May 20,20 15 Aerial Earth PhotoDrones LLC 3700 Dean Drive #2802

Ventura, CA 93003

U S Department of Transportation and Federal Aviatjon Adminjstration 800 Indepe ndence Avenue , S.W. Washington, DC 2059 1 Attn : Dan Ngo , Program Analyst, Aircraft & Airport Rules Division Re: Docket No. FAA-2015-0196 Petition for Authorization/Pe rmit US Congress PL 112-9 5,20 12, Section 333, FAA Reform Act, for limit ed, safe and responsible commercial u se of Small Unmanned Aircraft (SUA) Thank yo u for responding to my petition for waiver of th e above Section 333

. I would like to state that I wou ld like a temporary waiver until the certification process is approv e d and available

. At that time , I will g ladly apply for the certification as stated in Section 333. Until then , I do requ est a waiver

. Per you r requ est for further ex planation under Title 1 4 , Chapter 1 , Subchapter B , Part II , Subpart A, 

### § 11.81 , I will pro v ide the necessary answers below.

• The specific section or sections of 14 CFR from which I seek relief and the extent of th e relief I seek. Please find brief explanations in Appendix A. 14 C.F.R. Part 2 1 14 C.F.R. 45.23(b 14 C.F

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

. R

. 6 1.133 (a) 14 C

. F.R. 9 1.7(a) 14 C.F.R. 9 1.9(b) (2) & (c) 14 C.F.R. 9 1.103 14 C.F

. R

. 9 1.109 ( a) 14 C

. F.R. 9 1.119 14 C.F.R. 9 1. 203(a) & (b) 14 C. F. R. 9 1. 3 19(a)( I ) 14 C.F

. R. 91.405(a) 14 C.F.R. 9 1.407 (a)( l ) 14 C.F.R. 91.409(a) (2) 14 C.F.R. 91.417(a)

• Reasons why granting the requ est wo uld be in the pub li c

**interest**

**~** that is, how it wou ld benefit the public as a who le. By obtaining a temporary waiver to permit commercial operations , Aeria l E arth PhotoDrones LLC would perform aerial surveys of archaeological, environmental, power company ( oil fields , gas and oi l pipelines , land s urvey, leak d etect ion , e tc .), including

### Aerial E arth PhotoDrones LLC 3700 Dean Drive #2802

Ventura, CA 93003 photography , s urvey a nd vis ual in spectio n without requiring ' boot s on th e ground ' survey wo rk over possib le hazardous or sens iti ve terrain

. This b e ne fit s not only the peo pl e in vo l ve d for safety reaso n s, bu t a lso th e p ublic si nce a quick aerial s u rvey co uld d etect poss ib le da ngerous or hazardou s conditio n s. For i n stance, an aerial s urv ey over th e la nd scape could locat e possible fir e da nger (s ince Ca lifornia is in a seve r e drought) and e liminat e the need of humans or equ ipment to enter these drought lo cation s, could locat e threat e ne d or e ndan gere d species of pl ants (th ereby pr eservi n g habitat) and again e lim in ate the need of hum an s to imp act the area , fi nd critica l habitat that i s threatened d ue to th e ongoing drought or human careless ness , or detect leaks or im pe ndin g leaks in pip e lin es. B y using a s ma ll and efficie nt quadcopter, the necessity fo r hum a n pe rs onn e l or co n ve ntional aircraft is e liminate d. T hi s me an s a mor e eco nomical , quick and safe mean s to obtain vital information

.

• Any ad ditional inf o rm at io n , v iews , o r argume nt s ava il ab le to s upport your requ est. As a lic ensed private pilot , and the hold e r of two Bachelor degr ees in A rchae ology a nd Envi ronmental Resource Manage me nt/ Co n se rvation Bio logy, and on my third year of g raduate schoo l for my Master of Arts deg ree in Arc hae ology , alon g w ith more than fifte e n years experi e nce as an archaeologist, con servatio n biologist , and water re s ource m anage m e nt specialist, I be li eve I a m in a uniqu e posi ti o n as a woman-owned business to perform the above-m e ntion ed duties. I have already rece ived several req uests to perform aeria l photography of two archaeological si tes and have co ntacts w ith several e nvironmental consultants and po we r companies for additional survey work. If granted a te mporary waiv e r to u se my unmann e d aerial aircraft for commercial purpo ses, I can begin the se jobs immediately.
I al so h ave a business licen se and all necessary d oc ume nt s fil e d for my business. My quadcopter , and propo se d future purchase of a he xacopter, are both und er 55 pounds, as st ipul ate d by th e propo sed stat ute, will be u sed for day time u se only , with visua l-line-of-s i ght operations, und e r 400 f ee t AGL. Thank you very much for you r t im e. If you re quire a n y additional informat ion , pl ease do not hes it ate to contact me. My phone numb er is 805-861-9800 a nd m y e mail is ga i I be lleng e r @ yahoo. com . S inc erely ,



