1 

# Federal Aviation Administration Exemption

Petition for Exemption under Section 333

FAA Modernization and Reform Act of 2012

Public 112

- 95 Feb. 14, 2012, Section 333

Submitted by: John Rowe

dba Clear Lens Media

Date: 5/28 /2015

Dear Sir or Madam:

Attached please find John Rowe, dba Clear Lens Media request for an

exemption from the listed Federal Aviation Regulations to allow commercial

operation of its Small Unmanned Aircraft Systems ("UAS") for aerial imaging for

safety, monitoring, inspecting an d/or recording of secured and controlled

environment sites, proposed development sites, inspections of property and

photography for realty advertisements. This exemption request is exclusively for

the use of the UAS manufactured by DJI, Inspire 1 and by 3D R, Solo

.

Also please find the link to the DJI Inspire 1 UAS Manual which outlines the

operating requirements, limitations, and technical specifications for the DJI

Inspire 1 system.

http://www.dji.com/product/inspire

- 1/download

We have reviewed this Manual and in conjunction with the requirements outlined

in this document we have found it to be acceptable for UAS operations

. The

manual for the 3DR Solo is not available at this time but the opera ting

requirements and limitations are expected to be sim ilar to the DJI Inspire 1

.

Thank you for your time and consideration, and please let me know if you

have any questions.

Sincerely,

John Rowe

Clear Lens Media2 

# Table of Contents

Contact Information

........................................................ .......... ........................................3

John Rowe...........

. ...................................................................... ............ ..........................3

Exemption Appli cant ....................................................................

......... ............................3

Mission Statement ..............................................

............ ................... ...............................3

Intended UAS U se ........................................................................................ ....................4

Specific Section of 14 CFR ................................................................. ...........................5

- 11

Intended Equipmen t for Exemption .................................................................. ................12

Aircraft Specifications ..................................................................................... .................12

Aircraft Maintenance ...

................................................................................ ....... .............1 3

Safety Concerns .....................................................................................

............... .........1 4

Potential Hazards .....

................................................ .............. ........................................1 5

Privacy Concerns ...................................................... .................................................15

- 16

Operational Conditions

........................................................ ............................... . ...........17

Pilot Qualifications ............................................................... ..........................................17

Pre

- Flight Checklist ..

.................................................................................... ..................18

Active Flight Operations ............................................................... ..................................18

Additional Resources ...

............................................................ .................. . ...................18

Exhibit A ...............................................................

...................................... .... ..............19

Exhibit B ...........

.................................................................. ........................ . .......... .......2 0

Exhibit C ...............................................................

..................................... . ............ .21

- 22



### 33 

# Contact Information

Exemption Applicant

John Rowe

Clear Lens Media

Offic e 831

- 293

- 8824, Cell 831

- 594

- 394 1

john@vidgrip.com

26400 Via Mallorca

Carmel, CA 93923

4 

# Mission Statement

C apture video and photos of real estate and properties that

provide vital information to business and property owners used

to enhance public commercial services, safety, investigative

accuracy, and much more.

54 

# Intended UAS Use

To record video and capture pictures of client's homes/properties for the use in real estate

marketing materials, property development, property investigation and documentation by

the use of light weight UASs in the following areas of commerce :

Realty

- Selling properties, enhancing advertising campaigns, and increasing

produ ction of marketing materials. Evaluating property value by documenting

assets and deficits especially in hard to access areas as an alternate to

conventional large, heavy, combustible fuel bearing and manned vehicles are

currently used.

Property inspecti ons

- Especially roofing inspections, especially tile roofs, are

susceptible to added damage from an investigator walking on the roof to

complete his initial inspection. A UAS could do the work and record the inspection

findings without the probability of additional roof damage or personnel injury

from falls. This service would be valuable to companies like: Roofing contractors,

Insurance adjusters, property owners, renters, etc.

Construction defect investigations

- Site investigation and findings specifi cally for

building exteriors would be greatly enhanced by the use of a UAS. It can be very

expensive to safely find and document exterior construction defects on multiple

story building, a UAS could inspect, find and record information that would be

otherwise only be accessible by ladders or scaffolding. Also A UAS would be a

much safer way to do this type of high and/or difficult access investigation.

