June 21, 2015
Charles Ayers 6680 Mossy Glen Dr. Fort Myers, FL 33908 Cell 407-416-6781 Email: cayers13@gmail.com

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

Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) Phantom 2 Vision+ User Manual V1.04 2) Phantom 2 Vision Plus Quick Start Guide 3) Phantom 2 Vision Pilot Train ing Guide 4) Phantom 2 Vision Release Notes
References: 1) FAA E xemption No

. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYI NG CAM INC
Dear FAA, In accordance with the FAA's 

### Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I, Charl es Ayers, request exemption from the following sections of Ti tle 14, Code of Federal Regulations§§ 

### 61.113(a). 61.113(b). 91.119(c). 91.121. 91.151(a). 91.40S(a). 91
.407(a)(1). 91.409 (a)(1). 91.409(a)(2). 91.417(a) & 

### (b).
In order to operate sma ll unmanned aircraft systems (UAS) commercially i n airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, structural inspections of bridges, pipelines, we ll and ce ll towers, real estate marketing and surveys and other flight operations that could

### 91.405(a). 91.407(a)(1). 91.409 (a)(1) & 

### (2). 91.417(a) & 

### (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, Charles Ayers, propose to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety wou ld not be adversely affected

.


### The UAS The DJI Phantom 2 vision plus is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 ounces (1242g) designed primarily to carry aloft a high definition camera. It has an 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 motors with a distance between motors of less than 14 inches (350mm) It utilizes an internal inertial measuring unit (IM U) with integrated barometric sensor augmented with globa l positioning system (GPS) to mainta in its geospatial orientation and position. 

### It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery leve l, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. 

### It has fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life lim its flight times to approximately 25 minutes. The o nboard 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.

Risk mitigation I, Charles Ayers, have reviewed FAA exemptions reference's 13 

### Conditions and Limitations section and believe that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety.
A preflight checklist will be developed and employed to ensure that the UAS's airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components.I , Charl es Aye rs, state th at operation w ill not occur w ithin 5 m i les of an airport or any unauthorized space. 

### "The UA may not operate in Class B, C, or D airspace without written approval from the FAA

. The UA may not operate within 5 nautical miles of the geographic cente r of a non towe red airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the ope ration is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made ava ilable to the Administrator upon request. "

Publ ic i nterest Use of the UAS in lieu of a man ned aircraft would enhance safety and reduce the envi ron mental impact as compared to similar operations conducted with manned ai rcraft of greater proporti ons, ca rrying a crew and fl am ma bl e fuel.

In rega rds to performing i nspections of bridges, towers, and natural gas pipelines the UAS will mi nimize the risk to pe rsons attempting to climb these structu res and photograph prob lem areas. It will provide a way for companies to have their eng i neers review photographs and provide add itional safety to the general public in regards to towers failing or natural gas pipel ines having structural issues. Many of t h e natura l gas pipelines i n our area travel in areas that are hard to reach by ve hicle o r foot and if an area is suspected of having probl ems the UAS can reach it to make an assessment easier and safer.

I , Cha rles Ayers, wi ll also make the UAS and myself available to local volu nteer organizations (for no charge) such as fire departments, local law enforcement, etc., to perfo rm search and rescue operations, or other similar events as d irected by authorities

.

I n addition the use of the U AS in order to facilitate commerce cou ld lead to econ om ic growth

. Operatio ns for t h is petition w ill enable service for p roperty owners or their designees seekin g an enhanced perspective for cha racte rist ics, amen ities, and benefits of t heir desired photog rap hi c subjects that ca n not be disp layed th rough ground level photography. Aerial ph otography is a valuab lemarketing tool that can lead to increased commerce and enhance my persona l photography. A visual observer will be utilized at all times that the UAS is performing duties for compensation

. My own research shows an upward demand for these services t hat cu rrently exists in the real estate market, surveying and other markets are just beginning to realize the need for such services

. Flight data including UAS flight time, Control Unit operation time, incident, and details wi ll be recorded for each flight and made avai lab le to the FAA at any time needed. Any deviations from normal operations will also be recorded and made available to FAA

.

Conclusion I, Charles Ayers, am requesting this exemption for the purposes of ae ri al photog raphy of real estate, bridge in spections, land surveying, tower inspections, and other flight ope rat ions

. The reason for such a ge neral and broad based request is that I, Charles Ayers, wish to utilize a bus i ness strategy in order to capitalize on opportunities as they may arise in the future without the long t u rnaround time associated with additional exemptions. My business model is based on the idea of offering small UAS services to individuals o r compan ies who w ish to employ these services as a safe, effective, and legal option to enhance their business or prevent structu ral disasters that may influence the general public or individuals.be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by, Charles Ayers, are drawn from references 13.



### 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely populated". I, Charles Ayers, request waiver for this condition to allow reasonable and responsible operations with safety as my main concern in areas of subdivisions and neighborhoods if required.



### 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.


### 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.