June 14, 2015 DocketOperation, M-30 1200NewJersey Avenue, SE Room W12-140 WestBuildingGround Floor Washington, DC 20590-0001 

## QUAD PICTURES Aerial Phorogranhll And Vidoogranhll

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. §21, subpart H; 14 C.F.R. 42.23(b); 14 C.F.R. §§61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);(91.203(a) and (b); 91.405 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) and (b) to operate commercially for purposes in Real Estate. PERSONALINFORMATION Name VINCENTANTONIO PIATEK Company QUADPICTURES ADDRESS 1911 SWCAMPUS DR#392 FederalWay, Washington98023 253-335-2531 vincentapiatek@gmail.com
Dear Sir orMadam, My name is VincentPiatek, anowner and operator ofsmall unmanned aircraft systems and I am submitting request for exemption of Section 333 of the FAA Modernization and Reform Act of2012 and 14 C.F.R. Part lloftheFederal AviationRegulations. BACHGROUND I work is the Real Estate industry and specialize in photography and videography in Real Estate. When a realtor in the greater Seattle area is looking to list a piece ofproperty they want to showcase the best angles ofthe property, it is ofsignificant benefit to use an UAS for aerial photography and videography to help the listing be veryunique, Givingthe buyer a greater picture ofthe quality and build ofthehouse/property.REGARDINGTHEUNMANNED AIRCRAFT SYSTEM The UAS I will be using is a small quadcopter weighing less than 55 pounds with any and all payload. These UAS's operate at a speed no greater than 30 knots and can and can climb to an altitude to higherthen400ftAGL. It operates only inthe line ofmy sight as the sole operator and within a radius of300ft. These flight restrictions ensure that it is not a hazard to the aerospace in which it will operate. This UAS fall within the safety zone that the FAA will, with an exemption in place, allow commercial operations ofa UAS. The UAS I will be flying is a DJI PHANTOM 3 ADVANCED. The specific specifications are found below. WEIGHT (INCLUDING BATTERYAND PROPELLERS)
DIAGONAL SIZE (INCLUDING PROPELLERS) 590mm MAXASCENT SPEED

rri/s MAX DESCENT SPEED
HOVERACCURACY 

### Aircraft +/- 0.] fTI Vision ls 0( +/- rn +/- 1 MAX SPEED
MAXALT!TUDE ABOVE SEA LEVEL
OPERATING TEMPERATURE to 1\.0"C GPS MODE GPS/GlONASS 

### Camera SENSOR VI LENS
ISO RANGE

00<3200

### Gimbal
Vision Positioning SHUTTER SPEED**~1** IMAGE MAX SIZE 4000 STILL PHOTOGRAPHY MODES Shot * Burst
at 0.7EV Bias
VIDEO RECORDING MODES 

### Phantom 3Advanced

0 FttD: 1
q HD: ·1 SUPPORTED SD CARD TYPES
Max 64**:oorUHS~!** MAX BITRATE OF VIDEO STORAGE 

### Phantom 

### 3 Advanced M SUPPORTED FILE FORMATS

0 FAT32/cxFAT

OPERATING TEMPERATURE Or.'C to**i~Oec** CONTROLLABLE RANGE
STABILIZATION roll, MAXVELOCITY 8 rn/s 2 rnALTITUDE RANGE crn"300 ern OPERATING RANGE cnl-300 cn1 OPERATING ENViRONMENT Surface witn OPERATING
MAX DiSTANCE 200001 VIDEO OUTPUT PORT
OPERATING TEMPERATURE
BATTERY 

### Remote Controller Goco (nAh



### Battery Charger
Intelligent Flight Battery MOBILE DEVICE HOLDER Fm RECEIVER SENSITIVITY (1°/oPER)
TRANSMITTER POWER (EIRP) dBm