Site investigation

- Such as steep hillside or bluff. Recording the visual condition

of existing h illsides or bluffs that would otherwise be very difficult to access and

record. It would also be less intrusive to environmentally sensitive areas.

Site development

- Creating high resolution scalable overhead photography of a

property would be valuable to engineers, architects, designers and landscape

architects in evaluating the best use for developing a property and the potential

effects that such development might have. Development of existing properties for

remodeling or renovation especially commerc ial building where equipment is

located on the roof would also benefit from HD photos that document the

equipment and its location. Currently Google Maps are useful for such endeavors

but only with a very low resolution overhead photo of such properties.

Developers and Construction Companies

- To record and document the overall

progress of large developments and to observe and document job site safety.

Landscape maintenance

- To record landscape health and irrigation proficiency on

large properties such as condominiums, apartment complexes, malls, golf courses

or even public parks and recreation areas.

There are many other areas that a UAS would be a safer, accurate and less

expensive alternative to current commercial services but John Rowe dba Clear Lens

Media would be specifically interested in the areas mentioned above.



### 65 

# Specific Section of 14 CFR

Seeking specific exemption from:

Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14

C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2);

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and R eform Act of 2012 (the Reform Act)

and 14 C.F.R. Part 11, John Rowe, dba Clear Lens Media , a videography firm, hereby applies

for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial

operation of its Small Unmanned Aircraft Systems ("UAS") aerial imaging for safety,

monitoring, inspecting and/or recording of secured and controlled environment sites, proposed

development sites, inspections of property and photography for realty advertis ements , 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.

As detailed in this document and the link to Flight Manual, the requested exemption would

perm it the operation of UAS under controlled conditions in airspace that is 1 ) limited 2)

predetermined 3) controlled as to access and 4) would provide safety enhancements to the

already best practices safety protocols followed by John Rowe, dba Clear Lens Med ia at each

one of its project sites. Approval of this exemption would thereby 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."

Section 333(c) of the Reform Act.

The name and address of the applicant is:

John Rowe dba Clear Lens Media

PH: 831

- 594

- 3941

E

- Mail: john@vidgrip.com

Address: 26400 Via Mallorca

Carmel, CA 93923

Regulations from w hich the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)6 I. STATUTORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including

UAS, from the requi rement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under

subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if th e Administrator finds

the exemption in the public interest. 49 U.S .C. §44701 (f) See also 49 USC §44711(a); 49 USC

§44704; 14 CFR §91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate in the

National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to

N ational security. In making this determination, the Secretary must consider:

• The UAS's size, weight, speed, and operational capability;

• Whether the UAS operates wi thin the visual line of sight of the operator

• Whether the UAS operates outside of highly populated areas and away from close proximity to

airports

Reform Act §333(a). If the Secretary determines that a UAS "may operate safely in the national

airspace sys tem, the Secretary shall establish requirements for the safe operation of such aircraft in the

national airspace system." 

### Id. §333(c).

John Rowe dba Clear Lens Media' UASs are multi

- rotor vehicles, weighting 15 or fewer lbs. including

payload. They operate under normal conditions at a speed of no more than 50 knots and have the

capability to hover, and move in the vertical and horizontal plane simultaneously. The UAS will operate

only in the pilot's visual line of sight at all times and will operate only within the recommendations

described in the DJI and 3DR Flight Manual s

, Such operations will insure that the UAS will "not create a

hazard to users of the national airspace system or the public." Reform Act Section 333 (b).

Given the small size of the UAS involved and the restricted and sterile environment within which they

will operate, our application falls squarely within the zone of safety (an equivalent level of safety) in

which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to

commence immediately.

Also due to the small size of the UASs and the low altitudes and restricted areas in which our UAS will

operate, approval of the application presents no national securi ty issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations,

and the significant public benefit, including enhanced safety, the grant of the requested exemptions is

in the public interest. Accordingly, John Rowe, dba Clear Lens Media respectfully requests that the

FAA grant the requested exemption without delay.



### II. PUBLIC INTEREST

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a)

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in the NAS before completion o f the rulemaking

required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress's

intent of allowing UAS to operate with significant safety precautions in low risk environments.

