Haller Concepts, Inc. Robert Haller 4501 Mattis Road St. Louis, Missouri 63128 (314) 604-6544 robh@hallerconcepts.com

Date: July 2, 2015 U. S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

RE: Petition of Haller Concepts, Inc. for Exemption Pursuant to Section 333 ofthe FAA Reform Act Attn: To whom it may concern Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14C.F.R. Part 11, Haller Concepts, Inc., operatorofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333.1 As described more fully below, the requested exemption would permitthe operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Haller Concepts, Inc. to conduct commercial operations of small unmanned aircraft systems ("UAS") meeting orexceeding all ofthe operational and safety requirements Congress has set forth in Section 333. Page 2 Haller Concepts, Inc. is a media/technologycompany owned and run by Robert Haller. Mr. Halter has been active in Radio Controlled Aircraft forthe past 4 years with experience rotary wing aircraft. Haller Concepts, Inc. plans to exploitthe capabilities of Unmanned Aerial Systems to offer a multitude ofservices, including: -Aerial surveying- Event Photography/Videography -Agriculture purposes -Real Estate Photography -Aerial filmmaking and photography

- Construction site inspections and monitoring StatutoryAuthority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states thatthe FAA "shall determine if certain unmanned aircraft systems mayoperate safely in the national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirements to permit FAA approval ofcommercial UAS operations. The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14C.F.R. 61.113(a) and (b) 14C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14C.F.R. 91.109 14C.F.R. 91.119 14C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14C.F.R. 91.205 (b) 14 C.F.R. 91.215 14C.F.R. (91.401- 91.417) Unmanned Aircraft System sUASs are oftentimes seen as superiorto helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impactwhich promotes public safety.We are petitioningfor exemption to enable Haller Concepts, Inc. to operate a DJI Inspire 1 upgraded tothe latestfirmware and equipped with athree-axis camera gimbal and using a4K camera. This sUAS has a built-in capability to limitthe height itflies above the ground, to limitthe radius ofthe distance itflies from the operator. The Inspire 1 also has the failsafe function ofthe autopilot system which means when the communication between the Main Controller and thetransmitter is disconnected, the outputs ofall command sticks from controller will go to the center position. Ifthe GPS signal is good enough, the system will automaticallytrigger Return to Home and will land safely.

Please refer to the linkto the DJIInspire 11nstruction Manual forthe performance limitations and flight operations. http://download.djiinnovations.com/downloads/inspire_1/en/lnspire_1_User_Manual_v1.2_en.pdf Aircraft weight is 104oz. with battery, 3 Axis Camera Gimbal and Camera A Pre-flight inspection will be performed bythe PIC in accordance with thefactory instruction manual. An added step will be the inspection ofthe propellers. A propeller will be replaced ifit has any nicks and cracks with a manufacturers authorized propeller. The sUAS will be maintained in accordance with the manufacturers instruction manual and only manufacturer's authorized replacement parts will be used.

FCC Information This DJI C1 transmitter used for controlling the sUAS complies with part 15 ofthe FCC rules. Operation is subjectto the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any Interference received, including interference that may cause undesired operation. The DJI C1 radio transmitter used for controllingthe sUAS is wirelesstechnology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range.I • I

Antenna Separation Distance When operating our DJI Cltransmitter, the PIC will maintain a separation distance ofat least 5 em between his body {excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.



### Pilot in Command and Observer Qualifications and Duties The PIC will maintain at least 2 hours flying time and 3 takeoffs and landings within 30 days in thetype of UAS utilized in operations. The PIC will have at least 50 hours total time and at least 30 hours flying Radio Controlled Model Aircraft ofwhich will be 10 hours flying sUAS's. Training will be conducted at a local Radio Control Club flyingfield. Haller Concepts, Inc. has the abilityto provide "dual controls" utilizingtwo DJI Cltransmitters with awireless link between the transmitters. One transmitter is designated the mastertransmitter and the othertransmitter is designated as aslave. The PIC instructor, utilizingthe master transmitter, will be at all times be able assume control ofthe sUAS. The PIC is responsible forthe safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, all procedures including but not limited to: Safe in flight operations Risk Mitigationto Persons and propertyAirfield Suitability The Observer must have the visual acuityto observe the sUAV and be able to communicate clearly with the PIC.

