Detroit Aerial Imagery, LLC

1381 Delta Rd. Walled Lake, MI 48390 T: +1 734 755 9636 justin.vandemark@gmail.com January 13, 2016 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Request for Exemption Per PL 112

-95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.4 17(a) and (b) 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, operators at Detroit Aerial Imagery seek an exemption from Federal Aviation Regulations detailed herein for t he operation of lightweight aerial imaging equipment, also referred to throughout as S mall Unmanned Aerial Systems ( sUAS ), as well as their ground based operation equipment described within. **Our Aircraft:** Our operation will include two different sUAS, man ufactu red by DJI, the DJI Inspire 1 and the DJI Phantom 3 . ( sUAS manuals attached). The DJI Inspire 1 has the following flight and safety relatable features: • Inspire 1 is a sUAS Quadcopter made by DJI that has a fixed gimbal and camera attached to the bottom. Inspire 1 has a maximum weight of 6.47 lb. (2965 grams), and a maximum range of 5 000m. • Inspire 1 has built in telemetry to allow the operator to see all onboard information relating to the safety of flight including but not limited to battery pe rcentage remaining, overall health of the operating system, built
- in GPS for position hold and automatic return

-to - home, and multiple fail

- safes for maximum safety. • The onboard camera allows the operator to record High Definition video, as well as take camera stills. The video is transmitted real
-time to the control and operator allowing the operator to see images to all sides of the sUAS utilizing an Apple iOS Devi ce .• DJI Inspire 1 is limited to a maximum assent rate of 5 m/s and has a maximum decent rate of 4

m/s. It also has a limitation of maximum speed of 22 m/s or 49 mph. • The Inspire 1 will be operated with a 5700maH lithium polymer battery allowing for fl ight times not to exceed 22 minutes. The DJI Phantom 3 has the following flight and safety relatable features: • Phantom 3 is a sUAS Quadcopter made by DJI that has a fixed gimbal and camera attached to the bottom. Phantom 3 has a maximum weight of 2.82 lb . (1280 grams), and a maximum range of 5000m. • Phantom 3 has built in telemetry to allow the operator to see all onboard information relating to the safety of flight including but not limited to battery percentage remaining, overall health of the operati ng system, built
- in GPS for position hold and automatic return

-to - home, and multiple fail

- safes for maximum safety. • The onboard camera allows the operator to record High Definition video, as well as take camera stills. The video is transmitted real
-time to the control and operator allowing the operator to see images to all sides of the sUAS utilizing an Apple iOS Device. • DJI Phantom 3 is limited to a maximum assent rate of 5 m/s an d has a maximum decent rate of 3 m/s. It also has a l imitation of maximu m speed of 16 m/s or 36 mph. • The Phantom 3 will be operated with a 4480 maH lithium polymer battery allowing for flight times not to exceed 2 3 minutes.

**Our Ground Based Guidance and Control System:** • DJI Inspire 1 and DJI Phantom 3 are controlled using a DJI transmitter, operating on a 2.4GHz frequency to a maximum range of 5 km. (Specific operating range of 2.400

- 2.483GHz.) (See DJI Inspire 1 Manual Appendix page 58 and DJI Phantom 3 Manual Appendix page 54 for all specifications.) These specifications fall within FCC guidelines for operators. Powered by a lithium polymer battery it has a 4 hour time between charges. • The DJI Inspire 1 and Phantom 3 transmitters have a built in GPS allowing the the sUAS to always know where to return to in the event of a failure. • The sUAS transmitter will be controlled by a single operator, but will utilize a Visual Observer when necessary. **Our Operator:** • Detroit Aerial Imagery will use a single operator for each fligh t, and when able/necessary use a Visual Observer to assist i n keeping sight of the sUAS at all times. At no time will the sUAS be flown outside of visual line
-of

- sight and visual range.• Our operator/owner holds a current Airline Transport Pilot rating wi th 4 years of experience as an

