East	Coast	Aerial	Solutions ,	LLC
105	E	Curtin	Street Bellefonte,	PA	16823 January	7,	2016

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

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA Reform	Act	and	Part	11	of	the	Federal Aviation	Regulations	from:	14	CFR	21	subpart	H;	14	CFR	45.23(b);	14	CFR	61.113(a);	14	CFR	91.7(a);	14 CFR	91.9(b)(2);	14	CFR	91.103;	14	CFR	91.109;	14	CFR	91.119(c);	14	CFR	91.121;	14	CFR	91.151(a);	14 CFR	91.203	(a)	a nd	(b);	14	CFR	91.405	(a);	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)(1)	and	(2);	14	CFR 91.417(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 CFR	Part	11, East	Coast	Aerial	So lutions,	LLC

, an operator	of	Small	Unmanned	Aircraft	Systems	(“sUAS”), hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	Regulations	(“FARs”)	to	a llow commercial	operation	of	his sUAS,	so	long	as	such	operations	are	conducted	within	and	unde r	the
conditions	outlined	herein	or	as	m a y	be	established	by	the	FAA	as	required	by	Section	333.

Commercial	operation of sUAS,	as	described	herein,	which	are	equipped	with	cameras	and	sensors,
would operate	in	the	following	manner:

1. Aerial	photography	and /or	video	for	public	and/or	private	use	including commercial	and	residential real	estate,	architecture,	land	surveyi ng,	engineering,	photogrammetry,	agriculture, and	other related	professional	activities.

2. Aerial	inspection/photography	of public,	utility, commercial, and	residential	structures and
infrastructure under contract	with	the	owners or	local	government	authority.

3. Aerial	photography	and/or	video	for	public	and/or	private	use	including	special	events	and promotional	events.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	sUAS	und er controlled conditions	in	the	NAS	that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	will provide	safety enhancements	to	the	already	safe	operations	in	the	industry	presently	using	conventional
aircraft. Approval of	this	exemption	would	ther eby	enhance	safety	and	fulfill	the	Secretary	of Transportation’s	(the	FAA Administrator’s)	responsibilities	to	“....establish	requirements	for	the	safe operation	of	such	aircraft	systems in	the	national	airspace	system.”

The	name	and	address	of	the	applicant is: East	Coast	Aerial	Solutions,	LLC
Michael	and	Tara	Immel

105	E	Curtin	StreetBellefonte,	PA	16823
Phone: 814

- 548

- 7474
Email: eastcoastaerialsolutions@gmail.com

Regulations	from	which	the	exemption	is	requested:

14	CFR	Part	21	subpart	H 14	CFR	45.23	(b ) 14	CFR	61.113	(a) 14	CFR	91.7	(a) 14	CFR	91.9	(b)	(2)

14	CFR	91.103

14	CFR	91.109 14	CFR	91.119	(c)

14	CFR	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b)

Our	sUAS is a multi

- rotor	cr aft	weighing	no	more	than	55	lbs., including	payload.	Under	normal
conditions

, they operate	at	speeds	of	no	more	than	50kts	and	have	the	ability	hover	and	move	along	a
vertical	and	horizontal plane	simultaneously.	They	will	operate	in	line of	sight	and	will	operate	within	a
closed	off	and predetermined	area	owned	and/operated	by	the	property	representative. Given	the small	size	of	the	sUAS	and	the	controlled	environment	provided

, the	proposed	operations	will adhere	to
the	Reform	Act’s	safe ty	requirements.	The	approval	of	this	application	presents	no	national security issues.	Regarding	the	level	of	safety	surrounding	the	proposed	operations	and	the	public	benefit, reduction	in	environmental	impacts,	including	but	not	limited	to	reduced	emissions	and	noise,	the	grant of	the	requested	exemption	is	in	the	public	interest.

