### ALL AERIAL PHOTOGRAPHY 948 Oakpoint Circle. Apopka, FL 32712 adm·den(a super-bar.com Phone (407) 880-1402 Fax (407) 880-6099 Mobile (407) 467-1039 February 21 , 2015 U

.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room Wl2-140 1200 NewJersey Avenue, SE VIA ELECTRONICALLY Washington, DC 20590 VIA Re: Exemption Request under Section 333 oftheFAA Reform Act and Part 11 oftheFederal Aviation Regulations Dear Sir orMadam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11 , All Aerial Photography (CAV) seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described Unmanned Aerial System called in this application the CAV System, which includes an Phantom 2 Vision+, quadcopter Unmanned Aircraft (UAS) and ground station-based equipment and crew: THE PHANTOM 2 VISION+ UNMANNED AIRCRAFT (UA):

• A lightweight (maximum gross weight of3 pounds), electric motors powered by batteries

and operated with four rotors in the form ofa quad-copter that takes offand lands vertically, manufactured by DJI, PHANTOM 2 VISION+, 3-axel camera stabilization system; • An on-board flight computer with GPS navigation and location ability that receives

signals for flight controls from a ground-based transmitter /controller; • An GoPro 3+ camera capable ofcapturing imagery in the form offull color, high

definition still photos and video; • An on-board telemetry system that delivers flight data from the on-board flight computer

to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site; • A 5.8GHz on-board radio transmitter that transmits live video from the on-board camera

plus all the flight data from the telemetry system described above; Frequency 2462MHz THE GROUND STATION-BASED PART OF THE SYSTEM: • A Pilot in Command (PIC) in operational control ofa flight operation from beginningto

end and who controls the UA while inthe air; • A lOOmW, 2.4GHz radio transmitter/controller operated by the PIC to control the UA

while in flight; • A radio receiver receiving live video and flight data from the on-board cameraand

computer projects it all together onto a screen for the PIC to view during flight; • A Visual Observer (VO) is a person who provides a second pair ofeyes to visually track

the UA while in flight. The requested exemption would support an application for a commercial Certificate of

Page 1 of3Authorization to use the above described CAV System to conductaerial videography and cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout ofthe metro Orlando, Florida and surrounding area and augment real estate listing videos.

The UA, powered by batteries, is smaller, lighter, requires no fuel, and more maneuverable than largeraircraft running on combustible fuel, it operates at lower altitudes with no people on board andwill thereby reduce current risk levels and thereby enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum flight time ofonly 25 minutes with maximum air speed of30 knots, this is offers little orno risk to national security. Low-level oblique photos and video from several angles are far more effective than groundbased imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. The applicants in the pasthave chartered 2-seat full-sized helicopters for this purpose, which has proven more costly than many potential clientshave been able to afford. The benefits ofreduced cost and improved quality ofpresentationfrom the UA will be valuable to and benefit many buyers and sellers ofreal property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited inthis application as we do so. The CAV System will be operated in the field with both a PIC and aVO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and withthe following Restrictions:

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; (d) Operations will be restricted to flights overprivate property with the permission ofthe property owner; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UArotorcraft pilot and at least tenhours logged as a UA pilot with a similar UAtype; (f) All required permits will be obtained from state and local government priorto operation; (g) The CAV System will not be operated over densely populated areas; (h) The CAV System will not be operated at air shows; (i) The CAV System will not be operated over any open-air assembly ofpeople; 

## G) The CAV System will not be operated overheavily trafficked roads; (k) The CAV System will not be operated within 5 NM ofan airport or heliport; (1) The CAV System will not be operated overproperties smallerthan two acres in size; (m) Operations will be restricted to day only and weather conditions equivalent to VFR; (n) The PIC will briefthe VO and property owner about the operation and risk before the first flight at each new location; (o) No flight may be made without a Pre-Flight Inspection by the PIC before eachoperation Page 2 of 3to ascertain that the UA is in a condition safe for flight (see Appendix A).

The PIC and YO will meet the requirements outlined in FAA Policy N 8900

.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance onthe system and will complete a course ofmaintenance instruction as part oftheir initial training. We submit that the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all ofthe Restrictions (a) through (o) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level ofsafety than manned aircraft performing the same mission

. The name and contact information ofthe applicant are: All Aerial Photography, LLC Attn: Anastasia Durden Phone: ( 407) 880-1402 Fax: (407)880-6099 Email: adurden@super-bar.coll} The Title 14 Code ofFederal Regulations from which the exemptions are requested and listed below

. Beside each regulation number is the page ofthe attached Addendum upon which each may be found together with our proposed equivalent level ofsafety for eachregulation:

- 14 CFRPart 21

.. .... . .. . ........................ . ......Addendum Page 4

- 14 CFR 45.23(b)

................ . ..... . .. . .. . ..........Addendum Page 4

- 14 CFR 61.113(a); 61.113(b); ...... .. .......... .. ...Addendum Page 4

- 14 CFR 91.7(a); 91.9(b)(2); 91.103(b)

.............Addendum Page 4

- 14 CFR 91.109; 91.119; 91.12l..

