TO: U.S. Dept. of Transportation, Docket Operations 25 June 2015 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

FROM: Robert Crum 

U.S. Army (Retired) 

608 South 5 ~' Street 

Manhattan, Kansas 66502 

Phone 785-320-6503 

Emailinfo@patmanhat.com 

Subject: Request for Exemption's to operate Small Unmanned Aircraft Systems (UAS) for Aerial 

photography and/or video for real estate, architecture, land surveying, engineering and other related 

professional activities; aerial video and/or photography for television, public events, cinematography and 

newsgatl ering; aerial inspection/photography of residential/eommercial structures; 

residential/commercial utility infrastructure; aerial video/photography to assist with search and reseue 

operations; and training for UAS operations. 

PETITION SUMMARY 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

C.F.R. Part 11, Robert Crum an operator of Unmanned Aircraft Systems ("UAS(s)") for aerial 

photography and videography for Aerial photography and/or video for real estate, architecture, land 

surveying, engineering and other related professional activities; aerial video and/or photography for 

television, public events, cinematography and newsgathering; aerial inspection/photography of 

residential/commercial structures; residential/commercial utility infrastructure; aerial video/photography 

to assist with search and rescue operations; and training for UAS operations hereby petitions for an 

exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS(s). 

Exemptions Requested From; 14 CFR 61.113(a) and (b);91.7(a); 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)( 1); 91.409 (a)( 1) and (2); 91.417(a) and (b). 

Proposed Operations 

AIl UAS flights will occur over private or controlled access areas with the property owner's prior 

consent and knowledge. Robert Crum proposes to avoid flight over populated areas and operations over 

people who have not provided consent. Robert Crum's UAS Aerial photography and videography will be 

focused on Real Estate Marketing, Construction Site Inspections and Special Events. Satisfying the 

criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, 

proximity to airports and populated areas and operation within visual line of sight provide adequate 

justification to grant Robert Crum's requested exemptions, thereby allowing Robert Crum's UAS 

commercial operations for the Real Estate Marketing, Construction Site Inspection and Special Events. 

Prior to conducting operations, under this grant of exemption, Robert Crum will obtain a Certificate of 

Waiver or Authorization, (COA) from the Air Traffic Organization., (ATO). Commensurate with the 

COA Robert Crum will request Notice to Airman, (NOTAM) based upon the limits and time lines of the 
UAS flight operations. Robert Crum's requested exemption would permit the operation of small, 

unmanned UAS under controlled and "sterile" conditions defined as private properties and controlled 

access locations. 

As established by the exemptions previously granted by the FAA, approval of Robert Crum's exemption 

would enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national 

airspace system." Section 333 (c) of the Reform Act. UAS(s) operated by Robert Crum weigh less than 

55 pounds, including the payload (IE. camera, lens, and gimbals). They operate at speeds of no more than 

50 knots, can hover, and can simultaneously move vertically and horizontally. Robert Crum, UAS(s) 

will only be Pilot in Command (PIC), with supplemental Visual Observer, (VO), and maintaining visual 

line of sight and will operate only within the sterile environment described in the SOP. Such operations 

will insure that the UAS will "not create a hazard to users of the National Airspace System, (NAS) or the 

public." Given the small size of Robert Crum's UAS(s) and the restricted sterile environment within 

which they will operate, the UAS(s) operations adhere to the Reform Act's safety requirements while 

avoiding additional national security issues. 

Aircraft and Equivalent Level of Safety 

The operating limitations proposed by Robert Crum provide for at least an equivalent or higher level of 

safety than presently exist with conventional aircraft providing aerial photography and video graphic 

services. Robert Crum's UAS(s) are comprised of 1- Blade 350 QX3 AP, 1- DJI Inspire 1 Dual Controls, 

and 1- Yuneec Q500 Typhoon as set forth in the Flight Operations and Procedures Manual, (SOP). 

The SOP is of a proprietary nature containing procedures and information not available to the public. 

Robert Crum has not and will not share this information with others. 

