### 1

Docket Management System U.S. Department of Transportation 1200 New

Jersey Avenue, SE Washington, D.C. 20590 September 17 , 2015

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, Images Above, LLC, an operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to film and photograph commercial real estate, residential r eal estate and agricultural real estate , applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAS ( s ) , so long as such operations are conducted within and under the conditions outlined herein o r as may be established by the FAA as required by Section 333. **Requested Exe mptions:**  Im ages Above, LLC, r equest s e xemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R Se ctions:
45.23 b. 45.29 61.23 a. & c. 61.101 e. 4 & 5 61.113 a. 61.315 a. 91.7 a. 91.119 c. 91.121 91.151 a. & 1 91.405 a. 91.407 a. & 1 91.409 a. & 1 & 2 91.417 a. & b. **Proposed Usage:** Approval of ex emptions for Images Above, LLC, will permit Images Above , LLC, to assist owners, se llers, buyers, and realtors to acquire, sell, manage and inspect real estate, properties and structures by

making available high quality aerial imagery in photography and videography formats. Agricultural support will inclu de aerial photography and videography to support land management, crop management, erosion control efforts, the inspection of buildings and other structures.
**Within I ntent of Congress:**  The requested exemption should be granted because the proposed operations of the DJI Phantom 2 , a small UAS (s) with a total w eight of less than 10 lbs., inclusive of battery , camera, and gimbal. The UAS (s) operations will be conducted in the strict conditions outlined below and will provide an equivalent level of safety as directed by Congress while still allowing viable commercial operations. **UAS Type and Associated**  **Equipment:** The UAS(s) systems operated by Images Above, LLC, w ill be compri sed of an unmanned aircraft and a transportable ground station. The UAS(s) is a DJI Phantom 2

. The UAS(s) has a gross weight of about 3 pounds. When equipped with a gimbal and camera the total weight of the UAS(s) plus payload will not exceed 10 pounds. The UAS(s) is equipped with four rotors that are driven by electric motors po we red by batteries. The UAS(s) will be equipp ed with a GoPro camera and multidirectional gimbal mount. The ma ximum airspeed is 15m/s.

### 2

**Safety:** The UAS(s) operated by Images Above , LLC, and authorized by the exemption s requested are far safer than conventional operations conducted with manned helicopters and fixed

- wing aircraft weighing thousands of pounds, containing highly flammable fuel, and operating in close proximity to the ground and people, as a similar UAS has been previ ously approved in Exemption No. 11138, Douglas Trudeau, Realtor®. Congress directed the FAA to consider s even (7) factors when evaluating Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to pop ulated areas, and operation within visual line of sight . The UAS(s) operated by Images Above , LLC, are remotely piloted unmanned aircraft that are sm all, wil l operate at speeds of less than 50 miles per hour , fly close to the ground but not higher than 4 00 feet above the land surface , will be operated more than 5 mile s from airports and in low

risk, low population environment s
. Additionally, Images Above , LLC, will limit UAS(s) operations to daytime V isual Flight Rule (VFR) conditio ns and only fly UAS( s) within V isual Line of S ight (VLOS).
A visual observer will be pre sent to assist the UAS operator in the observati on of the UAS(s). The UAS(s) will remain within the range of human vision when unaided by any device other than corrective lenses

. The UAS(s) only be operated within the visual line of sight of both the operator and the visual observer at all times. The operator and the visual observer will remain within range of unaided voice contact to one another during all operations of the UAS(s) to ensure effective communications.
T he UAS(s) operated by Images Above, LLC, will use a global positioning system (GPS) flight safety feature causing the UAS(s) to hover and then land slowly if communicati on with the remote control operator is lost

. The f

light of the UAS(s) will be aborted in the event that unpredicted obstacles or em ergencies are encountered. Furthermore, the small UAS (s) operate d by Images Above, LLC, will pose a much more limited threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. Images Above, LLC, will provide an additional level of safety by operating in reasonably safe environments that are strictly controlled, are aw a y from pow er lines, elevated lights, airports and actively populated areas . Images Above , LLC, will conduct preflight inspections and follow the res trictions set forth in the approved exemption document.
At le ast 3 days before the use of the UAS(s) Imag es Above , LLC, will submit a Plan of Activities to the local Flight Standards District Office (FSDO) with jurisd iction over the area of the plan flight unless waived with the concurrence of the FSDO. The plan of activities will include the following and/o r any other information required in the exemption approval documentation; a. d ates and times for all flights; b.
n am e and phone number of the UAS(s) operator (s), c. n am e and phone number of the person responsible for the on

- scene operation of the UAS; d. m ake, m odel, and serial or N −Number of UAS to be used; e.
n am e of UAS PICs invo lved in the aerial filming; f. a statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption ho lder or representative; and h. a description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state ov er w hich filming will be conducted and the altitudes essential to accomplish the operation.
Following m aintenance, alterations, or replacement of a flight critical component the UAS (s) operated by Im ages Above, LLC, will have a functional test flight performed prior to conducting further operations

. During the functional test flight both the operator and a visual observer will be present. All rules governing norm al flights will be observed durin g functional test flights to ens ure the potential for un due hazard to persons and property is minimized.
**Benefit to the Public:** Aerial photography has been available for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost prohibitive

. Granti ng this exemption would allow Images Above , LLC, to provide this service at a much lower cost. Im ages Above, LLC , will provide the public a er ial videography that supports the real estate industry, the agricultural industry and the general public. Aerial imaging will permit the real estate industry and general public to market, inspect and evaluate real property. Aerial imaging will provide farm ers with real

- time high quality and affordable information to make erosion control, planting, fertilizing, weed control and irrigation

### 3

decisions. The farmer will also be able to use the aerial images to inspect buildings, structures, water containment structures and fencing.

**Contact Inform ation:**  Im ages Above William Andrew

Enfield 3804 Larkspur Ct. Columbia MO 65201 **Summary:** Im ages Above, LLC, seeks relief from the 14 C.F.R sections listed within this request in order to operate a UAS(s) to support real estate and agricultural sales, management and inspection. UAS(s) operator by Images Above, LLC, will be operated within the parameters specified by the FAA and will pose no significant threat to the public while offering a significant benefit to the public.

William Andrew

Enfield Owner Operator, Images Above, LLC Contact Info