WORKING VOLTAGE
VOLTAGE
RATED POWER 

### Phantom 3Advanced

CAPACITY 1nJ\h VOLTAGE

5.2

## vBATTERYTYPE
ENERGY 68\Nh NETWEIGHT
MAX FLIGHT TIME rr1inutes OPERATING TEMPERATURE
MAXCHARGING POWER

PROCEDURESFORFLIGHT

I will always follow procedures outline in the UAS operator's manual as to proper pref1ight inspection ofall hardware, software, environmental and any other factors needed to ensure a safe flight.
o Ifrequired, notify the appropriate FAA facility ofour launch schedule and location. o Checkweatherfor wind speed, cloud cover and any forecast change during flight. o Flowing takeoffI will hover 10 feet and assure the Home Point is solid and have Signals withthe GPS. o Iwill not fly over dense traffic or crowds o Iwill give right-of-way to any manned aircraft. o I will stay clear of FAA controlled airspace at airports as well as restricted and prohibited zones. o Examine the aircraft, Test batteries in remote control, and in the UAS. The only acceptable battle level before takeoffis 90% and the UAS with be grounded before battery reaches 25% o Permission from property ownerbefore flight. o With an Observer, make a walk around the area that is going to photographed or filmed. We will take note ofany trees, light poles, power lines, and or any other obstacles before takeoff o Go over flight path, speed, distances, and altitude. o The operator will make sure the site is secure and a perimeter of25 feet offlight path ofUAS. FCC INFORMATION The UAS being deployed here is DJI PHANTOM 3 ADVANCED. The control link operates on a frequency of 2.4. The range is 2000m (outdoors and unobstructed) The receiver sensitivity is 101 dbm.QUALIFICATION OFUAS PIC The PIC will have over 100 hours offlight time withUAS. The PIC has been flying UAS for over 3years starting with the DJI PHANTOM 1and then the PHANTOM 2+ and now operates the DJI PHANTOM 3 ADVANCED. Because the UAS will not carry passengers and will fly within a restricted area, it will exceed the safety standards set forth in 14 C.F.R. 61.113 (a) and (b). At all times there will be an observer who will also monitor the UAS, surrounding buildings or obstacles and will be the second set ofeyes during flight of the UAS. OPERATIONS OFUNMANNED AIRCRAFT The UAS will be a tool for photography and video graphing real estate in the greater Seattle area. Clients will be able to view aerial pictures and videos of property before purchase. This will give them abetter understating oflayout ofproperty. The flight ofthe UAS will not pose any safety threat to public. Flight will only be during the daytime. Batteries level will notbe lowerthan 90% for takeoff There will always be an observer for a second eye on the UAS during flight. A full pre-flight checklist and f1ight plan afterpermission is grantedform property owner. The UAS will not operate ifclouds are below 800ft AGL. This UAS does not f1y over 29.1577 knots and speed will notreach over 10 knots (11.507MPH). This will ensure great control oftheUAS. The intended area ofoperation will be in rural settings, as well as neighborhood. Potential hazards are power lines, trees, structure, streetlights. Low flight speed ofthe UAS when in operation for videography and photography for intended purpose, the PIC and observer will be able to safely maneuver the UAS around the hazards. The UAS also had capabilitiesto hover is place and fight the wind because ofGPS location. The UAS will NEVERbe flown nearthe airports so as to pose any sort ofsafety concerns to pilots in the area. UAS Will never be t1own within 5 miles radius of any large international airport and 0.6 miles ofa smaller regional airport. Ifthe UAS is in flight and tires to fly into a no fly zone, the UAS will stop and return home. Ifrequired by the FAA, I will notify the FSDO ofmy flight operations priorto flight. 