(See 14CFR, 11.35(b)) 

REQUESTED EXEMPTIONS 

14 CFR 61.113(a) and (b) 14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151(a) 14 

CFR 91.405(a) 14 CFR 407(a) (1) 14 CFR 409(a) (2) 14 CFR 417(a) and (b) 

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

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

Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground-based operator. The 

operational area is controlled and restricted, and all flights are planned and coordinated in advance. The 

level of safety exceeds that provided by a single individual holding a commercial pilot's certificate 3 

operating a conventional aircraft. The risks associated with the use of a UAS are diminished from the 

level of risk associated with commercial operations contemplated by Part 61 allowing UAS use by a 

private pilot as the PIC exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). (See 

Grant of Exemption No. 11062 Astraeus Aerial, Grant of Exemption No 11109, Clayco, Inc, for similar 

exemptions) 14 C.F.R. § 91.7 Civil Aircraft Airworthiness 91.7(a) No person may operate a civil aircraft 

unless it is in an airworthy condition. 

Although airworthiness certification does not exist for UAS, Robert Crum's, SOP, provides guidance to 

establish and maintain an equivalent level of safety. 14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in 

pertinent part, that: "except when necessary for takeoff or landing, no person may operate an aircraft 
below the following altitudes: ..... (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." Robert Crum requests authority 

to operate at altitudes up to 400 AGL, an exemption is needed to allow such operations. As stated in the 

SOP, the UAS will not operate higher than 400 AGL. However, operations would be conducted in sterile 

areas, where buildings and people will-not be exposed to operations without their preapproval. (See 

Exemption NO 11109 to Clayco Inc.) 

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

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

officials. Because of the advance notice to the property owners and participants in the UAS flight 

activities all affected individuals will be informed of the planned operations. Compared to flight 

operations for manned aircraft and the lack of flammable fuel, the mitigated risks associated with the 

proposed UAS operations is far less than conventional aircraft operating at or below 500 AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between a UAS and conventional 

aircraft. 14 C.F.R. §91.121 Altimeter Settings Section 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 a UAS may not have a 

barometric altimeter, but instead a GPS providing altitude data, an exemption is needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the SOP and Safety Check list, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. 

§91.151(a): Fuel Requirements for Flight in VFR Conditions Section 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 ...." 

Battery power for Robert Crum's UAS(s) provides approximately 12 to 20 minutes of powered flight, 

with 20% battery power remaining. To meet the 30-minute reserve requirement in 14 CFR §91.151, UAS 

flights would not be possible. Therefore, Robert Crum submits that safety can be achieved by limiting 

flights unless there is enough power to fly at normal cruising speed (given winds and forecast weather) to 

the intended point of landing with at least 30% battery power remaining. Given the limitations on the 

UAS'(s) proposed flight area and its proposed operations within a predetermined location, and flight in 

daylight VFR conditions will meet the intended requirements. (See Exemption Nos. 2689, 5745 and 

10650 for flight less than minimums. See Exemption Nos. 8811, 10808 and 10673 for daytime VFR 

conditions) 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (l) (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 Robert Crum UAS operations. However, Robert Crum's SOP provides 

guidance to establish and maintain an equivalent level of safety. Maintenance will be accomplished by the 

operator. Noting the UAS(s) are limited in size, will carry a small payload and operate only in sterile 

areas with brief flight times. If inechanical issues arise, the UAS can land immediately and will be 

operating no higher than 400 feet AGL. As provided for in the SOP, the PIC will ensure that the UAS is 

airworthy for each flight. 
PUBLIC INTEREST 

The enhanced safety of small unmanned UAS eliminates the greater risk alternatives when using larger 

manned aircraft, carrying fuels at low altitudes. In addition this relatively new technology provides clients 

access to photographic and videographic services and information that were previously not financially 

cost effective. Robert Crum proposes procedures and operational guidelines to provide the FAA good 

cause for granting instant Petition enabling the commercial operation of Robert Crum's UAS(s) and those 

being in the public interest. 

The FAA, by granting Robert Crum's exemption request, will serve to stimulate development of viable 

commercial UAS operations while guiding the public's understanding of how UAS can be legally and 

beneficially integrated into the National Air Space, NAS. 

CONCLUSIONS 

For the foregoing reasons, the exemptions requested herein should be granted and Robert Crum should be 

permitted to conduct UAS commercial operations according to the SOP and such additional parameters as 

the FAA should deem necessary. 

Respectfully submitted, 

obert Crum