The Observers duties are; warning the PIC ofany impending obstacles in the flight path ofthe sUAS. warning the PIC ofany deviations in the planned flight path ofthe sUAS. warningthe PIC should any unauthorized personnel appear in the area ofthe planned flight. The Observer will havethe authorityto orderthe PIC to terminatethe flight should he feel the flight cannot be conducted safely.General Operating Standards

• Haller Concepts, Inc. will only operate its sUAS in line ofsight ofa pilotand/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public."

• Before an operation ofa sUAV within SNM ofan airportwith a control tower,the control towerwill be called to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. The sUAS will not be operated at an altitude ofover 150feet AGL. Weather minimumswill be 3 miles visibility and a 1000foot ceiling. Before an operation ofa sUAS within SNM ofa non-towercontrolled, airport operators will be notified and the PIC will give the right ofway to avoid flying in the proximity of full-scale aircraft. At no time will the sUAV be operated within thefinal approach course and the takeoffcourse ofany runway. The sUAV will not be operated atan altitude of

over 150 feet AGL. Weather minimums will be 3 miles visibility and a 1000foot ceiling.

• Maximum flighttime for each operational flight will be 25 minutes.

• Flights will be terminated at 25% battery power reserve should thatoccur priorto the 25 minute limit.

• The sUAV will be programmed so that itwill not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist ofthe sUAS Pilot, and Visual Observer.

• The sUAV operated bythe petitionerweighs less than 55 pounds, includingthe payload (i.e. camera, lens, and gimbals).

• The sUAV will operate atspeeds of no more than 60 knots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size ofthe sUAV and the restricted sterile environment within which theywill operate, our sUAV operations adhere to the Reform Act's safety requirements. The UAS, powered by batteries, is smaller, lighter and more maneuverable than largeraircraft running on combustible fuel, itoperates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little or no risk to national security. Low level oblique photos and video from several angles are far more effectivethan ground based imageryfordisplayingthe characteristics of large, complex properties with several buildings and large trees. The applicants in the past have chartered 2-seat full sized helicopters forthis purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subjectto all limitations cited in this application as we do so. (a) No flight will be made with a Gross weight exceeding 35 pounds; (b) All operations must occur in 

### FM Class Gairspace at no morethan 400ftAGL, at an airspeed of no more than 60 knots and no furtherthan 1 NM from the PIC; (c) All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice at all times during aflight operation; (d) Operations will be restricted to flights over private propertywith the permission ofthe propertyowner; (e) All required permitswill be obtained from state and local government priorto operation; (f) Haller Concepts, Inc. will not be operated over densely populated areas; (g) Haller Concepts, Inc. will not be operating over any open-air assembly ofpeople; (h) Haller Concepts, Inc. will not be operating over heavilytrafficked roads;

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Haller Concepts, Inc. requests an exemption from thefollowing regulations as well asany additional regulations that maytechnically apply to the operation ofthe sUAV System: 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe DJI Inspire 1 under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research anddevelopment. Testing newaircraftdesign concepts, new aircraft equipment, new aircraft installations, newaircraft operatingtechniques, or new

uses for aircraft. (b) Showing compliance with regulations. Conductingflight tests and otheroperations To show compliance with the airworthiness regulations includingflights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit ourcommercial purpose as well. The aircraft will notcarry persons or property, will not carry fuel, and will onlyfly under strict operational requirements. Combined with the UA's light weight, being constructed primarily ofcarbon fiber and plastic, we propose thatthe UA will be at least as safe, if not safer, than a conventionally certificated aircraft performingthe same mission. Ifan experimental airworthiness certificate is notappropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph. 14 CFR 45.23 Display ofmarks; general and 45.29 Size of marks. These regulations providethat each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word"EXPERIMENTAL" can be placed, and may not have a registration numberassigned to it bythe FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display atthe ground station a high contrastflag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Since the aircraftwill operatewithin 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its pointoforigin. 

### 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command ofan aircraftfor compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental tothat business oremployment; and (2) The aircraft does notcarry passengers or propertyforcompensation or hire. Our proposed operations require thatthe PIC must hold at least a Private Pilot Certificate with a Class Ill Medical issued by the FAA and since the aircraft cannot carry passengers or property,

we feel we meetthe intentof61.113 Subparagraph (b) even though the intentofthis application is to conduct a business. 