The use of UAS on a construction or insp ection site can significantly reduce the risk to workers of falls

while inspecting, surveying, or monitoring site progress. UAS can inspect, photograph, and collect data

on hard to get to areas that otherwise would require worker inspection. Falls are the leading source of

workplace fatality and injury on construction sites', and reducing falls through UAS use for site imaging

could save workers lives.

Additionally, UAS could replace the use of helicopters and small aircraft to monitor sites. The UAS we

propose to fly in this application are under five pounds, and carry no combustible material on board, as

opposed to the much larger conventionally powered small aircraft. Shifting to UAS from helicopters

presents a marked safety increase for our workers an d the public.

Lastly, UAS reduce the environmental impact by dramatically decreasing the energy used for aerial7 imaging and data collection over a construction site. Our UAS use rechargeable lithium ion batteries, as

opposed to fossil fuels burned in opera tion of small aircraft that are many hundreds of times heavier.



### III. EQUIVALENT LEVEL OF SAFETY

John Rowe, dba Clear Lens Media proposes that the exemption requested herein apply to civil aircraft

that have the characteristics and that operate with the limitations listed herein. These limitations

provide for at least an equivalent or even higher level of safety to operations under the current

regulatory structure because the proposed operations represent a safety enhancement to the already

safe protocols followed on construction sites and imaging and surveying operations conducted with

helicopters and other conventional aircraft.

Please see "Commonly Used Statistics", Occupational Safety & Health Administration.

Available at: https://www.osha.gov/oshstats /commonstats.html

John Rowe dba Clear Lens Media will be bound by the following limitations when conducting its UAS

operations under an FAA issued exemption:



### 1. The UAS will be less than 1 5 pounds.



### 2. Flights will be operated within visual line of sight of a pilot.



### 3. Maximum total flight time for each operational flight will be 30 minutes. The UAS calculates battery

reserve in real time, and will return to its ground station with at least 20% battery power reserve

should that occur prior to the 30 minute l imit.



### 4. Flights will be operated at an altitude of 200 feet AGL, never exceeding 400 feet AGL.



### 5. Crew for each operation will consist of the UAS pilot who will keep the UAS within his visual line of

sight at all times and a spotter.



### 6. The UAS pilot will be trained in flight, operations, and safety procedures as detailed in this document

and as detailed in the DJI and 3DR Manual s

. 

### 7. The UAS will only operate within a confined areas as defined in this document. This document and

the DJI and 3DR Manual s also requires the establishment of a Security Perimeter for the flight

operations area.



### 8. A briefing will be conducted in regard to the planned UAS operations prior to each day's production

activities. It will be mandatory that all personnel who will be performing duties within the boundaries of

the safety perimeter be present for this briefing.



### 9. All onsite personnel will consent to the UAS flyover on site by waiver, and the operator will obtain

additional verbal or written consent of all persons who wi ll be allowed within 100 feet of the flight

operation.



### 10. The pilot will have been trained in operation of UAS generally and received up

- to

- date information

on the particular UAS to be operated as required by this document.



### 11. Written and/or oral permiss ion from the relevant property holders will be obtained.



### 12. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.



### 13. If the UAS loses communications or loses its GPS signal, it will have capability to return to a

predetermined location within the Security Perimeter and land.

IV. DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91203(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 ai rcraft to be utilized by John Rowe, dba Clear Lens Media

, 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 UAS. Our small UAS will be operated at low speed in a8 controlled environment, at least five miles from an airport and more than three miles from any city or

densely populated area.



### 9

An analysis of these criteria demonstrates that t he UAS 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 helicopter) operating with an airworthiness certificate wi thout the

restrictions and conditions proposed. The UAS to be op erated hereunder is less than 15 lbs. fully

loaded, carries neither a pilot nor p assenger, carries no explosive materials or flammable liquid fuels,

and operates exclusively within a secured a rea as set out in this document and the DJI manual . Like

other civil aircraft, operations under this exemption will be tightly controlled and monitored by the

operator, pursuant to this document and the DJI Manual's requirements, and under the requirement s

and in compliance with local public safety requirements, to provide security for the area of operation as

is currently done on active construction sites. These safety enhancements, which already apply to civil

aircraft operated in connection with constru ction sites, 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 UAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load no

greater than two lbs.

