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May 17, 2015

Falcon Aerial Inspections, Inc.

311 Bauman Ave Pittsburgh PA 15227-1305

Cell: 412-720-4506 Email: FalconAerialInspections@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 (links provided for files over 10 MB): 1) Phantom 2 Vision+ User Manual 2) Phantom Quick Start Manual 3) Phantom 2 Vision Pilot Training Guide 4) Phantom 2 Vision Release Notes 5) Phantom 2 Vision Battery Safety Guidelines 6) Phantom Flying Flowchart

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA201 40481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA–20 14–0508 in the matter of the petition of ADVANCED AVIATION SOLU TIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA2014 0355 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 Modernizatio n and Reform Act

of 2012 , I, John Barry, President of Falcon Aerial Inspections Inc., 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). 91.405(a). 91.407(a)(1). 91.409 (a)(1). 91.409(a)(2). 91.417(a) & (b).Page 2 of 7

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal A viation Administration (FAA) for the purposes of aerial pho tography, structural inspections of bridges, pipelines, well and cell to wers, real estate marketing and surveys and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitu de within the U.S. national airspace system as compared to a manned aircraft. O perations will be performed only at the request of and with the authorization a nd permission of clients or their authorized agents in order to facilitate comm erce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations

are conducted within and under the conditions outli ned herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by, Falcon Aerial Inspections are drawn fr om references 13.

The FARs I, John Barry, President of Falcon Aerial Inspections Inc., request exemption

from the above mentioned FARs for the following reasons. I have been a licensed

Private Pilot since November 1989 and hold a Class III Medical Certificate.

61.113(a) & (b) . I, John Barry, President of Falcon Aerial Inspections, Inc request relief in order to facilitate the utilizati on of pilots, who hold a private pilot (or greater) certificate. Any pilots operating unde r this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions. A Visual Observer wi ll be used at all times while under this requested exemption.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may re quire 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 “c ongested areas” and “densely populated”. I, John Barry, President of Falcon Aeri al Inspections Inc., request

waiver for this condition to allow reasonable and r esponsible 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 instea d 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 ma nned aircraft to operate at less than the prescribed minimums, including Exempti on Nos. 2689, 5745, andPage 3 of 7

10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, V FR conditions. The UAS provides battery power remainin g in percent to the PIC. The UA batteries provide approximately 25 minu tes of powered flight. Information provided in the operating documents dis cusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure whe n battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a red uced minimum power reserve for flight in daytime VFR conditions was re asonable.

91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.41 7(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, J ohn Barry, President of Falcon Aerial Inspections Inc., propose to inspect and ensure that the UAS is in a condition for safe flight in accordance with the op erating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and limitations specified, describing the requireme nts for maintenance, inspection, and recordkeeping, were sufficient to e nsure that safety would not be adversely affected.

The UAS The DJI Phantom 2 vision plus is a highly successfu l consumer grade small rotorcraft in the quad copter 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 kno ts (15m/s) and a maximum climb rate of less than 1200 feet per minut e (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 cont rolled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowi ng the operator and/or PIC to monitor battery level, GPS signal strength, altitud e (AGL), distance from PIC, camera imagery, and control camera angle. It has fa il safe modes of operation for either loss of RC or GPS signal. Altitude can b e limited by the onboard flight controller and maximum altitude can be preprogramme d by the PIC. Battery life limits flight times to approximately 25 minutes. Th e onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight a nd 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 inform ation is available in attachment

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Risk mitigation I, John Barry, President of Falcon Aerial Inspections Inc., have reviewed FAA exemptions reference’s 13 Conditions and Limitations section and believe that the procedures specified t herein are reasonable and will be utilized in order to manage and mitigate ri sk and ensure public safety.

A preflight checklist will be developed and employe d to ensure that the UAS’s

airworthiness will be verified before launch. Airwo rthiness will be maintained by performance of routine inspections before each flig ht, maintaining flight and maintenance logs to record time on failure prone co mponents.