14 C.F.R. Part21, SubpartH, 91.203(a) & (b) Airworthiness Certificate Because the UAS in under 55lbs, fully loaded, and does not carry pilot, passenger, any explosive material or flammable fuel, operates in a fully restricted and controlled environment, I request exemptionfrom 91.203 partA & B. 14 C.F.R. 45.23 BMarkingTheAircraft The UAS will not have an airworthiness certificate and because there is no entrance to the cabin, cockpit, or pilot station, there is no place inside the aircraft to place the word "Experimental" on the exterior ofthe UAS. However, due to size 2 inch lettering will not be possible.14 C.F.R. 61.113 A & BPrivatePilotPrivilegesAndLimitations: Pilotin Command Unlike civil aircraft, the UAS doesn't carry living things on board; rather, it is controlled remotely via a safe and restricted location. The risk during operation are so minuscule the PIC will exceed the present level of safety required for a commercial pilot to operate a rotorcraft. 14 C.F.R. 91.9 B(2): CivilAircraftFlightManualInTheAircraft Because the UAS has not cockpit or storage space on board the flight manual will be carriedbythe PIC and observer at all time when operatingthe UAS. 14 C.F.R. 91.103 B(2): PreflightAction An extensive pre-flight inspection will take place before every flight. See Page 5 (Procedures for Flight) for pre-flight checklist. 14 C.F.R. 91.105: FlightCrewmembers atStation Because there are no human life aboard the UAS, regulation 91.105 should be exempt for my purpose ofusing my UAS. But the PIC and observer will be on the ground and have visual ofUAS at all time. 14 C.F.R. 91.109: FlightInstruction The UAS does not have dual controls. The PIC communicates to the UAS via radio Control Box. The FAA had approved exemption for flight training without fully functional dual controls for a number ofaircraft. 14 C.F.R. 91.119: Minimum Safe Altitudes The UAS will neverreach a flight altitude greater than400ftAGL. Itwill always be flown withpermissionand consent ofproperty owner. 14 C.F.R. 91.121: AltimeterSettings The UAS doesn't use an altimeter. Ithas GPS (connects to 15 satellites) to determine the altitude. Will need and exemption since normal protocol is to set the altimeter to the barometric pressure reading at the time offlight. Before takeoffofthe UAS, I will ensure that GPS altitude is working correctly. 14 C.F.R. 91.151: FuelRequirements ForFlightinVFRCondition The battery life oftheDJI PHANTOM 3ADVANCED is capable of23 minutes (withmild temperature conditions) offlight and will not take flight with battery life lower than 90%. The UAS will not fly higher than 400ft AGL and 300ft away, at the furthest feet away the UAS will take no longer than 2 minutes to reach the ground. Battery life at 25% will be about 5mins offlighttime, plenty oftimeto safely gethome and land. Battery life and time remaining offlight is displayed on the 1 0" screen visible to the PIC and observer at alltime. When battery life reaches 25% the UAS will automatically return home and land from place oftakeoff 14 C.F.R. 91.203 A & B: Carrying Civil Aircraft Certification AndRegistration The UAS does not have any storage on board to carry such documents. UAS weight under 55lbs and doesn't have an onboard pilot operating it. Ifrequired by the FAA, they will be carried at all time by the PIC. 14 C.F.R. 91.405 A; 407 A(l); 409 A(2); 417 A & B: Maintenance Inspection This regulation applies to aircraft that have an airworthiness certificate and should not apply to the operation ofmy intended use for the UAS. Before each flight, maintenance of the UAS such as cleaning ofmotors, light, inspection ofprops and body for damage will take place. Each flight is logged onthe software and also hand written. Ifrequired by FAA logbook and software will be surrendered uponrequest. SUMMARY I Vincent Piatek feel my operation of my UAS will meet/exceed all current safety standards and regulations set by the FAA. I am seeking exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R. 45.23(b);14 C.F.R. §§ 61.113(a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.105; 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b);91.405 (a); 91.407 (a) (1); 91.409(a) (2); and 91.417(a) & (b) to operate commercially for purpose in real estate I respectfully request exemption for the above listed regulations in order to conducted aerial videography andphotography for Real Estate. Please contactme at any time for any further information. Thankyoufor yourtime.

# Sillc~£ VincentPiatek

# ~ QuadPictures