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

This regulation requires certain experimental, provisionally certificated aircraft, or light

- sport category

aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light

sport," "exp erimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be

placed. Given the size of the UAS, two

- inch lettering 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 UAS marked on its fuselage as required

by 

### §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of

the UAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions

Nos. 10700, 873 8, 10167 and 10167A.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of

current operations by requiring the pilot operating the aircraft to have completed a UAS flight training

course of 10 hours before flying a UAS. Unlike a conventional aircraft that carries the pilot and

passengers, the UAS is remotely controlled with no living thing or cargo on board. The area of

operation is controlled and restricted, and all flights are planned and coordinated in advance as set

forth in this document. The risks associated with the o peration of the UAS are so diminished from the

level of risk associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations of the UAS as requested with a pilot who has met the minimum requirements of

this document exc eeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

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 airworth iness certificate issued for the aircraft, should this exemption be granted, no

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

requirements contained in the DJI Manual for maintenance and use of saf ety checklists prior to each

flight, as set forth in this document, an equivalent level of safety will be provided.9 14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

The UAS, given its size and configuration has no abil ity 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 UAS will have immediate access to it. The

FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 

### 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of

flight. An exemption is needed from this requirement as the pilot will take separate preflight actions,

inc luding checking for weather conditions, checking flight battery requirements, checking takeoff and

landing distances, and all other actions in the Preflight Checklist in this document and the DJI Manual.

These actions will provide an equivalent level of sa fety.

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. By design,

UAS and remotely piloted aircraft 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 previously approved exemptions for aircraft without fully functional dual

controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that

neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via radio

signals from the con troller, and by the 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. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescrib ed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is

for a multi

- rotor craft that flies similarly to a helicopter, with vertical take off and vertical landing, which

will typically operate at altitudes of 200 AGL, so an exemption may be needed to allow such operations.

The UAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security

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 UAS as

well as the location where it is operated. No flight will be taken without the permission of the prope rty

owner or local officials. Because of the advance notice to the property owner and any onsite personnel

as outlined in the Manual, all affected individuals will be aware of the planned flight operations.

Compared to flight operations with aircraft or ro torcraft weight ing far more than the maximum 15 lbs.

proposed herein and carrying flammable fuel, any risk associated with our operations is far less than

those presently presented with helicopters and other conventional aircraft operating at or below 500

AGL in the construction industry. In addition, the low

- altitude operations of the UAS will ensure

separation between these small

- UAS operations and the operations of conventional aircraft that must

comply with Section 91.119.

14 C.F.R. 91.121: Altimeter S ettings

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 departure airport or an appropriate altimeter setting

available before departure." As the UAS 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, pursuant to the Manual and Safety Check list, confirming the altitude of the launch si te

shown on the GPS altitude indicator before flight.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our UAS is

limited to operations in sterile and controlled environments as outlined in the Manual, and has a limited

range and flight time which require an exemption from 14 CFR 91.151(a).10 The battery powering the UAS provides approximately 

### 18 minutes of powered flight. To meet the 30

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to 0 minutes in length.

Given the limitations on the UAS's proposed flight area and the location of its proposed operations

within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is

reasonable. John Rowe dba Clear Lens Media believes that an exemption from 14 CFR §91.151(a) falls

within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to

operate without compliance with FAR 

### 91.151(a)). Operating the small UAS, in a tightly controlled area

where only people and property owners or official representatives 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

UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.

An equivalent level of safety can be ac h ieved by limiting flights to 18 minutes, or enough battery

reserve to ensure that the UAS lands at the ground station with at least 20% of battery power (as

determined by the onboard monitoring system and the pilot), whichever happens first. This restricti on

would be more than adequate to return the UAS to its planned landing zone from anywhere in its

limited operating area. Similar exemptions have been granted to other operations, including

Exemptions 2689F, 5745, 10673, and 10808.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration The regulation

provides in 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 certific ate....

(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 UAS ful ly loaded weighs no more than 15 lbs and is operated without an onboard pilot. Therefore

there is no ability or place to carry certification and registration documents or to display them on the

UAS.