I, John Barry, President of Falcon Aerial Inspections Inc., request that in a manner similar to reference 13, be allowed to opera te within 5 miles of an airport provided that.

“The UA may not operate in Class B, C, or D airspac e without written approval from the FAA. The UA may not opera te within 5 nautical miles of the geographic center of a non to wered airport as denoted on a current FAA published aeronautical cha rt 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 agree ment with the airport management must be made available to the Ad ministrator upon request.”

Operations within 5 miles of an airport are not ant icipated to be routine but I am requesting a mechanism to facilitate such activitie s without requesting a new and separate exemption(s) should the need arise. Op erations within class B airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would e nhance safety and reduce the environmental impact as compared to similar operati ons conducted with manned aircraft of greater proportions, carrying a crew an d flammable fuel.

In regards to performing inspections of bridges, to wers, and natural gas pipelines the UAS will minimize the risk to persons attempting to climb these structures and photograph problem areas. It will pr ovide a way for companies to have their engineers review photographs and provide additional safety to the general public in regards to towers failing or natu ral gas pipelines having structural issues. Many of the natural gas pipeline s 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.Page 5 of 7

I, John Barry, President of Falcon Aerial Inspections Inc., will also make the UAS and myself available to local voluntee r organizations (for no charge) such as fire departments, local law enfo rcement, etc., to perform search and rescue operations, or other simi lar events as directed by

authorities.

In addition the use of the UAS in order to facilita te commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced persp ective for characteristics, amenities, and benefits of their desired photograph ic 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 and the PIC will hold a Private Pilots

license.

Flight data including UAS flight time, Control Unit operation time, incident, and details will be recorded for each fli ght 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, John Barry, President of Falcon Aerial Inspections Inc., am requesting this exemption for the purposes of aeria l photography of real estate, bridge inspections, lan d surveying, pipeline inspections, tower inspections, and other flight operations. The reason for such a general and broad based reque st is that I, John Barry, President of Falcon Aerial Inspections Inc., wish t o 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 exe mptions.

My business model is based on the idea of offering small UAS services to individuals or companies who wish to em ploy these services as a safe, effective, and legal option to enhance their business or prevent structural disasters that may i nfluence the general public or individuals.

My own research shows an upward demand for these se rvices that currently exists in the real estate market, natural gas market and other markets are just beginning to realize the nee d for such

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I, John Barry, President of Falcon Aerial Inspectio ns Inc., have been

a licensed Private Pilot #2881711 since November 19 89, hold a Class III

Medical Certificate and have flown over 100 hours i n fixed wing aircraft and autogyro aircraft. I have flown Radio Controlled Aircraft since 2013. I am familiar with aircraft preflight. Falcon Aerial Inspections, Inc. is a business corporation incorpo rated on January 24 2014 under the provisions of the Pennsylvania Busin ess Corporation Law of 1988, entity number 4241643.Page 7 of 7

URL Links for attachment files over 30 MB:

1) Phantom 2 Vision+ User Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/ Phantom_2_Vision_Plus_User_Manual_v1.8_en.pdf

2) Phantom Quick Start Manual

http://download.dji-innovations.com/downloads/phant om/en/PHANTOM_Quick_Start_Manual_v1.7_en.pdf

3) Phantom 2 Vision Pilot Training Guide

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/ Phantom_2_Vision_Plus_Pilot_Training_Guide_v1.1_en. pdf

4) Phantom 2 Vision Release Notes

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/ Phantom_2_Vision_Plus_Release_Notes_en.pdf

5) Phantom 2 Vision Battery Safety Guidelines

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/Sma rt_Flight_Battery_Safety_Guidelines.pdf

6) Phantom Flying Flowchart

http://download.dji-innovations.com/downloads/phant om/en/PHANTOM_Flying_Flowchart_v1.0_en.pdf