whenever possible and appropriate, especially when
flying by First Person View (FPV).

o Do not fly UAVs within distance defined by local laws of any private/commercial airport/helipad

o Do not fly around a pre

- existing UAV flying site without a frequency

- management

agreement.

o Do not interfere with operations and traffic patterns at any airport

o Landing: Regardless of whether of a manual or automated UAV landing,
scan landing area for potential obstruction hazards.

o Announce out loud “ **Preparing to Land”.** 



##  Carefully land the aircraft away from obstructions and people.

**Post**

**- Flight** 

o **Shutting Down: Turn the power off to the aircraft**  **and/or disconnect**

**the batteries.** 

o Turn off the transmitter.

o Turn the power off to the photo equipment.

o Visually check aircraft for signs of damage and/or excessive wear.

o Remove the unused fuel if applicable. Secure the aircraft.

o Check pictures: Verify that the UAV camera actually took the pictures.August 18 th , 2015 Page 14 **Preventative Maintenance** 
A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS’s
software is up

- to

- date, the batteries are in good health, and the aircraft itself is always ready for safe

flight 10

.

10 See the “Q500 Typhoon Instruction Manuel” document.

**Pilot in Command (PIC) Qualifications** 

The PIC does hold an airman certificate and medical certification. Since the SUAS is similar in size, weight, speed, and operating capability as those currently allowed to be flown for hobby/recreation, holding the PIC to those same set of standards will allow for an equivalent level of safety. The PIC has the computer proficiency needed for the configuration, updating, and maintenance of the SUAS, thus ensuring safe operation.

It cannot be assumed that a commercial pilot, approved to opera te a helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre

- approved airspace. Since there are no standards for either private
or commerci al SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the SUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. With that in mind, Akflyin Aerial Photography LLC proposes that its PIC be required to do the following prior to the first commercial operation:

1. Perform 25 hours of flight time with the (Q500 Typhoon)
2. Successfully learn and demonstrate all flight maneuvers in the “Q500 Typhoon Instruction

Manuel Guide ” 11

. 3. Study and be familiar with all sections of the “ Q500 Typhoon Instruction Manuel Guide ” 12

. **Public Interest**  Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent level of safety, a reduction in environmental impacts, and are free from the harmful emissions associated with the manned aircraft that are currently used for aerial photography and videography. Due to the size of the SUAS and the tightly contro lled and limited airspace in which the SUAS will operate, approval of this application presents no risk to the public. Furthermore, the public will be able to legally acquire aerial photography and videography to help in, but not limited to, advertising ho mes for sale, advertising uninhabited home lots, use of photos and video as an aid when researching homes for sale on the market, or safely accessing high and/or awkward areas of a home’s exterior to assess damage that needs to be repaired.August 18 th , 2015 Page 15 **Privacy** Since the areas being photographed or filmed will be on private property, accessed only after given written and/or oral consent by the property owner(s), and clear of all people, except for the PIC and the PIC's helper(s), approval of this application presents n o risk to the public privacy.

**National Security**  Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this application presents no risk to national security.

**Requested Exemptions**  Akflyin A erial Photography requests exemption from the following regulations since it’s not possible

to fully comply with them, and since attempting to follow them for the purposes of operating a SUAS
would be a burden:
**Airworthiness Certificates** 

11 See the attached

“Q500TyphoonInstructionManuel .pdf”document. ”

“Q500TyphoonQuickStartManuel.pdf” document.

14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Singer’s Creations, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. T he Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximi ty to airports and populated areas of the particular SUAS. In all cases, an analysis of these criteria demonstrates that the SUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without
the restrictions and conditions proposed.

**Flight Instruction** August 18 th , 2015 Page 16 14 CFR 91.109

This regulation provides that no person may operate a civil aircraft ( except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual
controls.

SUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the
aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in

ex perimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

**Altimeter Settings** 
14 CFR 91.121

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 SUAS may not have a barometric altimeter, but i nstead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator by confirming the altitude of the
launch site shown on the GPS altitude indicator before flight.

**Fuel Requirements for Flight in VFR Conditions** 
14 CFR 91.151 (a)

This regulation 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; or (2) At night, to fly after that for
at least 45 minutes.”

The battery powering the SUAS provides approximately 25 minutes of powered flight. That would make it impossible to meet the 30 minute reserve requirement. Given the August
17 th

, 2015 limitations on the SUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in d aylight or night
VFR conditions is reasonable.August 18 th , 2015 Page 17 An equivalent level of safety can be achieved by limiting flights to 25 minutes or 25% of battery power (whichever occurs first). This restriction would be more than adequate to return the SUAS to its planned landing zone from anywhere in its limited operating area.

**Maintenance Inspections**  14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b)

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 shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply. Maintenance will be accomplished by the operator pursuant to the aforementioned Phantom user manual and guide. An equivalent level of safety will be achieved because these small SUASs are very limited in size, will carry a small payload, and operate only in restricted areas for limited periods of time. If mechanical issues arise, the SUAS can land immediately and will be operating from no higher than 400 feet AGL. As outlined in the
aforementioned Pre

- flight Action Plan, the operator will ensure that the SUAS is in working order prior to initiating flight and perform maintenance as required. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

In accordance with 14 CFR Part 11, the following summary is provided for publication in the
Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.40 7 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially operate small unmanned aircraft systems (55 lbs. or less) in order to safely and legally capture aerial photography and videography for use by homeowners, realtors, home builders, home contractors, and/or home inspectors. The operation of SUASs conducted in the strict conditions outlined above, will provide an equivalent and/or greater level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and as a result, are far safer than existing operat ions conducted with helicopters operating in close proximity to the ground, people, or other buildings in the vicinity.August 18 th , 2015 Page 18 Given the small size of the SUASs involved, the slow speed at which they must be operated in order to capture photos and videos, and the restricted environment within which they will operate, the Q500 (Typhoon) demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by exemption, allow commercial operations of SUASs to co mmence immediately. Also, due to the size of the SUASs and the
restricted areas in which the relevant SUASs will operate, approval of this application presents no threat to national security. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations, the significant public benefit

– including enhanced safety, reduction in environmental impacts, no emissions, ability to legally obtain aerial photography and videography
services

– the grant of the requested exemptions is in the public interest. Accordingly, Akflyin Aerial Photography LLC respectfully requests that the FAA grant the requested exemption without delay.

Satisfa ction of the criteria provided in Section 333 of the Reform Act

– size, weight, speed, operating capability, proximity to airports and populated areas, operation within the visual line of sight, public safety, and national security

– provide more than adequate justification to grant Akflyin Aerial Photography the requested exemption, allowing for commercial operations as
described herewith.

Sincerely,

Steve Grier

. Ne w Founder, Akflyin Aerial Photography