East	Coast	Aerial	Solutions

, L LC seeks	an	exemption	to	operate a	DJI	Phantom	3	Professional for

c ompensation	or	hire	within	the	NAS.	The	DJI	Phantom	3	Professional	is	vertical	takeoff	and	landing (VTOL)	Unmanned	Aircraft	(UA)	with	a	Ground	Control	Station	(GCS)	utilizing	electronic	tablet	or	smart phone	systems.	The	DJI	Phantom	3	Professional	has	a	ma ximum	gross	weight	of	approximately	2.82	lb. while	having	a	diagonal	dimension	of	23.2”,	a	maximum	speed	of	approximately	16	fps	and	a	maximum flying	height	of	400'.	The	DJI	Phantom	3	Professional	is	equipped	with	four	main	rotors;	driven	by Lithium	Polyme r	battery	powered	electric	motors.

Granting	t he exemption will	further	the	public	interest	by	allowing	East	Coast	Aerial	Solutions ,	LLC to safely,	efficiently,	and	economically	perform	aerial	video	and	photography	for	residential	and commercial	real	estate;	photogrammetry;	industrial	and	agricultural inspections;	surveying	and engineering;	mapping	and	GIS;	inspection	of	public,	utility,	and	residential	structures and infrastructure; and	special	events	over	certain	areas	of	the	United	States.

The	DJI	Phantom	3	Professional	UAS	is	battery	powered	and	serve s	as	a	safe,	efficient,	and	economical alternative	to	the	manned	aircraft	traditionally	utilized	to	obtain	aerial	imagery.	By	reducing	the	amountof	manned	aircraft	needed	to	perform	aerial	acquisitions,	an	exemption	allowing	the	use	of	a	DJI
Phantom	3	Pro fessional	UAS	would	reduce	the	amount	of	manned	aircraft	in	the	NAS,	reduce	noise	and air	pollution,	as	well	as	increase	the	safety	of	life	and	property	in	the	air	and	on	the	ground. Additionally,
b y	operating	the	UAS rather	than manned aircraft for	aerial photography	and	videography

, we can provide	a	more	affordable	service	to	clients.

Similar	to	the	manned	aerial	acquisition	flight	operations	that	have	been	conducted	for	decades,	East
Coast	Aerial	Solutions

, LLC’s	proposed	operation	of	the	DJI	Phantom	3	P rofessional	UAS	will	not implicate	any	privacy	issues.

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety	because	operations	will
further enhance	the	safety	of	the	persons	and/or	property	using	conventional aircraft. These	limitations and	conditions	to	which	the	applicant	agrees	to	adhere	to	when	conducting	commercial operations under	the	FAA	issued	exemption	as	set	forth	in	the	Flight	Operations	Manual	(FOM)	include:

1. Flight	operations	will	be	conducted	in	a ccordance	to	the	Academy	o f	Model	Aeronautics	Safety
Code	which follows the	FAA	Modernization	and	Reform	Act	of	2012	with	regard	to	model aircraft	operations	and	limits

. 2. Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.

3. Minimum	crew for	each	operation	will	consist	of	the	sUAS	Pilot,	the	Visual	Observer	(VO)	and

may include	but	not	limited	to	a	Camera	Operator.

4. The	sUAS	pilot	will	be	a	designated	Pilot	in Command	(PIC)	and	hold	a	private	pilot’s	license	and

a state	driver’s	license

. 5. A briefing	will	be	performed	regarding	the	planned	sUAS	opera tions	prior	to	each	day’s	flight consisting	of	all	the	days’ flight activities.

6. The	PIC	and	VO	will	have	been	trained	in	operation	of	sUAS	and	receive	up

- to

- date	information
for the	particular	sUA S	to	be	operated.

7. The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	times.

8. If	the	sUAS	loses	communications	or	loses	GPS	signal,	the	sUAS	will	have	the	capability	to	return

to	a pre

- determined	location	within	a	designated	locat ion	and	land	autonomously.

