U.S. Department of Transportation August 10, 2015

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modern ization and Reform Act of 2012 (the “Reform Act”) and 14

C.F.R. Part 11

, James Powers , seeks an exemption from Federal Aviation Regulatio ns (“FARs”) detailed
below for (1) DJI Inspire 1 q uadcopter manufactured by DJI Innovations.

The requested exemption would support a n application for a commercial Certificate of Authorization to use the system to support aerial photography and videography. The DJI Inspire 1 (6.5lb) consist of a battery operated aircraft, a tablet

- based ground control station and/ a RC Controller, and associated

communicat ions equipment. The aircraft carries an onboard geo

- referenced gimbaled c amera that
allows it to obtain photography and videography.

The Unmanned Aircraft System will be opera ted in the field with a PIC in accordance with FAA Policy N

89 00.227 Section 14 "Operational Requirements for UAS".

James Powers respectfully requests the grant of exemption allowing to operate lightweight, remote controlled UAS's lawfully and safely.

James Powers also respectfully requ ests Exemption Request Section 333 from (but not limited to) the Specific Sect ions of Title 14 of the Code of Federal Regulations and part ll of the Federa l Aviation. Regulations listed below.

14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121~ 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)

The extent of relief James Powers seeks and the reason why:

James Powers is seeking relief from an y applicable FARs operating to prevent James Powers from conducting a erial photography of real estate and other possible legal flight operations including

cin ematography, videography, mapping, surveying, inspections and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S.

nati onal airspace system as compared to manned aircraft . T he weight of the UAS meets the definition of
''small unmanned aircraft” fo und in section 331 "The Reform Act”. James Powers seeks to operate
le gally as a small business that cater mostly to real estate agents. Realtors are not allowed to use UA S's

or hire unless they or the person they hire, is allowed by the FAA to fly a UAS.

James Powers would satisfy the need for safe and affordable aerial shots.At less than 7 pounds, James Powers uses UAS that is considerably less than 55 po unds including the

camera tha t is attached. The UAS will be used at speeds under 35 mph because of the nature of the
business and the limited physical capabilities of the UAS. It is designed to hover and take pictures. The
UAS will be in accordance with flying well below 400ft.

The UAS in which James Powers would be using only utilizes battery power for its operations. There are

no com bustible fuels used in the UAS that James Powers uses. The maximum flight time for our particular UAS is 2 0 minutes battery life. It will fly n o more than 15 minutes maximum at one time at
one location. The amount of ti me the UAS will be in the air, less than 400ft, is very minimal.

A Safety system in place for James Powers UAS includes a GPS mode tha t allows the UAS to return home
if commu nication is lost. Further, the GPS onboard allows the UAS to return back t o its launched position if the battery life of the UAS is low.

THE GROUND STATION PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational cont rol of a flight operation from beginning to end and who
controls the UAS w hile in the air. Additionally, the line of site of the UAS will not leave the sight of the

PIC.

A 2.4GHz radio transmitter/controller oper ated by the PIC to control the U.AS while in flight; A radio receiver receiving live video, and flight data from the on

- board camera and computer. It projects it all in
one screen to the Pilot in Command

.

The UAS, weighing less than 7lbs fully loade d, is powered by batteries and operat es with no people on
board which low ers the likelihood of death or serious bodily injury. With a small payload consisting of
harmless electronics such as a camera and GPS, the UASs only purpose is to be used as a tool to take pictures and videos.

Low le vel aerial photos and video fr om several angles are far more effective than ground based photos.
Low l evel aerial video a nd pictures show the layout of properties with the a dvantage of seeing more in

one photo or short video.

Current applicants have use d helicopters and small planes for this purpose b ut the cost of fuel, time, and
emissions of such aircraft is not efficient enough for most customers to afford.

The benefits of reduced cost and improve d efficiency of the UAS allows future customers to a fford this
service with a faster turnaround time at a lesser cost.

Additionally, I respectfully request that JAMES POWERS be allowed to use the UAS to benefit possible
first responders our local area for actions that could benefit the public. Such as, fires and search and

rescue.

James Powers will not operate a UAS ne ar airports and generally does not fly over crowds. Situational

awarenes s is most important. The areas where James Powers conducts aeria l photography is predetermined whi ch allows for a controlled environment to operate safely.With allowing James Powers to conduc t business with a light weight UAS, it could very well help the

econo my and benefit people in first response situations. Further, James Powers UAS i s considerably lighter than the alternative which is a helicopter or small plane. Currently, James Powers has 1 UAS which only operates of f 20 minutes of battery power. Therefore, the UAS used by James Powers would only have a flight time of 5

- 15 minutes at one time. The likelihoo d of injury or even death with such a small unmanned aircraft, compared to an air craft flown by a person loaded with combustible fuel, is considerably low

.

SUMMARY:

James Po wers is more than willing to fol lo w the safety guidelines of the FAA Policy N 8900.227 Section 14 "Oper ational Requirements for UAS'1 with the appropriate exemptions for flying a small UAS. A preflight chec klist will be developed and employed to en sure that the UA airworthiness will be verified
before launch. Airworthiness will b e maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components.

A

- No flight will be made with a UA Gross weight exceeding 55lbs

B

- All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of not
more than 25 knots and no further than 3/4 NM from the Pilot In Charge while always maintaining a Visual Line of Sight ( VLOS ).

C

- Operations will be restricted to flights over private property with the permission of the property

owner

D

- All required permits will be obtained f rom state and local government prior to operation

E

- The UAS will not be operated over densely populated areas

F

- The UAS will not be operated at air shows

G

- The UAS will not be operated over any open

- air assembl y of people

H

- The UAS will not be operated over heavily trafficked roads

I

- The UAS w ill not be operated within 5 NM of an airport or heliport The petitioner request that he be allowed to operate within 5 miles of an airport provided that; “The UA may not operate in Class B, C, or D air space without written approval from the FAA. The UA may not operate wit hin 5 na utical miles of the geographic center of a non

- towered airport as deno ted on a current FAA published aeronautical chart unless a letter of agreement wit h 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 agreement with the airport management must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not ant icipated to be routine but the petitioner is re questing
a mechanism to facilitate such a ctivities without requesting a new and separate exemption(s) should the
need ar ise. Operations within class B airspace are not requested due to the lack of mode C transponder.J

- Operations will be restricted to d ay only and weather conditions equivalent to VFR

K

- The PIC will notify prope rty owner about the operation and risk before the first flight at each new location;

L

- No flight may be made without a Pre

- Fligh t Inspection by the PIC before each operation to ascertain
that the UAS is in a condition safe for flight

.

The petitioner is requesting this exe mpti on for the purposes of “aerial photography, cinematography, videography, mapping, crop surveying, inspections and other flight operations”. The reason for such a general and broad based request is that the petitioner wishes to utilize a business str ategy of horizontal integration and maximize economies of scope in order to capitalize on o pportunities as they may arise in the future without the long turnaround time associated with additional exemptions

.

My operations above are the bare minimum s afety guidelines James Powers will follow. James Powers is
also m ore than willing to follow any additional safety requirements if not listed above.

James Powers believes flying its UAS as a smal l business w ithin the safety parameters of the FAA, can help people and promote the economy.

The name and contact information of the applicant is:

James Powers

1825 NW 12 th ST Boca Raton, FL 33486
Phone: 954

- 868

- 4662
Email: jamespowers04@gmail.com

James Powers respectfully requests th at the FAA grant its exemption request without delay. I very much look for ward working together with you

. Thank you for your time.

Respectfully,

James Powers

954

- 868

- 4662