Airline Pilot. (Certificate #3178335 ) • Our Ope rator/Pilot has a total of 2,770 hours of flight time at the time of filing. • Our Operator/Pilot currently holds and will maintain a 1st Class medical certificate. • Our Ope rator/Pilot has approximately 12 years of aircraft flight experience. • The only pilot allowed to operate the sUAS under this exemption will be the Owner/Operator of Detroit Aerial Imagery, ATP C ertificate #3178335 . **Our Business Intent:** Detroit Aerial Imagery will be utilizing the sUAS for multiple projects from time to time. These include: • Precision Farming Based in Southeast Michigan , we have a large amount of interest in using our sUAS to inspect and photograph produce fields (corn, soybeans, potatoes, etc) for precision farming. Utilizing a sUAS to inspect fields instead of a costly traditional helicopter or airplane will not only save a significant amount of money, but also increase safety over traditional methods that u tilize gas/turbine helicopters. • Microwave Tower Inspection Inspecting microwave towers (including cellular telephone towers) traditionally requires a human inspection. Utilizing a sUAS to inspect these towers greatly improves safety and will prevent deaths of tower Inspectors. We have a significant amount of interest from companies doing business throughout Michigan to conduct such inspections. • Bridge Inspections Similar to inspecting towers with the use of sUAS, the required inspections of local bridges and overpasses will see a significant amount of increased safety. • Livestock Search and Inspection Searching for cattle and other livestock utilizing traditional means is both time consuming and ineffective. We plan to utilize the sUAS to aid farmers and ranchers in making this process much faster, saving time and money. • Insurance Inspections of Home and Property Detroit Aerial Imagery has a significant amount of interest from local and regional Insurance companies and adjusters to utilize the sUAS to conduct inspections of prope rty and struct ures. By utilizing a sUAS to conduct inspections of rooftops, farm fields, and other property, the insurance company stands to save a significant amount of time inspecting such property after storms. Also, utilizing a sUAS will increase safety by preventing adjusters from having to climb tall ladders and roofs to make such inspections. • Factory Inspections (both internal and external)Similar to tower and bridge inspections, we plan to use a sUAS to conduct inspections within and outside

of m anufacturing facilities. These dangerous and costl y inspections will be made safe r and less expensive with use of our sUAS. • Commercial Advertising Video and Photography Detroit Aerial Imagery has a significant amount of interest in taking video and photo s for advertising i n our local area. Utilizing a sUAS will offer a significant improvement to the agency with regards to both safety and cost. Using a 6 lb. or less sUAS compared to a gas turbine helicopter or aircraft will offer a considerable safety margin as well as cost savings advantage. • Real Estate Photography and Videography Real Estate photography will see a significant impact with our services, allowing real estate agents a much more competitive product at a much lower price. Safety will also b e increased as well as producti vity by utilizing out services. • Yacht Sales Photography and Videography Detroit Aerial Imagery has seen a significant interest in utilizing out sUAS to capture video and photos for Yacht sales near the numerous lakes in the Northwest Metro Detroit area . We will utilize the sUAS to increase scope of sales to the yacht brokers. We can offer again a more cost competit ive product and a much safer development method over the current use of airplanes and gas/turbine helicopters.

• Police/Fire/Search and Rescue Detroit Aerial Imagery intends to offer our services on a voluntary and pro bono basis for multiple local services including but not l imited to Police services, fire

-fighting services, and search and rescue. These services will increase safety associated with law enforcement and search and rescue. The services will be offered free of charge to the community. **Our Safety and Operating Plan:** Utilizing our sUAS in a safe manner is of upmost importance. Safety will be the guid ing principle of our operation, both with respect to the National Airspace System, as well as those on the ground. including persons and property. Our Safety plan will start with complying with all Federal Aviation Regulations, as well as conducting audits of safety procedures set forth within Detroit Aerial Imagery to keep up to date with the safest practices. Our initial safety philosophy will be based on the premise of “Be Safe Before Takeoff”. We will complete preflight checklists set forth by DJI, the sUAS manufacturer, as well as do thorough post

-flight inspections. (see attached manual for the complete checklist) We will also complete post

-flight checklist and debriefs to constantly monitor our procedures and identify any changes that can be made, si milar to those set forth on airline flight decks.Maintenance and repair of our sUAS will be conducted solely by the manufacturer, DJI, by its employees

or designated technicians. With respect to safety, Detroit Aerial Imagery believes the manufacturer hol ds higher maintenance abilities. Detroit Aerial Imagery will comply with the following at all times when conducting commercial operations: 1. All operations will remain outside Class A,B,C,D airspace. 2. Our operating system will be programmed before all flights to avoid airports so as not to accidentally fly too close to one. The onboard system will not allow either of our sUAS to fly into such airspace. This is an automatic safety feature within the Ins pire 1 and Phantom 3 . 3. Operations conducted by Detroit Aerial Imagery will always remain within visual line
- of

