FAA

- 2007

- 0001

Paul Funk Aerovues 100 W . Montereys Av e. Schaumburg, IL

6 0193 847

- 361

- 7074 (cell)

This request is in reference to the F AA Modernization and Reform Act of 2012, Public Law 1 12

- 95 FEB. 14, 2012, Section 333. I would like to request an exemption to allow for the following applications: • Real Est ate V ideography and Photography • W edding V i deography and Photography • Land survey & appraisals• Equipment Inspections • Roof Inspections • Construction sites before & af ter

• Aerial V ideography and Photography • Creation of commercial messages for Te levision. • Motion Picture Filming • Increase p ublic knowledge of UAS and promote safe UAS operations.

While requesting the exemption for the use of the UAS for these applications I would like to present my case for the exemption from the following regulations. 14 C.F .R § 61.1 13(a) & (b) 91.7(a) 91.12 1 91.151(b)91.405(a) 91.407(a)(1) 91.409(a)(1) & (a)(2) 91.417(a) & (b) The drone we are requesting exemption for is the DJI Phantom Pro. W e have chosen this drone due to it's reliability and safety features which have all been granted previous exemptions. This drone will be equipped with a 4k, high resolution camera, which will be used for the photography and video p ortion of the applications we are seeking exemption for. For the purposes of brevity, the extent and reason for relief will be explained below per each requirement. In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraf t and its operation, Aerovues DJI Phantom Pro’ s UAs meets theconditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subp art H.

Accordingly

, Aerovues request s reli ef from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraf t with an airworthiness certificate. There will still be a safety requirement in ef fect to ensure proper operation of the drone at all times. Which will include a manual pre

- flight check, a weekly maintenance check, and a limit to flight times based on available flight cap ability

. This flight time will not exceed half of the available fligh t time. A maintenance checklist will be maint ained for allpre

- flights and weekly check. Any rep airs needed to be made will be documented, along with any failures that caused an inability to fly

. Also at any time the logs will be made available to any p art ies involved with the flight. Also any law enforcement may ask at any time for any of the flight manuals and/or logs. Records will be kept of each check for the life of the use of the drone for commercial purposes. These documents will be kept with the (PI C) during flight. Relief from cert ain requirement s of Section 61.1 13(a) and (b), entitled Private pilot privileges and limit ations: Pilot in command, is requested by Arovues, to the extent necessary to allow a Pilot in Command (PIC) with a minimum of 20 ho urs of UAS flight time with the specified model. This is to include emergency maneuvers to avoid any private or public damage, and any injuries to the public, by an unforeseen failure of the drone in use. A device (such as cell phone)cap able of cont acting emergency services and a first aid kit at the flight site at all times. W e would also like to request relief due to the UAS not being manned but pilot or pa ssengers, and due to it's small size and weight, and complying with st aying under 200 feet of altit ude, similar to an ultralight which does not require certification either

. Also since I am requesting exemption from the aircraf t worthiness certificate I would be unable to provide all of the required document ation for gaining the pilot certification. All of the (PIC)s will still be required to have yearly physicals, and any corrective devices used authorized and prescribed by a Board Certified MD.

Aerovues seeks relief from Section 91.7(a), entitled Civil aircraf t airworthiness, because the DJI Phantom P ro UAS do not require an airworthiness certificate in accordance with 14C.F .R. Part 21, Subp art H. As such we will maint ain airworthiness based on the operator manuals and precedents set by prior granted exemptions. This is to include the aforementioned m aintenance check, pre

- flight checks, and minimum (PIC) requirement s.

Aerovues also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom Pro will not have a barometric altimeter onboard. However, altit ude information of the DJI Phantom Pro UAS will be provided to the (PIC) via Global Positioning System (GPS) equipment and radio communications telemetry dat a link, which downlinks from the UA to the GCS for active monitoring of the flight p ath. Also with the current model at no time will the DJI Phantom Pro leave the (PICS)s visual line of sight. With our current intended uses of the UAS wewill also not have a need to exceed 200 feet of altitude.

