11/16/2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12 Washington, DC 20590

RE: Petition of Thorn Aerial Imaging for

ope rate Unmanned Aircraft Systems p

Act.

Petitioner:

Chandler Thorn Thorn Aerial Imaging

299 San Leon Irvine, CA 92606 Tel: (707) 333-5625

Email: info@thornaerialimaging.com Email: chandlerthorn2@gmail.com

Website: ThornAerialImaging.com

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Mode Thorn Aerial Imaging hereby petitions the Federal Avia C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121,

91.151 (a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1 FAA deems necessary, to enable Thorn Aerial Imaging (sUAS) for aer ial data collection and imaging 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 described in more detail below, the requested exemption would per sUAS under controlled, limited, and predetermined conditions in the National Airspace System (NAS). Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's responsibilities to establish re quirements for the safe operations of such aircraft systems in the NAS. West Building Ground Floor, Room W12 -140

RE: Petition of Thorn Aerial Imaging for exemption from certain Federal Aviation regulations rate Unmanned Aircraft Systems p ursuant to Section 333 of the FAA Modernization and Reform

info@thornaerialimaging.com

333 of the FAA Mode rnization and Reform Act (FMRA ) and 14 C.F.R. part 11, hereby petitions the Federal Avia tion Administration (FAA ) for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, (a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1 ) and (2), and 91.417(a) and (b), and any other rules the

Thorn Aerial Imaging to operate Small Unmanned Aircraft S ial data collection and imaging 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 described in more detail below, the requested exemption would per mit the operation of sUAS under controlled, limited, and predetermined conditions in the National Airspace System (NAS). Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's

quirements for the safe operations of such aircraft systems in the NAS. exemption from certain Federal Aviation regulations to

ursuant to Section 333 of the FAA Modernization and Reform

) and 14 C.F.R. part 11, ) for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, and (b), and any other rules the

Aircraft S ystems ial data collection and imaging 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.

mit the operation of sUAS under controlled, limited, and predetermined conditions in the National Airspace System (NAS). Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's

quirements for the safe operations of such aircraft systems in the NAS.1) Specific Sections from which Exemptions are Sought:

a) 14 CFR Part 21, subpart H b) 14 CFR 45.23(b) c) 14 CFR 61.113(a) and (b) d) 14 CFR Part 91: i) 91.7(a) ii) 91.9(b)(2) iii) 91.103 iv) 91.109 v) 91.119(c) vi) 91.121 vii) 91.151(a) viii) 91.203 (a) and (b) ix) 91.405 (a) x) 91.407 (a) (1) xi) 91.409 (a)(1) and (2) xii) 91.417(a) and (b)

2) Relief Sought for Proposed Operations:

a) Thorn Aerial Imaging wishes to operate small Unmanned Aircraft Systems (sUAS) for private and commercial purposes provided such operations are conducted within and under the conditions outlined by the FAA as required by Section 333. Use of sUAS make and models include but are not limited to DJI Phantom series, DJI Inspire series, DJI Spreading wings series, and Freefly Systems Alta series. Proposed areas for professional private and commercial services are to include but not limited to the following areas:

i) Aerial video and/or photography for public and/or private use including television, public events, cinematography, and commercials. ii) Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. iii) Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation. iv) Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, and mapping mining, agriculture, topography, inspections, and natural resources management. v) Aerial photography and/or video for public and/or private events such as wedding venues, golf courses, hotels, and resorts.

3) Public Benefit:

a) Current methods of obtaining imagery, information, and data put human life in danger with such methods as helicopters which carry combustible fuel and other various dangerous activities such as scaffolding or rigging accidents. The use of sUAS in a controlled and predetermined operation alleviates the risk to human and property safety and wellness. Using sUAS also benefits the public because the sUAS reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft. Lastly, the economy will benefit from controlledoperations of sUAS because the cost of obtaining this data will be far less expensive than current

methods.

4) Safety Not Adversely Affected:

a) Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. b) Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by the sUAS manufacturer, and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. c) The Pilot in Command (PIC) must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. d) sUAS will weigh less than 55 pounds. e) Flights will be operated within visual line of sigh (VLOS) of the pilot (operator) and/or designated observer (spotter). f) Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 15% batter power reserve should that occur before the maximum 30 minutes. g) Flights will be operated at an altitude of no more than 400 feet above ground level (AGL). h) Aircraft speed will not exceed 65 mph. i) Flight operations will take place during daylight hours (hours of civil dawn and civil twilight). j) sUAS aircraft will only be flown inside Class G (uncontrolled) airspace and stay more than five miles from any airport or other location with aviation activities. k) The sUAS pilot/operator will be Pilot in Command (PIC). If the PIC determines another pilot/operator to be qualified with the necessary skills to be the PIC, that person can also be designated as the PIC provided they have a minimum of 10 hours of flight time with that specific sUAS model including at 5 takeoffs and landings. l) All flight operations will have a PIC along with an observer/spotter and sensor operator as