9. The	sUAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles,	weather,	or emergencies.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1) Subpart	H,	entitled
Airworthiness Certificates,	establishes	the	procedural	requirements	for	the	issuance	of airworthiness certificates	as	required	by	FAR	§91.203	(a)	(1). Given	the	size	and	limited	operating	area associated	with the	aircraft	to	be	utilized	by	the	Applicant,	an	exemption from	Part	21	Subpart	H	meets	the requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	the	Reform	Act.	The
Federal Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of	the	Reform	Act	both	authorize	the	FAA	to
exempt aircraft	from the	requirement	for	an	airworthiness	certificate,	upon	consideration	of	the	size, weight,	speed, operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	particular sUAS.	In	all	cases,	an analysis	of	these	criteria	demonstrates	that	the sUAS	operated	without	an airworthiness	certificate,	in	the restricted	environment	and	under	the	conditions	proposed	will	be	at least	as	safe,	or	safer,	than	a conventional	aircraft	(fixed	wing	or	rotorcraft)	operating	with	an
airworthiness	certificate without	the restrictions	and	conditions	proposed. The	sUAS	to	be	operatedhereunder	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger, carries	no	explosive materials	or	flammable	liquid	fuels,	and	operates	exclusively	within	a	secure d	and designated	area. Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	tightly	controlled	and monitored	by both	the	operator	and	under	the	requirements	and	in	compliance	with	local	public	safety requirements. These	safety	enhancements provide	a greater	degree	of	safety	to	the	public	and	property	owners	than conventional	operations	conducted	with airworthiness	certificates	issued	under	14	C.F.R.	Part	21, Subpart	H.	Lastly,	application	of	these	same	criteria demonstrates	that	there	is	no credible	threat	to national	security	posed	by	the	sUAS,	due	to	its	size,	speed	of operation,	location	of	operation,	lack	of explosive	materials	or	flammable	liquid	fuels,	and	inability	to	carry	a substantial	external	load.

14	C.F.R.	§	45.23	(b).	Marking	of the	Aircraft

The	regulation	requires: When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration number	is	displayed	on	limited, restricted	or	light

- sport	category	aircraft	or	experimental	or provisionally	certificated	aircraft,	the	operato r must	also	display	on	that	aircraft	near	each	entrance	to the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less than	2	inches	nor	more	than	6	inches	high,	the words	"limited,"	"restricted,"	"light

- sport,"	"experimental,"	or "provisional,"	as	applicabl e.

Even	though	the	sUAS	will	have	no	airworthiness	certificate,	an	exemption	may	be	needed	as	the	sUAS
will have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word	“Experimental”	can	be placed. Given	the	size	of	the	sUAS,	two

- inch	letteri ng	will	be	impossible.	The	word	“Experimental”	will be	placed	on the	fuselage	in	compliance	with	§45.29	(f). The	equivalent	level	of	safety	will	be	provided by	having	the	sUAS	marked	on	its	fuselage	as	required	by §45.29	(f)	where	the	pilot,	observer	and others working	with	the	sUAS	will	see	the	identification	of	the	sUAS as	“Experimental.”

14	C.F.R.	§	61.113	(a):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.

Pursuant	to	14	CFR	61.113	(a),	no	person	who	holds	a	private	pilot	certificate	may	a ct	as	a	pilot	in
command of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	Our	sUAS	do
not	carry	any pilots	or	passengers	nor	property	therefore	I	am	seeking	an	exemption	to	14	CFR 61.113(a).	Although	helpful, a	pilot’s	licen se	will	not	ensure	remote	control	piloting	skills.	The	risks attendant	to	the	operation	of	sUAS	is far	less	than	the	risk	levels	inherent	in	the	commercial	activities outlined	in	14	CFR	61.	I	feel	the	operation and	limitations	set	forth	in	the	FOM	will	equ ate	to	the	safe operation	of	the	sUAS.

14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness.

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	As
there will	be	no	airworthiness	certificate	issued	for	the	a ircraft,	should	this	exemption	be	granted,	no

FAA regulatory	standard	will	exist	for	determining	airworthiness.	Given	the	size	of	the	aircraft	for

maintenance and	use	of	safety	check	lists	prior	to	each	flight	an	equivalent	level	of	safety	will	be provided

.
14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.

Section	91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S.

- registered	civil	aircraft	...	(2)	For	which	an Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this	chapt er,	unless	there	is	available	in
the aircraft	a	current	approved	airplane	or	Rotorcraft	Flight	Manual,	approved	manual	material, markings,	and placards,	or	any	combination	thereof.	The	sUAS,	given	its	size	and	configuration	has	no ability	or	place	to carry such	a	flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,but	because	there	is	no room	or	capacity	to	carry	such	an	item	on	the	aircraft.	The	equivalent	level	of safety	will	be	maintained	by keeping	the	flight	manual	at	the	ground control	point	where	the	pilot	flying
the	sUAS	will	have	immediate access	to	it.