An equivalent level of saf ety will be achieved by keeping these documents at the ground flight control

point where the pilot flying the UAS will have immediate access to them, to the extent they are

applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A representative

sample of other exceptions includes Exemption Nos. 

### 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A,

and 10700.

14 CFR 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 John Rowe, dba Clear Lens Media

. Maintenance will be accomplished by the

operator pursuant to the flight manual and operating handbook as referenced in this Document and the

DJI Manual. An equivalent level of safety will be achieved because these small UASs are very limited in

size and will carry a small pay load and operate only in restricted areas for limited periods of time. If

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400

feet AGL. As provided in the DJI and 3DR Manual s and this document , the operator w ill ensure that

the UAS 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.11 *******

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 

### 45.23(b);14

C.F.R. § § 61.113( a) & (b);91.7

(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a);

91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small

unmanned vehicle (551bs or less) in construction operations.

Approval of exemptions allowing commercial operations of UASs in the construction industry enhances

safety while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because

the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a

UAS weighing fewer t han 15 lbs. and powered by batteries eliminates virtually a ll of that risk

given the reduced mass and lack of combustible fuel carried on board. The UAS will carry no

passengers or crew and, therefore, will not expose them to the risks associated with manned

aircraft flights.

The operation of sm all UASs, weighting less than 15 lbs., conducted in the strict conditions

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions

requested herein, including exempting the applicant from the requirements of Part 21 and

allowing comme rcial operations. These lightweight aircraft operate at slow speeds, close to the

ground, and in a controlled environment and, as a result, are far safer than conventional operations

conducted with turbine helicopters operating in close proximity to the gr ound and people.



### 1312 

# Intended Equipment for Exemption

Aircraft (s) : 1. DJI Inspire 1 (camera included)

2. 3DR Solo (uses GoPro Cameras)

Radio Frequency: 2.4GHz ISM Radio Sensitivity:

- 97dBm

Manufactures Website (s) : http://www.dji.com/

http://www.3dr.com/

3DR Solo Cameras: GoPro Hero, and GoPro Hero 4

Manufactures Website: http://gopro.com/

14



# Aircraft Performance

DJI Inspire 1

- 

## Altitude: 1640 ft. (500m)

- 

## Operational Range: 3,280 ft. (1,000m)

- 

## Hover Accuracy: (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Precision Flight and Stable Hovering

- 

## Flight Time: 18 Minutes

- 

## Battery Life

Quad

- copter: 18 Minutes

Remote Control: Over 2 Hours of Continuous Use

- 

## Weight (Battery & Propellers included): 2935 g

- 

## Max Yaw Angular Velocity: 15 0/s

- 

## Max Tilt Angle: 35 0

- 

## Max Ascent Speed: 5 m/s

- 

## Max Descent Speed: 4 m/s

- 

## Max Flight Speed: 22 m/s (Not Recommended)

- 

## Take

- off Weight: 2935g

- 

## Operating Temperature:

- 10°C to 5 0°C

Self

- Tightening Propellers

1513 

# Maintenance

To ensure safe operational control a maintenance schedule will be followed, a personal

tailored maintenance manual has been created, and quality replacement part will be used.

Inspection : Before and after every flight, the quad

- copter's operational condition will be

inspected for damage and deterioration, paying attention to the props for damage, cracks or

ware and the UASs fuselage for damage . If damage, cracks or unusual ware is detected

the flight will be suspended until proper repairs have been made.

Maintenance

o Simon Newton's Maintenance Videos

https://www.youtube.com/watch?v=7Jum34eU4W8

o Also

http://www.phantompilots.com/viewtopic.php?f=7&t=5148

o Other tutorials and how

- to videos

Hypervision Australia Tutorials

https://www.youtube.com/watch?v=fKIAf j tdPgI&l ist=PLX7

-

5smcu

- Vw38bmfMnunAESCTiNgbt8S

Replacement Parts

o Dji (manufacturer)

o 3DR (manufacturer)

o Reputable After Market Companies

There is no intention in modifying aircraft beyond factory specifications.

• The UAS will be in compliance with the FAA airworthiness regulations.

1614 

# Safety Concerns

Hazards Spotter : To ensure safety, either the listing agent, seller, contractor, owner or

another party, will be on site to review and observe hazards before and during the flight.