- sight of the sUAS . Never to exceed the limitations of our operator’s eye sight. We will limit the maximum range of the sUAS to not exceed a si ngle person ’ s visual eye
- sight range. Utilizing the software within the sUAS will help to maintain this limit, not to exceed 300m. (.186 miles) 4. Our sUAS will never carry an implement not approved by the manufacturer and will never exceed a weight of 55 lb. as stated within this exemption. 5. All operations conducted by Detroit Aerial Imagery will be at an altitude of less than 400ft AGL, while the majority of our operations will be at an altitude less than 200ft AGL. The Inspire 1 and Phantom 3 have an automatic altitude limit built in and will be set and checked by our operator prior to every flight operation as part of the pre

-flight inspection. 6. Detroit Aerial Imagery will not conduct operations with a speed in excess of 27 knots. The Inspire 1 and Phantom 3 sUAS have an automatic speed limiter that will be set and checked prior to every flight by the operator as part of the pre

-flight inspection checklist. 7. All operations will be conducted in Day VFR conditions. Minimum flight visibility for all o peration will be 5 miles. Minimum cloud ceilings will be 2000ft OVC (overcast) or BKN (broken). 8. All operations will be conducted away from densely populated areas. Detroit Aerial Imagery will work with local officials to make sure any required local doc uments or permits are attained prior to each flight. 9. Prior to each flight our operator will conduct a safety audit of the area to be flown. An assessment will be made with regards to persons, property, and weather. This assessment will allow our operat or to determine whether a safe operation and outcome will be expected. 10. Our operation will utilize a single, dual
- band transceiver and will maintain a “listening watch” of airspace surrounding the operations. ( eg. we will monitor both local frequency 12 2.8 as well as maintain watch of emergency frequency 121.5.) Our operator will also make traffic advisories of our operation location and maximum altitudes prior to all flights utilizing the sUAS . 11. Prior to operating under this exemption, our operator w ill obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization.**The current regulations that we seek exemption from are:**

A. 14 CFR Part 21 (h) Airworthiness Certification • Under this part we seek exemption to apply for an d maintain airworthiness certification for our sUAS . Model and serial number of our sUAS will be provided within. B. 14 CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness • Under this part, “no person may operate a civil aircraft unless it is in airworthy condition.” • We seek exemption from this part, as we will keep our sUAS in a safe, reliable, and airworthy condition, it may not meet all standards as set for by this part of the FAR’s. Our operator will assume all responsibility for determining that the sUAS is in a condition safe for flight, as well as a condition that will not harm other people or property. This will be accomplished using specific guidelines from the manufacture, DJI, as well as following any guidance s et for for routine maintenance. C. 14 CFR Part 91 Subpart C: 91.203: Certifications Required • Under this part, (a) no person may operate an aircraft unless it has within it the following; An appropriate and current airworthiness certificate. This part also includes regulations re garding the use of fuel tanks, which do not apply. • We seek exemption from this part as an airworthiness certificate does not apply to our specific sUAS . D. 14 CFR Part 91 Subpart B; 91.119 Minimum Safe Altitude • Under this part, (a) no person may operate an aircraft below an altitude allowing, if power fails, an emergency landing without undue hazard. (c) over other than congested areas an altitude below 500ft AGL. • We seek exemption from this part due to the nature of the operation, as well as the safety procedures set forth will have little to no risk of damaging any person or structure. E. 14 CFR Part 91 S ubpart B; 91.121 (a)(1) Altimeter Setting • This section pertains to setting an altimeter setting below 18, 000 ft to a reported altimeter reporting station setting. • We seek expedition from this part as our sUAS has no way of setting an alternate altimeter setting. With a built
- in barometer, the Inspire 1 and Phantom 3 use real
-time data to determine altitude during each flight. Operating less than 400ft AGL, we feel our sUAS will have little to no impact on other participating aircraft. Also, with flig hts not to exceed 16 minutes (22 minute battery, and landing at 30% battery remaining) our sUAS will not need to recalibrate its altimeter while in flight. F. 14 CFR Part 91 Subpart B; 91.151 Fuel Required for VFR flight • This section contains requirement s for fuel in VFR flight for combustion engines.• We seek exemption from this part as our sUAS operates off of battery power only. We feel

our operations will not compromise safety to either the operator or property as we have set forth a procedure to land our sUAS when the battery level reaches 30%, or approximately 6 minutes flight time remaining. The Inspire 1 and Phantom 3 have built in battery telemetry that feeds information real time to the operator and an alarm notifies the operator of minimum battery level remaining. (See attached manual for more information) G. 14 CFR Part 91 Subpart E; 91.405 Maintenance Required • This section contains requirements for the operator to maintain and have inspected the aircraft in accordance with Part 43 of the CFR. Under this section it is required to keep maintenance logbooks with the aircraft. It also requires the aircraft to contain placards of the inoperative equipment. • We seek exemption from this part as our sUAS will not be operating with inoperative equipment and is too small to carry logbooks. We also seek exemption due to no certified maintenance technicians will work on the sUAS . Under this exemption August Aerial will be completing pre
-flight and post