...... . ..... . .... ..Addendum Page 3

- 14 CFR 91.151 (a); 91.203(a) & (b)

.... .. . .... .. ..Addendum Page 4

- 14 CFR Subpart E (91.405(a); 91.407(a)(l)

.... ..Addendum Page 4

- 14 CFR Subpart E (91.409(a)(2) ; 91.417(a) & (b)) Addendum Page 4 -FAA Policy 8900

.227 Paragraph 16(c)(4) and Paragraph 16(e)(l)

.. .Addendum Page 4 We are prepared to modify or amend any part ofthis request to satisfy the need for an equivalent level ofsafety. Please contact us at any time ifyou require additional information or clarification. We look forward to working with your office. Sincerely,

stasia Durden All Aerial Photography Addendum containing Exemption Requests and Equivalent Level ofSafety Appendix A - FlightManual Appendix B- Owner's Manual for Phantom 2 Vision+ (UA) Page 3 of 3ADDENDUM EXEMPTION REQUESTS AND EQUivALENT LEYEL OF SAFETY All Aerial Photography, requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe CA V System: 14 CFR Part 21, Subpart H: Airworthiness Certificates 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research anddevelopment. Testing new aircraft design concepts, new aircraftequipment, new aircraft installations, new aircraft operating techniques, or newuses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance withthe airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations.

Section 45.23(b) prescribes that when marks include only the Roman capital letter "N"andthe registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Section 61.113(a) and (b) prescribesthat- (a) no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers orproperty for compensation or hire; nor may that person, for compensation orhire, act as pilot in command ofan aircraft. (b) a private pilot may, for compensation or hire, act as pilot in command ofanaircraft in connection with any business or employmentif: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation or hire. Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is inan airworthy condition. Section 91.7(b) prescribes that the pilot in command ofa civil aircraft is responsiblefor determining whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when unairworthy mechanical, electrical, or structural conditionsoccur. Section 91.9(b)(2) prohibits operation ofU.S.-registered civil aircraft unless there isavailable in Addendum Page 4 of 10the aircraft a current approved Airplane or Rotorcraft Flight Manual, approvedmanual material, markings, and placards, or any combinationthereof. Section 91.103(b) prescribes that a pilot shall for any flight, become familiar withrunway lengths at airports ofintended use, and takeoffand landing distanceinformation. Section 91.109(a) prescribes, inpertinentpart, that no person may operate a civilaircraft (except a manned free balloon) that is being used for flight instruction unless that aircrafthas fully functioning dual controls. Section 91.119 prescribes that, except when necessary for takeoffor landing, no personmay operate an aircraft belowthe following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property onthe surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to persons or property on the surface- (1) A helicopter may be operated at less than the minimums prescribed inparagraph (b) or (c) ofthis section, provided each person operating the helicoptercomplies with any routes or altitudes specificallyprescribed for helicopters by the FAA; and (2) A poweredparachute or weight-shift-control aircraft maybe operated at less than the minimums prescribed in paragraph (c) ofthis section. Section 91.121 requires, inpertinentpart, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set available within 100 NM ofthe aircraft "