Population of Intended Areas : To ensure safety, all non

- essential personnel will be

removed from the area. There will be no flight over heavily populated areas like stadiums,

schools, malls, casinos, and the like during operating hours.

Airports: According FAA rules and to ensure pilot(s) safety, there will no flight in or

around airports unless explicit permission is granted according to current FAA regulations.

Weather: To ensure safety of spotter, agents, property owners, pet and wildlife flights

will be conducte d in optimal weather conditions. Flights will not be conducted in winds

above 20 mph.

Return

- to

- Home Feature: In the event the DJI Inspire 1 or 3DR Solo loses signal or

runs critically low on battery the UAS has a GPS controlled return to home feature. Th e

"home" is set upon flight startup.

- Auto Return

- to

- Home & Landing

- See Pre

- Flight Checklist Exhibit A

Flying in Confined Areas: There is a high probability of flying in confined spaces,

around residential properties. Pilot and spotter will be in consta nt communication by

two way radio, or cell phone, or other approved FAA communications device when

geographically separated during flight to ensure awareness of obstacles, hazards

and UAS location.

Line of Site: The UAS will always be within the line of s ite of the pilot and spotter.

If the UAS cannot be seen the return home failsafe will be used to regain visual

control.

Height : Fights will not exceed 400 ft AGL above subject properties at any time.



### 1715 

# Potential Hazards

The following are potential hazards that may, or may not be,

present during flight operations. The Pilot and Spotter will be

aware of :

- Other UASs

- Houses, Commercial Buildings, Shops, and Out Buildings

- Power Lines, Low Voltage Lines, High Voltage Lines, Cable

Lines

- Trees, Shrubs , and Hedges

- Automobiles and RVs

- Wildlife, both Land and Air

- Rivers, Lakes, Ponds, Sounds, Straits, and Other Bodies of

Water

- Unaccounted for People

- Unaccounted for Pets

- Conditions as set forth in the DJI and 3DR Manual s

18



# Privacy Concerns

During flight operations privacy concerns are of high priority.

With each commercial flight a signed agreement, will be in place.

Seller/property owner, contractor, engineer or authorized agent will sign

a letter authorizing John Rowe, dba Clear Lens Media UAS's use for marketing

purposes.

-

Please see Exhibit B

.

Neighboring parcels or properties: During each flight operation, the UAS

pilot will be extremely mindful of neighboring parcels to not film, record, or take

pictures of people a nd property without their written & signed consent.

All neighboring properties will be cropped from photos unless authorization to

use such photos is granted in writing.16 

# Privacy Concerns Cont.

Suburban Homes & Properties

Homes that are within residential neighborhoods, it is easy for the camera's field

of view to record and take pictures of homes and properties that are not

i ntended to be advertised for sale. As the UAS increases altitude, so does the risk

of inadvertently filming a home or pro perty that hasn't given written permission

to do so. Where privacy is a concern images will be cropped to omit neighboring

properties

.



## Properties with Acreage

Homes and properties with acreage have a higher degree of uncertainty when

trying to determine lot lines, boundaries, and proximity to neighboring properties

than a suburban home. Also, people looking to purchase a home with acreage,

or a larger lot, have a higher degree of interest on knowing were the

a pproximate lot lines are and an aerial perspec tive affords them such

i nformation. The use of an UAS would be the most effeminate means to provide

such information.

Homes with View & Waterfront

People looking to purchase and/or sell a home, or a property, with a view, or on

waterfront, want to see the home or property from an aerial perspective and to

be showcased in this format. This is part of property owner profile. In addition,

even though neighboring parcels might be shown in the picture and video, the

neighboring properties will only be includ ed if is necessary to the subject

property's marketing materials. * All flights will occur over private or controlled

access property with the property owner's prior consent and knowledge. Images

taken will be of individuals who have also consented to bein g filmed or otherwise

have agreed to be in the area where aerial photography will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of

2012

-- size, weight, speed, operating capabilities, proximity to airports and

populated a reas and operation within visual line of sight and national security

- provide more than adequate justification for the grant of the requested

exemptions allowing commercial operation of applicant's UAS in the construction,

realty industry pursuant to the DJI Manual and this document appended hereto.*

2117 

# Operational Conditions

To capture high resolution images and video operational conditions will be

c losely monitored because showcasing a property in the best light is and image

quality is the utmost client priority.