-flight inspections, and any required mainten ance or repairs will be completed by the manufacturer, DJI, or one of its certified technicians. H. 14 CFR Part 91 Subpart E; 91.407 Operation After Maintenance • This part requires an aircraft that has undergone repair, rebuilding, alterations, or general maintenance to be approved by an authorized person required by CFR 43.9 and CFR 43.11. • We seek exemption from this part as these inspections do not pertain to our operation of the sUAS . The operator will be responsible for determining the airworthiness of the sUAS pr ior to each flight. After maintenance provided by the manufacturer, the operator will complete test flights before any operation in the vicinity of persons or property to assure all systems are functioning normally. I. 14 CFR Part 91 Subpart E; 91.409 Inspections • This section provides details of the required inspection on an aircraft. No person will operate an aircraft unless in the preceding 12 months has had (1) an annual inspection (2) an issuance of an airworthiness certificate. • We se ek exemption from this part as the inspection and airworthiness certificate to not apply to our sUAS . Our operator will be responsible for the inspection and airworthiness determination prior to each flight and will have the sUAS repaired by the manufactu rer or one of its certified technicians, if the sUAS is found to be in a state other than intended but the manufacturer. J. 14 CFR Part 91 Subpart E; 91.417 Maintenance Records • This section requires the owner/operator to complete and retain a list of all records pert aining to the work p e rformed, the date of completion, the signature of the inspector, and all work performed on the aircraft.• We seek exemption from this part as the inspections and technician work will not apply. Our

operator will be respo nsible for determining the airworthiness of the sUAS prior to each flight and will not operate the sUAS in any condition other than intended by the manufacturer. The operator will keep records of all work completed by the maintenance facility. K. 14 CFR Part 91 Subpart B; 91.103 Preflight Action • This section requires each pilot prior to flight will become familiar will all available information pertaining to that flight including runway lengths, flight information, weather, etc. For any flight, runway l engths at airports of intended use, and the following takeoff and landing distance information include; all applicable information relating to aircraft performance, airport elevation, runway slope, aircraft gross weight, wind and temperature. • We seek exe mption from this part as our operator, while utilizing all available information for the safe operation of the sUAS, will not have the above information available for most flights. The operator will use good judgement and all resources available to ascert ain the information necessary for the safe operation of the sUAS . A preflight inspection will be accomplished according to the manufactures instructions prior to each flight. L. 14 CFR Part 91 Subpart B; 91.105 Flight Crew members Stations • This section p ertains to the required crew members being at their stations during all phases of flight, and requires the use of seat belts and shoulder harnesses. • We seek exemption from this section as it pertains to aircraft with flight crew member stations. Our sUAS does not have such stations. M. 14 CFR Part 91 Subpart B; 91.9 Placement of Manual • This part states no aircraft may operate without a manual onboard the aircraft. • Our sUAS is not large enough to carry such operating manual. We will however carry a current manufacturer manual in the sUAS carrying case along with the operator on all flights. N. 14 CFR Part 45.23 • Under this part, it is required that each operator must displ ay on that aircraft marks consisting of the Roman capital N followed by the registration number of the aircraft. • Our sUAS is too small to attach the “N” number. We seek exemption from this part as we will be attaching the registration or serial number as required on the sUAS . Detroit Aerial Imagery and its owners are committed to a “Safety First” atmosphere. We are committed to conducting our operation in accordance with all Federal Aviation Regulations and maintaining a safety margin of at least those regulations while striving to exceed expectations set forth by the FAA. We are confident we can approach our operations with safety while adding a significant advantage to our community both thro ugh private and civil services.Detroit Aerial Imagery is pre pared to respond to any concerns and look forward to working with you on

this important exemption. Please contact us with a ny other questions or concerns. Sincerely yours, Justin VanDemark Detroit Aerial Imagery, LLC