necessary. m) A briefing will be conducted in regard to the planned sUAS operations prior to each flight operation. It is mandatory that all personnel involved with the operational duties of the flight be present for this meeting. n) The PIC and observer/spotter will, at all times, maintain verbal communication by voice or radio. o) Written and/or oral permission from the relevant property holders or property representatives

will be obtained. p) If the sUAS loses communications or loses its GPS signal, the sUAS will have the capability toreturn to a pre-determined location and land autonomously or hover in the air waiting to reobtain signal. q) All flight operations will comply with the sUAS's manufacturer manual. r) All flight operations will comply with any applicable local FSDO requirements. s) All flight operations will be conducted in accordance with valid Certificates of Authorization. t) Any incidents will be reported within 24 hours of occurrence. u) Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined and tested lost link procedures.v) Preflight and standard operating procedures for flight operation are listed in section 5 found

below.

5) sUAS Checklist and Standard Operating Procedures:

a) Preflight: i) Weather and wind limits checked to be within tolerance (do not attempt to fly in winds exceeding 20mph) ii) Check surrounding area for civilians, animals, objects, and proximity to airports and other illegal flight areas iii) Confirm operating controller battery and sUAS battery are fully charged and secure iv) Thoroughly inspect each propeller for imperfections such as cracks or bends and install to aircraft if necessary v) Install and secure SD card vi) Remove camera lens cap and gimbal clamp vii) Place sUAS on level surface away from nearby civilians and objects, into the wind and facing away from the operator

b) Power-Up: i) Power on transmitter and confirm full battery charge ii) Power on sUAS and confirm full battery charge iii) Open sUAS operating software through display and confirm successful connection to aircraft iv) Perform compass calibration if necessary as per operating manual

c) Before Takeoff: i) Confirm satellite lock and return-to-home point is updated ii) Inspect all aircraft readings and data to ensure that the aircraft is operating at full capacity iii) Test all not-flight related hardware functionality such as camera and gimbal operations iv) Point aircraft away from operator v) Secure takeoff area and make sure there is nothing in a close proximity to the sUAS vi) Observers, authorized personal and crew warned of sUAS launch vii) Start sUAS propellers and allow to warm up while closely monitoring monitor readings

d) Takeoff: i) Ascend the aircraft to a safe, predetermined height and initiate hover ii) Confirm GPS position hold and First Person View (FPV) live feed is working properly iii) Take note of weather conditions, battery levels, and time taken for safe takeoff.

e) Mission:

i) Confirm predetermined point at which mission will be terminated due to battery level (15%) (1) Weather such as wind may greatly affect return time, allow extra time to return to home point ii) Maintain radio connection and visual line of sight (VLOS) with aircraft iii) Utilize a trusted spotter who has been briefed on standard operating procedures to

maintain visual contact when available iv) Verify recording status at all timesf) Recovery:

i) Position aircraft over return to home position and confirm landing area is clear of objects

and civilians ii) Decrease altitude and hover at a safe altitude roughly 20 feet above the ground iii) Visually inspect landing area again for object or civilians iv) Lower aircraft slowly until landing gear is securely on a level surface (if level surface is not readily available recovery by hand may be authorized for safety) (1) If recovery by hand is used, once the catcher has securely confirmed a firm and safe grasp on the aircrafts landing gear (or predetermined safe secure point) power to the propellers may be terminated and no one may move until all propellers have safely powered down and stopped moving. v) Once aircraft is on the ground power to the propellers may be terminated. No one may approach the aircraft until all motors have powered down and propellers have stopped moving.

g) Post Flight:

i) Approach aircraft and power down primary battery ii) Power down transmitter and any other operating controllers or systems iii) Clean, inspect for any damages, and secure aircraft prior to storage or transport iv) Properly store aircraft, batteries, and transmitters in conditions outlined in the user's

manual v) Prepare aircraft for next flight or storage

6) Manuals

a) DJI Phantom 3 Professional: http://www.dji.com/product/phantom-3/download?gclid=CKOW5eHRkMkCFZKBaQodHWwNVg

b) DJI Inspire 1: https://www.dji.com/product/inspire-1/download

c) DJI Spreading Wings S1000: https://www.dji.com/product/spreading-wings-s1000/download

d) Freefly Alta: http://freeflysystems.com/software-manuals

Please advise us of any additional information or changes that may be required.

Sincerely,

Chandler Thorn Owner, Thorn Aerial Imaging