Day Time

Sunny Weather is Highly Preferred

Little to No Cloud Cover

Zero to Low Wind Speeds

High Visibility Conditions

22 

# Pilot Qualifications

Training Sessions for a Clear Lens Media pilot(s).

Current Pilot: John Rowe

Please see Pilot's Training and Flight Log; Exhibit C

The Pilot in command will be familiar with current FAA regulations regarding UAS

commercial usage.

The Pilot in command will have sufficient eye sight (with or without corrective lenses

and without the aid of binoculars) to see and operate the UAS at the distances

necessary for the purpose of the flight.

Pilot will be in good health.

New Pilots in training will shadow and act as the Pilot in Command

Spotter for 3 Months or for a minimum of 20 ho urs Prior to First Flight Operations

New Pilots will demonstrate a workable knowledge or the UAS and proficiency in operational

control at all times.

Pilots in training will Watch Online Training Videos.

Pilots will watch Online Training Videos for S pecific Type of Filming Needs

Pilots will attend Upcoming, and Local, UAS Courses (This is Part of Pilot's Continuing

Education)

Pilots will attend Local Courses Hosted by Dji and 3DR (This is Part of Pilot's Continuing

Education)

Every Pilot Will Fo llow the Flight Plans and Schedules Set Forth in this Document and current

FAA regulations.

2318 

# Pre

- Flight Checklist

Prior to every flight, the pilot will go through a pre

- flight checklist. The checklist

will then be filed with every property's file in the event of an audit.

Preflight Checklist: Please see Exhibit A

.



# Active Flight Operations

Exercise continuous control of UAS, monitor potential hazards, be aware of

changing environments that may present hazards. UAS will always be in view of

Pilot and spotter. There will be a strict flight ceiling of 400 ft AGL. All flight will be

done in accordance with current FAA rules and the conditions set forth in this

document.

24 

# Additional Resources

- http://knowbeforeyoufly.org/

- http://www.dji.com/newpilot

- https://www.lioutube.com/channel/UC R io W t W R 9 BPVZK8

YxMrH2Zw

- http://www.modelaircraft.org/

- http://www.dji.com/product/phantom

- 2/download

- http : / /www.dj i .com/product /phantom

- 2/sec

- http://www.dji .com/suppor t

- http://wiki.dji.com/en/index.php/Phantom 2

- htt p ://wiki.dii.com/en/index.php/Phantom 2 Vision%213 Flight Limits

- http://www.dji.com/newpilot

2519 

### Exhibit A



# Pre

- Flight Checklist

Flight Operation Location: ________________________

Pilot:_________________________

Date:_________________________

Conduct Walk Around of Flight Area

Identify Potential Hazards with Spotter

Locate Safe Launch & Landing Area

Set Spotter (Spotter May Change Location due to Filming Angle) Secure all

Pets

. Request on Non

- Essential Personnel to Remain Behind Pilot

Unpack All Equipment from Transportation Case

Inspect UAS for damage, ware and proper flight setup according to the DJI

and 3DR m anual s . If no damage or unusual ware is detected pr oceed to

the next step. If damage is detected the flight will be aborted until proper

repairs are completed.

If the UAS is deemed flight worthy

- Power Up Remote

Power Up GoPro

Initiate Video Recording

Power Up DJI Inspire 1 or 3DR Solo

Launch DJI Inspire 1 or 3DR Solo

Conduct Flight Operations

Land DJI Inspire 1 or 3DR Solo in Designated Landing Area

Power Down Inspire 1 or 3DR Solo

Turn Off Video Recording

Power Down GoPro

Power Down Remote

Inspect UAS for damage and ware

Put All Equipment Back into Transportation Case

Pilot Signature___________________________________________

2620 

### Exhibit B

RE: Authorization to Record Video & Photograph Property



### I, , legal seller and/or representative, authorize and give permission to John Rowe dba Clear

Lens Media to record video and photograph the property commonly known as:

________________________________________________________________________

________________________________________________________________________

____________________________ ____________________________________________

The recorded video and photography is to be used in a manner consistent with the clients

interests, current real estate marketing strategies and advertising techniques, property

development, investigation and observation.

