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 Training Guide 

4) Phantom 2 Vision Release Notes 

References: 

1) FAA Exemption 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 FLYING 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, Charles Ayers, request exemption from the following sections of 

Title 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 small unmanned aircraft systems (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA) for the purposes 

of aerial photography, structural inspections of bridges, pipelines, well and cell 

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 would 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 (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 

transmitted 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 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 

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. 

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, Charles Ayers, state that operation will not occur within 5 miles 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 center of a non towered airport as 

denoted on a current FAA published aeronautical chart unless a letter 

of agreement with that airport's management is obtained, and the 

operation 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 available to the Administrator upon request." 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned 

aircraft of greater proportions, carrying a crew and flammable fuel. 

In regards to performing inspections of bridges, towers, and natural gas 

pipelines the UAS will minimize the risk to persons attempting to climb these 

structures and photograph problem areas. It will provide a way for companies to 

have their engineers review photographs and provide additional safety to the 

general public in regards to towers failing or natural gas pipelines having 

structural issues. Many of the natural gas pipelines in our area travel in areas 

that are hard to reach by vehicle or foot and if an area is suspected of having 

problems the UAS can reach it to make an assessment easier and safer. 

I, Charles Ayers, will also make the UAS and myself available to local 

volunteer organizations (for no charge) such as fire departments, local law 

enforcement, etc., to perform search and rescue operations, or other similar 

events as directed by authorities. 

In addition the use of the UAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property 

owners or their designees seeking an enhanced perspective for characteristics, 

amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level photography. Aerial photography is a valuable 
marketing tool that can lead to increased commerce and enhance my personal 

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 that currently 

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 will be recorded for each flight and made available 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 aerial 

photography of real estate, bridge inspections, land surveying, tower 

inspections, and other flight operations. 

The reason for such a general and broad based request is that I, Charles 

Ayers, wish to utilize a business strategy in order to capitalize on 

opportunities as they may arise in the future without the long turnaround 

time associated with additional exemptions. 

My business model is based on the idea of offering small UAS services to 

individuals or companies who wish to employ these services as a safe, 

effective, and legal option to enhance their business or prevent structural 

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.