14	C.F.R.	§	91.103:	Preflight	Action.

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure	the	safety
of flight.	As	FAA	approved	roto rcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an	exemption
will	be needed.	The	PIC	will	take	all	actions	including	reviewing	weather,	flight	battery	requirements, landing	and takeoff	distances	and	aircraft	performance	data	before	initiation	o f	flight.

14	C.F.R.	§91.109:	Flight	Instruction.

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that

is being	used	for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	sUAS	and remotely piloted	aircraft,	by	their	design	do	not	have	fully	functional	dual	controls.	Flight	control	is accomplished through	the	use	of	a	control	box	that	communicates	with	the	aircraft	via	radio
communications.	The	FAA	has approved	exemptions	for	flight training	without	fully	functional	dual
controls	for	a	number	of	aircraft	and	for flight	instruction	in	experimental	aircraft.	The	equivalent	level of	safety	provided	by	the	fact	that	neither	a pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by	th e size	and	speed	of	the	aircraft.

14	C.F.R. §91.119:	Minimum	Safe	Altitudes

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft

. As	set	forth	herein,	the	sUAS	will never	operate	at	higher	than	400	AGL	with	the	exception	that	in circumstances	where	the	sUAS	is	used to	survey	or	photograph	a	structure	whose	height	exceeds	400	feet AGL,	the	sUAS	will	not	be	operated more	than	100'	above	the	highest	point	on	the	structure.	It	will	however be	operated	in	a	restricted	area
with	securit y	perimeter,	where	buildings	and	people	will	not	be	exposed	to operations	without	their

pre

- obtained	consent. The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the
sUAS	as	well	as	the location	where	it	is	operated.	No	flight will	be	taken	without	the	permission	of	the property	owner	or	local officials.	Compared	to	flight	operations	with aircraft	or	rotorcraft	weighting	far more	than	the	maximum	55lbs.	proposed	herein	and	the	lack	of	flammable fuel,	any	risk	associated	with
the se	operations	is	far	less	than	those	presently	presented	with	conventional aircraft	operating	at	or below	500	AGL.	In	addition,	the	low

- altitude	operations	of	the	sUAS	will	ensure separation	between
these	small

- UAS	operations	and	the	operations	of	convent ional	aircraft	that	must comply	with	Section

91.119.

14	C. F.R.	§91.121	Altimeter	Settings

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	altitude	by	reference	to

an altimeter	that	is	set	“...to	the	elevation	of	the	departur e	airport	or	an	appropriate	altimeter	setting
available before	departure.”	As	the	sUAS	may	not	have	a	barometric	altimeter,	but	instead	a	GPS altitude	read	out,	an exemption	may	be	needed.	An	equivalent	level	of	safety	will	be	achieved	by	the
operator,	pur suant	to	the safety	check	list	and	live	flight	data	monitoring,	confirming	the	altitude	of	the
launch	site	shown	on	the	GPS altitude	indicator	before	flight.

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	ConditionsSection	91.151	(a)	prohibits an	individual	from	beginning	“a	flight	in	an	airplane	under	VFR	conditions
unless (considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of
intended landing,	and,	assuming	normal	cruising	speed

– (1)	During	the	d ay,	to	fly	after	that	for	at	least 30	minutes;	or (2)	At	night,	to	fly	after	that	for	at	least	45	minutes.” The	battery	powering	the	sUAS provides	approximately	30	minutes	of	powered	flight.	To	meet	the	30	minute reserve	requirement	in	14 CFR	§91.151,	sUAS flights	would	be	limited	to	approximately	10	minutes	in	length. Given	the	limitations on	the	sUAS’s	proposed	flight	area	and	the	location	of	its	proposed	operations	within	a predetermined area,	a	longer	time	frame	for	flight	in	daylight	or	twilight	VFR	co nditions	is	reasonable. Applicant believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	exemptions. Operating the	small	UAS,	in	a	tightly	controlled	area	where	only	people and	property	owners	or	official

