Walton Communication s

Walton Communications, LLC 

303 E. Gurley St. #404 

Prescott, AZ 86301 

August 17, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Summary 

Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012. An exemption granted 

would permit its operation of lightweight, unmanned, remotely controlled, UASs in a tightly controlled 

environment with limited airspace.

Contact Information 

The name and contact information of the applicant is: 

Walton Communications, LLC 

attn: Conrad Walton 

303 E. Gurley St. suite 404 

Prescott, AZ 86301 

Phone: 310-200-3455 

Email: section333@walton2.com 

Walton Communications is an Arizona LLC owned by Conrad Walton and Victoria Walton as partners. 

Walton Communications provides web sites, Internet marketing, consulting, videos and photography 

for advertising and media. 

The Extent Of Relief We Seek And The Reason We Seek The Relief 

We request approval to operate unmanned aircraft systems (UAS) commercially for aerial data 

collection, including data capture, photography, videography, and inspections. 

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455
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How Our Request Would Benefit The Public As A Whole 

The proposed services are offered with the intent of enhancing the development and safe operation 

of unmanned aircraft systems, realizing that current manned aircraft operations pose a much greater 

risk of personal injury and or death and extensive property damage. 

The use of UAS would fulfill a service to consumers and small entities that would otherwise not exist 

due to the risks and costs involved with manned aircraft. 

The Specific Sections Of 14 CFR From Which We Seek An Exemption 

Petitioner seeks an exemption from the following rules: 

14 C.F.R 21(h); 

14 CFR 61.23(a) and (c) 

14 CFR 61.101(e)(4) and (5) 

14 CFR 61.113(a) 

14 CFR 61.315(a) 

14 CFR 91.7(a) 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151(a)(1) 

14 CFR 91.405(a) 

14 CFR 91.407(a)(1) 

14 CFR 91.409(a)(1) and (2) 

14 CFR 91.417(a) and (b) 

How The Exemption Will Provide A Level Of Safety At Least Equal To The Existing Rule 

14 CFR part 21, Certification Procedures For Products And Parts, Subpart H—Airworthiness 

Certificates 

The UASs will include multiple DJI Phantom 2s and 3D Robotics Solos. The DJI Phantom 2 

exemption is similar in all material respects to relief previously requested in Grant of Exemption Nos. 

11062, 11109, 11112, and 11213. The 3D Robotics Solo was not released at the time of the previous 

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455
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approved exemptions available at the date of this request, so no other exemptions can be cited as 

similar in all material respects as this is written. 

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in reference to 

49 U.S.C. 44704, and in consideration of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, please determine that these aircraft meets the 

conditions of Section 333. 

14 C.F.R. 61.113 {a) {b): Private Pilot Privileges and Limitations: Pilot in Command 

61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring a ground crew member to have a private 

pilot's license rather than a commercial pilot's license to operate this UAS. 

Unlike a conventional aircraft that carries the pilot and passengers, the stasis remotely controlled 

with no persons on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance. 

The risks associated with the operation of the UAS are so diminished from the level of risk associated 

with commercial operations contemplated by Part 64 when drafted, that allowing operations as 

requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 

CFR .113 (a) & (b). 

14 C.F.R. 91.7 {a); Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, 

no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance and use 

of safety check lists prior to each flight, a subset of which are provided in enclosed Supplemental 

material, an equivalent level of safety will be provided. 

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455
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14C.F.R. 91.9 (b) (2). Civil Aircraft Flight Manual in the Aircraft. 

91.9 (b) {2) provides: No person may operate a US registered civil aircraft... {2) For which an Airplane 

or Rotorcraft Flight Manual is not required by 21.5 of this chapter, unless there is available in the 

aircraft current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof. 

The UAS, given its size and configuration has no ability to carry a physical flight manual on the 

aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Numbers 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 32827, and 10700. 

14C.F.R. 91.103: Preflight Action 

91.103 requires each PIC to take certain actions before flight to insure the safety of flight. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions including reviewing weather flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight. Further, we have 

proprietary manuals created with the help of UAS experts, the manufacturer, the regional UAS vendor 

and policy holding insurer and continue to work with these organizations to ensure best safe 

practices are adhered to. 

14 CFR. 91.109: Flight Instruction 

91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls, 

UASs and remotely piloted aircraft, by their design do not have fully functional dual controls, Flight 

control is accomplished through the use of a 4 control box that communicates with the aircraft via 

radio communications. The FAA has approved exemptions for flight training without fully functional 

dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos. 5778K & 9862A. 

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455
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The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried 

in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology 

inherent in the remote controls utilizing digital communications which is paired to the UAS making it 

nearly impossible to unintentionally or intentionally have the control communications interrupted. 

14C.F.R. 91.119; Minimum Safe Altitudes

91.119 establishes safe altitudes for operation of civil aircraft. 91.119 {d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter 

complies with any route or altitudes prescribed for helicopters by the FAA. 

As this exemption is for a UAS that closely mimics the behavior of a helicopter, and the exemption 

requests authority to operate at altitudes up to 400 AGL, an exemption maybe needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided 

visual line of sight, whichever is closer, it will however be operated in a restricted area with security 

officials tasked with ensuring public safety, and where buildings and people will not be exposed to 

operations without their pre-obtained consent and training. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight operation will be taken without the permission of the property 

owner in the case of private property or local officials in the case of public property or private 

property with public interests. 

Because of the advance notice to the property owner and participants in the remote sensing activity, 

all affected individuals will be aware of the planned flight operations. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 11kg 

of Walton Communications, LLC's UASs proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL. 

In addition, the low altitude operations of the UAS will ensure separation between these small UAS 

operations and the operations of conventional aircraft that must comply with 91.119. 

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455
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14C.F.R. 91.121 Altimeter Settings 

91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set to the elevation of the departure airport or an appropriate altimeter setting 

available before departure. 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption 

may be needed. 

An equivalent level of safety will be achieved by the operator, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight. The PIC and VO will also ensure effective 

pairing with multiple GPS sources to guarantee accurate detection of height. 

14 C.F.R. 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

91.151 (a) prohibits an individual from beginning a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes. 

The battery powering the UAS provides approximately 20 minutes of powered flight. The UAS will not 

be able to meet the 30 minute reserve requirement in 14 CFR 91.151. 

Operating the small UAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

power, does not engender the type of risks that Section 91.151a) was intended to alleviate given the 

size and speed of the small UAS. 

An equivalent level of safety can be achieved by limiting flights to 20 minutes or 75% of battery 

power whichever happens first. This restriction would be more than adequate to return the UAS to its 

planned landing zone from anywhere in its limited operating area. Similar exemptions have been 

granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455
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14 C.F.R. 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

91.203 provides in pertinent part: (a) Except as provided in 91.715, no person may operate a civil 

aircraft unless it has within it the following: (1) An appropriate and current air worthiness certificate. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 10lbs and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565,9665, 9789, 9789A, 9797, 9797A, 9816A, 

and 10700. 

14 C.F.R. 91.405 (a); 407 (a) (1): 409 (a) (2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant 

to the flight manual. 

An equivalent level of safety will be achieved because these small UASs are very limited in size and 

will carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed.

Walton Communications, LLC 303 E. Gurley St. #404 Prescott, AZ 86301 310-200-3455