U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12

- 140 Washington, DC 20590

RE: Docket ID: FAA

- 2014

- 1081 Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal Aviation Regulations

April 24, 2015

Petitioner: William Kruger, DBA Above All Imaging

183 Pelican Circle #1302 Breckenridge, CO 80424

Tel.: 330

- 606

- 7593

Email : kruger.will@gmail.com

Dear Sir or Madam,

Pur suant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11.81, William Kruger, DBA Above All Imaging , hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow

commercial operation of its small, unmanned aircraft for photogrammetry, photography/cinematography, industrial inspections

, search & rescue, and analyses . All operations shall be conducted within and under the conditions and limitations outlined previously by the F AA as required by Section 333 and conducted in compliance with the attached operator’s manuals.

1. Sections from which exemptions are sought : Application is hereby made for exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.4172. Relief sought :

a. William Kruger, DBA Above All Imaging wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) p hotogrammetry, photography/cinematography, industrial inspections

, search & rescue, and analyses. This relief is sought because commercial use of sUAS is currently prohibited by law unless performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including payload and energy sources:

i. CarbonCore H650 Foldable Multi

- rotor (6

- propeller hexagonal frame, carbon fiber):

1. Total weight with maximum allowable payload: 9.3lbs.

2. Dimensions: Greate st width: 650mm (25.59in), Height (with landing gear): 14.25”

3. Maximum speed: 30kts

4. Battery system (1x 4

- cell, 14.8 volt, 16,000maH lithium

polymer) provides fifteen (15) minutes of flight time, and two (2) minutes of reserve flight time.

5. NAZA

- M Flight Controller (with GPS and compass) is installed on this sUAS, and is the most advanced system currently available, with latest firmware release.

6. Use of First

- Person View (“FPV”) for advanced flight safety; provides real

- time video downlink from sUAS as well as

c ritical flight systems status to video monitor on transmitter.

ii. DJI F550 Flamewheel Multi

- rotor (6

- propeller hexagonal frame, plastic/metals):

1. Total weight with maximum allowable payload: 6.5lbs

2. Dimensions: Greatest width: 550mm (21.65in), Height (with landing gear): 10.5”

3. Maximum speed: 30kts

4. Batt ery system (4

- cell, 14.8 volt, 5 000maH lithium

- polymer) provides eight (8) to twelve (12) minutes of flig ht time, and one (1) minute of reserve for RTH function if necessary.

5. NAZA

- M Flight Controller (with GPS and compass) is installed on this sUAS, and is the most advanced system currently available, with latest firmware release.

6. Use of First

- Person View (“FPV”) for advanced flight safety; provides real

- time video downlink from sUAS as well as

c ritical flight systems status to video monitor on transmitter.

iii. DJI Phantom 2 (see www.dji.com/product/phantom

- 2 )

iv. Flight Controller and Fail

- Safe systems:

1. The existing flight control technology that William Kruger, DBA Above All Imaging utilizes is the DJI NAZA

- M Flight Controller, which provides these safety features:

a. GPS Attitude Control: Prior to flight operation, the GPS records latitude and longitude, and that positionbecomes the origin of flight. Once airborne, the GPS holds the sUAS in this position, and does not deviate from it, unless the operator changes the mode. This level of safety safeguards the sUAS, preventing it from drifting away, and posi ng a potential risk of injury or damage to property.

b. Attitude Control: The flight controller disables the GPS, and allows operator to control the sUAS in a manner consistent with manual flight. The onboard stability systems keep sUAS horizontally stabiliz ed, to prevent erratic flight performance.

c. Return

- to

- Home (“RTH”): If the operator, under any circumstances, deems the operation of the sUAS to become a risk to persons, property, or the sUAS itself, the RTH command may be invoked, safely returning

the sUA S to the origin of flight, subsequently landing and powering down autonomously. This feature is a design protocol that allows the operator to dismiss operation in the event of his or her inability to control the sUAS, as in with an emergency situation.

v. Oth er models to be added by future amendment to this exemption.

3. Public benefit :

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of m anned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, wh ich benefits

consum ers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon

em issions from manned aircraft.

4. Safety not adversely affected :

a. Aircraft will be registered and marked in accordance with Section 44711 and

P art 47 and Part 45, Subpar t C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by Robotic Skies (or equivalent), and will require a t est flight after such work. Records of all maintenance and repair work will be kept in a main tenance log for each

aircraft.

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capabi lity with each otherat all times during the flight, and who will remain stationary on the ground during the flight operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot

lice nse) screened by the TSA.

2. A Third Class medical certificate issued under 14 CFR 67

. 3. A bi

- annual flight review under 14 CFR 61.56

4. Successful completion of a UAS knowledge test in a specified

form.

5. At least 200 cycles and 25 hours of flight experience in a U AS rotorcraft (or UAS fixed

- wing in the case of fixed

- wing flight operations under this exemption). Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.

6. At l east 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the prior 90 days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in

accordance with 14 CF R 91.119.

ii. A Visual Obser ver. iii. A Sensor Operator as necessary.

d. All operations will be conducted in accordance with valid Certificates of

Authorization.

e. All flight operations will comply with the following:

i. T he manufacturers’ user manuals.

ii. William Kruger, DBA Above All Imaging Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM ),

which include lost communication and other e mergency and safety procedures.

iii. Conducted in VMC co nditions during daylight hours.

iv. PIC and VO w ill maintain VLOS at all times.

v. Pre

- flight inspections (including ground control station, if any) and safety risk assessments will be c onducted prior to each flight.

vi. Flight altitudes will remain below 400 feet abo ve ground level.

vii. Flight ground sp eeds will not exceed 50 kno ts.
viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground w ithout their prior permission.

x. Each flight will be logged in both the PIC’s log book and the aircraft logbook.

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30

min utes, whichever occurs first.

xii. Any incidents will be reported within 24 hours of occur rence.xiii. William Kruger, DBA Above All Imaging will maintain liability insurance of at least $1,000,000 issued by a major a viation insurance

underwriter.

xiv. Any appli cable local FSDO requirements.

xv. All other applicable regulations concerned w ith the operation of

aircraft.

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the

aircraft with well

- defined and tested lost link procedures.

Please advise us of any additional information or changes that may be requi red.

Sincerely,

William Kruger DBA Above All Imaging