...to the elevation ofthedeparture airport or an appropriate altimeter setting available beforedeparture." Section 91.151(a) prescribes that no person may begin a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuelto fly to the first point ofintended landing and, assuming normal cruising speed, (1) duringthe day, to fly after that for at least 30 minutes [emphasis added]. Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraftunless it has within it (1) an appropriate and current airworthiness certificate; and (2) aneffective U.S. registration certificate issued to its owner or, for operation within the United States,the Addendum Page 5 of 10second copy ofthe Aircraftregistration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person may operate a civilaircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew. At a maximum gross weight of5.3 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meetthe intent of91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground control station and available for inspection upon request. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall havethat aircraft inspected as prescribed in subpart E ofthe same part and shall, betweenrequired inspections, except as provided in paragraph (c) ofthe same section, have discrepancies repaired as prescribed inpart 43 ofthe chapter. Section 91.407(a)(l) prohibits, in pertinent part, any person from operating an aircraft thathas undergone maintenance, preventive maintenance, rebuilding, or alteration unless it hasbeen approved for return to service by a person authorized under§ 43.7 ofthe samechapter. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate anaircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthischapter. Section 91.417(a) and (b) prescribes, in pertinentpart,that- (a) Each registered owner or operator shall keep the following records for theperiods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alterationand records ofthe 1 00-hour, annual, progressive, and other required orapproved inspections, as appropriate, for each aircraft (including the airframe) andeach engine, propeller, rotor, and appliance ofan aircraft. The records must include- (i) A description (orreference to data acceptable tothe Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approvingthe aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine,each Addendum Page 6 of 10propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe,engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified timebasis. (iv) The current inspection status ofthe aircraft, including thetime since the last inspection required by the inspection programunder which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD)and safety directives including, for each, the method ofcompliance, theAD or safety directive number and revision date. Ifthe AD orsafety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter foreach major alteration to the airframe and currently installed engines,rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periodsprescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year afterthe work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall beretained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operatorunder § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. Concluding, the Phantom 2 Vision+ aircraft (UA) will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's lightweight, being constructed primarilyofcarbon fiber and plastic, we propose that the UA will be at least as safe, ifnot safer, than a conventionally certificated aircraft performing the same missiOn. Ifan airworthiness certificate is not appropriate for this application, thenwe request an exemption of 14 CFRPart 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety. The UA is battery operated and the maximum duration offlight from a single battery charge is 25 minutes with a 20%reserve. Since the aircraft will never fly more than 3/4 NM from the Addendum Page 7 of 10point ofintended landing, a full battery charge at launch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". Itis our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." As provided in the Pre-FlightChecklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy conditionprior to every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. The UA maximum gross weight is 3.0 pounds and the PIC is not onboard. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site oflaunching and land without crewintervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above takeoffpoint is transmitted via radio from UA on-board computer to display screen held by the PIC, providing a constant updated AGL readout. We propose that the minimum medical requirements for the PIC and VO be vision correctedto 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle. UAS Operating Parameters The petitioner states that he will abide by the following additional operating conditionsunder this exemption: • operate his UAS below 300 feet and within a radius distance of 1000 feet fromthe controller to both aid in direct line ofsight visual observation; 1 • operate the UAS for 15 minutes perflight; • land his UAS prior to the manufacturer's recommended minimum level ofbattery power; • operate his UAS only within visual line ofsight (VLOS); • use the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands ifcommunication with the remote control pilot is lost; • conduct all operations under his ownpersonal and flight safety protocols(including posting a warning signreading: "Attention Aerial Photography in Progress- Remain Addendum Page 8 of 10

---------------------- --·- ------------Back 150 feet") contained in the operating documents and will actively analyze flight data and other sources ofinformation to constantly update and enhance his safety protocols; • contact respective airports ifoperations will be within 5 miles to advise them ofhis estimated flight time, flight duration, elevation offlight and otherpertinent information; • always obtain all necessary permissions prior to operation; and • have procedures in place to abort flights in the event ofsafety breaches orpotential danger.

Addendum Page 9 of 10APPENDIX A- FLIGHT MANUAL FLIGHT RESTRICTIONS

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace atno more than 400' AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be ableto communicate verbally at all times during a flight operation; (d) Operations will be restricted to flights overprivate property with the permission ofthe property owner; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot andat least ten hours logged as a UA pilot with a similar UA type; (f) All required permits will be obtained from state and local government priorto operation; (g) The CA V System will not be operated over densely populated areas; (h) The CAV System will not be operated at air shows; (i) The CA V System will not be operated over any open-air assembly ofpeople; 

### G) The CA V System will not be operated over heavily trafficked roads; (k) The CA V System will not be operated within 5 NM ofan airport orheliport; (1) The CAV System will not be operated over properties smaller than two acres insize; (m) Operations will be restricted to day only and weather conditions equivalent to VFR; (n) The PIC will briefthe VO and property owner about the operation and risk beforethe first flight at each newlocation; (o) No flight may be made without a successful Pre-Flight Inspectionby the PIC beforeeach operationto ascertain that the UA is in a condition safe for flight. PRE-FLIGHT CHECKLIST (1) Use voltmeter to determine that UA battery is fully charged in order to preventunexpected premature descent; (2) Check all wiring connections are tight; (3) Check all propellers are undamaged and no cracks exist in any structural members oftheUA; (5) Turn on radio controller, check for adequate voltage, set it to connect to the UA, move all control switches to forward or down position and throttle control stick full backposition; (6) Connect UA main battery, check for radio contact with UA's radio receiver; (7) At a location different from previous flight, re-set GPS and compass to currentlocation; (8) Tum ontransmitter, gimbal and camera. TO REGAIN CONTROL AFTER LOST RADIO CONTACT



### 1. 

### Failsafe = ON If radio contact is not restored, the UA 

### 2. Throttle 

## =50°/o will automatically continue at 60ft. 

### 3. Mode = 

### ATTl above its last elevation before losing 

### 4. Failsafe= OFF Mode= G contact toward its takeoff point, then descend and land there autonomously

Addendum Page 10 of 10