Additionally

, Aerovues, seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirement s for flight in VFR conditions. Aerovues submit s that safety will not be af fected by operation of the DJI Phantom Pro UAS during daylight hours in visual meteorological conditions (VMC) under visual fli ght rules (VFR), with enough battery power to fly for a tot al duration of approximately 10 minutes, which is more than enough time needed for our intended applications of use. Also to ensure safety, once flight time, or battery power (whichever occurs firs t) have reached a halfway mark, the UAS will be returned to the flight area and a freshly charged battery will be used if more flight time is needed.In accordance with 14 C.F .R. § 11.81 , provides the following information in support of it s petition for e xemption Name and cont act information of intended Primary (PIC)s Paul B. Funk 100 W . Monterey Av e. Schaumburg, IL

60193 (847) 361

- 7074 cell

Sp ecific areas of requested exemption. Section Part 21, Subp art H Section 61.1 13(a) And (b) Section 91.121 Section 91.151(b) Section 91.405(a) Section 91.407(a)(1) Sections 91.409(a)(1) And 91.409(a)(2Sections 91.417(a) And 91.417(b). Per the mission behind integrating UAS into the NAS below is how granting Aerovues an exemption will benefit the public. Increased safety for aerial photography

. Ty pical means of aerial photography require a manned and piloted vehicle. The ability to use a drone will not only cut down on environment al and noise pollution, but will also increase personal safety by being unmanned, lighter, and using electrical propulsion instead of gas powered.

Economical Benefit s. Granting us this exemption will help Aerovu es st abilize it's business plan, in turn this will provide Aerovues income, and allow us to assist others with advertising of their business which in turn can increase their

revenue. All of this can also be of fered more af

fordable than the typical means, a nd those that may not have had accessto this method before now may have a viable solution.

Any concerns of Privacy will be complied with by asking for property owner permission before any flight is t aken. Also by cooperating with any civil service or law enforcement agency

. Also any commercial flight will be well documented with address, time, property owner names, and intent of flight. Copies of these will be made available to any involved pa rties that may ask.

Granting these exemptions will not be a da nger to public safety due to the stringent pre

- flight requirement s we are placing all (PIC)s under

. As explained earlier all (PIC)s will have a minimum of 20 hours of documented flight time with the intended drone, as well as thorough knowledge of the main tenance requirement s of the specific model. All (PIC)swill also maint ain the cap ability (such as a cell phone) to cont act any emergency services that may be necessary

. All (PIC)s will also only fly in daylight hours with V isual meteorological conditions a nd V isual flight rules. The drone will never be flown longer than 50% of the intended battery life or average flight time, whichever occurs first. The drone itself is also equipped with several safeties of it's on including a return to flyer when it loses connectivity with the (PIC) or if the battery life does suddenly drop to %10. These safety requirement s and pre

- flight requirement s were all pulled from previously granted exemptions by the F AA. aerovues have chosen the requirement s that we felt we could c omply with, that also provided an adequate level of safety. Some of these requirement s were pulled from the previously granted exemption Nos. 1 1062, 1 1063, 1 1064, 11 065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 1 11 36,111 38, 1 11 50, 1 11 53, 1 11 56, 1 11 58, 1 1 159, 1 11 60, 111 61.

Due to having met the previous requirement s, and due to the size and weight of the intended drone. W e also do not believe this drone to be a danger to the NAS or National Security

. This Petition is made pursuant to the F AA Modernization and Reform Act of 2012 (FMRA) Section 333, which direct s the Secret ary of Transport ation to determine if cert ain UAS may operate safely in the NAS. As such, Aerovues request for exemption may be granted pursuant to the authority of FMRA

Section 333 and 14 C.F .R. Part 1 1, as set forth above. FMRA

Section 333 set s forth the requirement s for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides theauthority for such UAS to operate without airworthiness certification. As discussed in det ail above, Aerovues will operate the DJI Phantom Pro UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national se curity

.
In Conclusion, Aerovues thanks the F AA for it's time, we underst and many of exemptions are being requested at this time, therefore we have tried our best to cover the material necessary but in a brief format. If there are any other questions pleas e feel free to cont act the

owner, Paul Funk for answers to any technical or safety

concerns.