re presentatives	who	have signed	waivers	will	be	allowed,	with	less	than	30	minutes	of	reserve	fuel,	does

not engender	the	type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed
of	the small	UAS.	Additionally,	limiting	sUAS	flights	to	10	minutes	wo uld	greatly	reduce	the	utility	for
which	the exemption	will	be	granted.	Applicant	believes	that	an	equivalent	level	of	safety	can	be achieved	by	limiting flights	to	25%	of	batter y	power. This	restriction	would	be	more	than adequate	to
return	the	sUAS	to	i ts	planned	landing	zone	from	anywhere	in	its	limited	operating	area.

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration

The	regulation	provides	in	pertinent	part: (a)	Except	as	provided	in	§	91.715,	no	person	may	operate a civil	aircraft	unless	it	has	within	it	the	following: (1)	An	appropriate	and	current airworthiness	certificate. (b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	required	by	paragraph	(a)
of	this section	or	a	special	flight authorization	issued	under	§91.715	is	displayed	at	the	cabin	or	cockpit

entrance	so that	it	is	legible	to	passengers	or	crew. The	sUAS	fully	loaded	weighs	no	more	than	55	lbs. and	is	operated	without	an	onboard	pilot.	As	such,	there	is no	ability	or	place to	carry	certification	and registration	documents	or	to	display	them	on	the	sUAS. An	equivalent	level	of	safety	will	be	achieved	by keeping	these	documents	at	the	ground	control	point	where the	pilot	flying	the	sUAS	will	have immediate	access	to	them,	to the	extent	they	are	applicable	to	the	sUAS. 14	C.F.R.	§91.405	(a);	407	(a) (1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections. These	regulations	require	that	an	aircraft operator	or	owner	“shall	have	that	aircraft	inspected	as	prescribed in	subpart	E of	this	part	and	shall between	required	inspections,	except	as	provided	in	paragraph	(c)	of	this section,	have	discrepancies repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or maintain	the	aircraft	in compliance	with	Part	43

. Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an airworthiness	certificate,	these	sections will	not	apply	to	the	applicant.	Maintenance	will	be accomplished	by	the	operator	pursuant	to	the	flight manual	and	operating	handbook.	An	equiv alent level	of	safety	will	be	achieved	because	these	small	UASs	are very	limited	in	size	and	will	carry	a	small payload	and	operate	only	in	restricted	areas	for	limited	periods	of time.	If	mechanical	issues	arise	the sUAS	can	land	immediately	and	will	be	o perating	from	no	higher	than	400 feet	AGL.	The	operator	will ensure	that	the	sUAS	is	in	working	order	prior	to	initiating	flight,	perform	required maintenance,	and keep	a	log	of	any	maintenance	performed.	Moreover,	the	operator	is	the	person	most familiar with	the aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to	provide	the equivalent	level of	safety. An	equivalent	level	of	safety	will	be	achieved	because	maintenance	and	inspections	will	be performed	in accordance	with	the	sUAS Manufacturer's	Manual,	as	referenced	in	the	Aircraft Operations	Manual	(AOM).	As	provided	in	the	FOM,	the	operator	will	ensure	that	the	sUAS	is	in	working order	prior	to	initiating	flight	and perform	required	maintenance	needed.

ADDITIONAL	INFORMATIONThe	applicant, Michael	Immel,	co

- owner,	has	over	30	years	of	experience	in	engineering	and	landscape photography.	Tara	Immel,	co

- owner,	has	11	years	of	experience	in	marketing,	c ommunications,	and photography.

Satisfaction	of the criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	provide	more	than adequate justification	for	the	grant	of	the	requested	exemptions	allowing	the	commercial	operation	of the	applicant’s sUAS. Ba sed	upon	recent	rulings	by	the	FAA	concerning	the	333	exemption

, we would ask	that	this	request	be	issued	under	the	summary	grant	process	as	this	application	is	similar	to	many
before	it. Thank	you	for	your	review	and	consideration.

Sincerely,

Michael and	Tara	Immel East	Coast	Aerial	Solutions,	LLC