### 14 CFR 91.7 Prohibits the Operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 

### 14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available tothe aircrew while operatingthe aircraft. Werequest an exemption tothis requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available tothe crew duringflight operations. To obtain an equivalent level ofsafety and meetthe intent of91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytimethe aircraft is in, or preparingfor, flight. 

### 14CFR 91.109 Flight Instruction; Simulated instrumentflight andcertainflight tests The regulation states that "No person may operate a civil aircraftthat is being used for flight instruction unless that aircraft has fullyfunctioning dual controls." Training will be conducted at a local Radio Control Club flying field. Perch Photography has the abilityto provide "dual controls" utilizingtwo DJI C1 transmitters with awireless link between the transmitters. One transmitter is designated the master transmitter and the othertransmitter is designated as a slave. The PIC instructor, utilizingthe mastertransmitter, will be at all times be able assume control ofthe sUAV. 

### 91.119 Minimum safealtitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feetto any person, vessel, vehicle, orstructure. Since the typical mission ofthe sUAS would be photography orsurvey of persons, vessels, vehicles or structures itwould be necessary to operate closer than 500 feetto the items listed. Operations will only be flown over propertyor persons where permission has been obtained and careful pre-planned flight path has been performed. The aircraftwill be operated ata low altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or propertyon the surface. Therefore we maintainthat due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in grantingthe exemption. 

### CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in orderto preventI ! ' '

conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computertothe display

screen held by the PIC, providing a constantly updated AGL readout. 14CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin aflight in an airplane under day-vFR conditions unless there is enough fuel to flyto thefirst pointofintended landing and to fly afterthatfor at least 20 minutes. We feel the intention ofthis paragraph is to provide

an energy reserve as a safety bufferfor delays to landing. The sUAV is battery operated and the maximum duration offlight from a single batterycharge is 15 minuteswith a 20% reserve. Since the aircraft will never fly morethan 1 NM from the pointof intended landing, a full battery charge at launch will ensure thatwe meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14CFR 91.203(a) 

### & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew." Ata maximum gross weight of5.3 pounds, the sUAS is too small to carry documentation, does not have

an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intentof91.203, we propose that documents deemed appropriate forthis aircraft by the FAA will be with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containingthe following information plus the word "EXPERIMENTAL" to satisfythe requirement of 14CFR 45.23. 14CFR Subpart E(91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintainingtheaircraft in an airworthycondition, including compliance with part39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection. It is our intention thatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." The PIC will ensure thatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections afterevery two hours offlight. Maintenance performed bythe PIC is limitedto repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer ortheirdesignated repairfacility. The PIC will documentwork performed in accordance with 91.417. We feel that due tothe size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level ofsafety. 

### Safety and Benefits ofthe UAS Haller Concepts, Inc. will be usingthe UAS in avariety ofapplicationsthatgenerally require expensive full-size manned aircraftto complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offull-sized manned aircraftfor electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography,justto name afew. Replacing significantly larger manned aircraft carrying

crew and flammable fuel with small UAS carrying no passengers orcrew creates a much greater margin ofsafetyforthe pilots and crew. By granting Perch Photography's requested exemptions, the FAA will help drive developmentofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. Haller Concepts, Inc. is committed to promotingthe UAS research efforts of policymakers includingthe FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource forfuture UAS research operations. Thus, the FAA has good cause to grantthis Petition. 

### Conclusion As pointed out in this application, all the SUAs which our company would use, under authorization bythe US DOT-FAA, are small, light-weight devices operated within theline ofsight ofthe Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, orother location with aviation activities, unless the airtraffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance. All our SUAs have proven capability for controlled flight. They are devices offered for general sale on the marketaround the world and have often been used as Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 112-95, 2014, have already provided you with the assurances on the airworthiness ofSUAs such as ours. Forthe foregoing reasons, the exemptions requested herein should be granted and Perch Photography, LLC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. The submission ofthis application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so thatsome SUAs may be used for legitimate commercial activities and under reasonably safe conditions. Signed



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Robert Hailer

Hailer Concepts, Inc. 4501 Mattis Road St. Louis, Missouri 63128 (314) 604-6544 robh@hallerconcepts.com