Sincerely,

Signature___________________________________________ Date

_______________

Signature___________________________________________Date_______________

2721 

### Exhibit C



## UAS Training Notes

Notes by John Rowe:

When I decided I wanted to shoot real estate vide os, etc. with drone s I knew I'd need to learn

all aspects of drone piloting. I wanted to learn the hard way, without the automated GPS hold,

auto level ing

, return to home and the other features in an effort to g ain the experience needed

to fly the drone manually in case one of these systems fail ed

.

I started out with a toy drone, the Syma X5C. I got a lot a great experience, but it was a toy

and didn't last long. Then I got a Blade 200 QX made by Horizon Hobby

. The Blade 200 QX

may look like a toy but it is no t. It is powerful and has bee n an excellent training drone. But the

Blade 200 QX is not immune to damage

. In an effort to excel my manual drone piloting skills I

practice by racing my drones around a course in my back yard about 75 yards long. I've

crashed the Blade 200 QX many times. And have rebuilt it many times. I replaced the plastic

body with a aftermarket carbon fiber and CNC aluminum body, but it didn't help much. I got to

where I was afraid to crash the Blade 200 QX and felt it was impeding my ability to advance

my manual drone piloting skills.

So now in addition to practicing with a DJI Inspire 1, I practice daily with an Armattan CF 258

quad

- copter made of carbon fiber . The Armattan CF 258's fram e comes with an unlimited

lifetime warranty, and therefore I no longer have any fear about crashing. Which by the way, I

do rarely any more.

The Armattan CF 258 is incredibly powerful and stable, truly an excellent training drone.

For more info on Armattan carbon fiber quad

- copters please review:

http://www.armattanquads.com/carbon

- fiber

- quadcopters/

Flying the DJI Inspire 1 is incredibly easy. With GPS hold, auto leveling, return to home, etc. it

is very simple to operate. But I can't express how much better I feel knowing I've already

trained myself to fly the $3,500 DJI Inspire 1 manually incase one of the above systems fails.



## UAS Flight log

Pilot

- John Rowe

Date Location Hours Notes

03/01/15 Home

- 26400 Via Mallorca

- Carmel, CA

93923 0.5 Practice

03/02/15 Home 0.5 Practice

03/03/15 Home 0.5 Practice

03/05/15 Home 0.5 Practice

03/06/15 Home 0.5 Practice

03/08/15 Home 1 Practice22 Date Location Hours Notes

03/09/15 Home 0.75 Practice

03/11/15 Home 1 Practice

03/12/15 Home 0.75 Practice

03/13/15 Home 1 Practice

03/15/15 Home 0.25 Practice

03/24/15 Home 0.75 Practice

03/25/15 Home 0.5 Practice

03/27/15 Home 1 Practice

03/28/15 Home 1.25 Practice

03/29/15 Home 0.75 Practice

03/31/15 Home 1 Practice

04/01/15 Home 0.5 Practice

04/02/15 Home 1.5 Practice

04/03/15 Home 0.5 Practice

04/04/15 Home 1.25 Practice

04/23/15 Home 0.5 Practice

04/24/15 Home 0.5 Practice

04/25/15 Home 0.5 Practice

04/26/15 Home 1.25 Practice

04/27/15 Home 1 Practice

04/28/15 Home 1.5 Practice

05/02/15 Home 0.5 Practice

05/03/15 Home 1 Practice

05/04/15 Home 1.25 Practice

05/05/15 Home 1.5 Practice

05/06/15 Home 0.5 Practice

05/07/15 Home 1 Practice

05/08/15 Home 1.25 Practice

05/09/15 Home 0.5 Practice

05/10/15 Home 1 Practice

05/13/15 Home 0.75 Practice

05/14/15 Home 0.5 Practice

05/15/15 Home 0.25 Practice

05/16/15 Home 1 Practice

05/17/15 Home 0.75 Practice

05/22/15 Home 2 Practice

05/23/15 Home 1.5 Practice

05/25/15 Home 0.75 Practice

05/27/15 Home 1 Practice

Total 38.5