# t{~~

Gai l Be ll e nger 

### Ovmer, Aerial Earth PhotoDro ne s LLC 3700 D ean Drive, #2802 Ventura , CA 93003



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### Aerial Earth PhotoDrones LLC 3700 Dean Drive #2802

Ventura, CA 93003
A()Jlendix A

14 C.F.R. Part 21, Subpart H: Ainvorthiness Certificates 14 CFR 

### § 91.203(a)(l) Due to the size and weight (unde r 10 pound s) and th e limited area of operation of my DJI Ph a ntom 2 Vision + Q uadcopter (and future hexacopter), I request that thi s certification be wa ived under Part 21 Subpart H. This would abide by safety measures und er Part 11 and Section 333 of the Refonn Act. 

### 14 C.F.R. 

### § 45.23 & 

### 91.9(c): Marking of the Aircraft As the DJl Quadcopter is a s mall , unmanned vehicle, containing its ' serial number located under the battery bay , with ample room for future registration numbers and/or appropriate additional markings to be affixed, Aerial Earth PhotoDrones LLC wi ll mark the quad w ith whatever marks are appropriate to designate insp ectio n or r egist ration in the future. The FAA has previously issued the following exempt ions to this regulation , see Exemption Nos. 8738, I 0 167 , I 0167 A and 10700. 

### 14 C.F.R. § 

### 61.113(a) & 

### (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. Aerial Earth PhotoDrones LLC, does not operate any aircraft that carries a pilot or passengers and is , in fact , controlled remotely with a handheld transmitter. However, I personally do hold a private pilot certificate (93504636). I request exemption from this rule to allow additional pilots, after training, to operate the qu ad. The DJI Quadcopter is associated with a smart phone /personal computer application that displays battery lif e, a ltitude, a ircraft climbing speed and flight speed, and is equipped with a fail-safe automatic aircraft return to home feature s hould the battery fail or deplete. The is a warning light set-up to noti fy the operator should the GIS or Wi-Fi system not be operating correctly. 

### 14 C.F.R. 

### § 91.7(a): Civil aircraft airworthiness. I will personally maintain the quadcopter to assure it is undamaged and ainvorthy at all times, including a visual pr e-flight check prior to eac h and every flight. DJI, th e manufacturer of the quadcopter ha s a so lid safety reputation

. Aerial Earth PhotoDrones LLC also has a drone copter repair facility nearby s hould any damages occur. 

### 14 C.F.R. § 

### 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. Due to the small s ize of the Phantom 2 Vision+ Quadcopter, it is not possible to carry a flight manual aboard, howev e r, the flight manual is always available while flying. The FAA has pr

ev iously issu e d the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658,10167, 10167A , 10602,32827, and 10700. 

### 14 C.F.R. 

### § 91.103: Preflight action Aerial Earth P hotoDron es LLC always conducts a preflight check of th e quadcopter prior to any fli ght. The instruction manual is always available and carried on s ite

. 

### 3Aerial Earth PhotoDrones LLC 3700 Dean Drive #2802

Ventura, CA 93003

14 C.F.R. 

### § 91.109(a) & 91.319(a)(l): F light Instruction The Phantom 2 Vision + Quadcopter i s contro ll e d via a sing le remote tran smitte r . The quadcopter is programmed via software eq uipped with waypoints or by lin e -of-sight via th e transmitter controller

. The FAA has pr eviously exempted this requireme nt , Exemption Nos. 5778K 

### & 9862A.
14 CFR 

### § 91.119: Minimum Safe Altitudes To abide by this regulation , Aerial Earth PhotoDrones 

### LLC never flies abov e 400 feet 

### AGL , within fiv e miles of any airport , over populated areas or peo pl e. Due to the purpo se of relatively low

- flying aerial photography and survey, I am requesting an exemption from Section 91.119(c)

. Permission to fly over privately held land will b e obtained by the landowner or manager ahead of any flight.
14 C.F.R. 

### § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration Aerial Earth PhotoDrones 

### LLC request s waiver of this regulation due to the fact that the Phantom 2 Vision + Quadcopter is small, unmanned and does not have the capacity to carry or display certificates in a location visib le for the flight crew, as the operator especially remains on the ground. Any and all necessary certificates will remain with th e operator or within close proximity

. There have been previous exemptions to this regulation. 14 C.F.R. 

### § 91.40S(a); 407(a)(l); 409(a)(2); 417(a): Maintenance Inspections As the Phantom 2 Vision + Quadcopter doe s not regularly require routine maintenance and has the capacity to perform its own systems verification, with alerts if there are any prob lems, Aerial Earth PhotoDrones 

### LLC requests a waiver for this regulation. A pre-flight check is always performed by the ope rator prior to any and a ll flight , which includes a systems check, visual inspection of th e quadcopte r a nd verification that all batteries and e quipme nt are fully charged prior to flight.

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