## . November 0 I, 2015
Phoenix Professiona l Pr oductions 133 1 Bradley Ave. Hummelstown, P A 1703 6 (717) 566-7 408
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Exemption Reque st Section 333 of the FAA Reform Actof2012 Attachments: References: l. FAA Exempt ion No 12939, Regulatory Docket No. FAA2015-2297 in the matter of the petition STEVEN DOHERTY 1. FAA Exempt i on No. I I 138 , Regulatory Docket No. FAA2014-0481 in the matter of the petition of DOUGLAS TRUDEAU 2. FAA Exemption No. 1 1136, Regulatory Docket No. FAA-2014--0508 in the matter of the petition ofADVANCED AVIATION SOLUTIONS LLC 3. FAA Exemption No. 11080 Regulatory Docket No. FAA20 14 0355 in t he matter of the petition ofFLYING CAM INC
Dear Sir or Madam, In accordance with the FAA's Guidelines for Submifling a Petition for Exemplion under section 

### 333 of the FAA Modernization and Reform Act o.f2012, the peti tioner, requests exemption from the following sections of Ti tle 1 4, Code of Federal Regula ti ons : 61.113(a), 61.113(b), 91.119( c), 91.121, 91.15 I (a), 9 I .405(a), 91.407(a)(l ), 91.409 (a)( l ), 9 ! .409 (a)(2), and 91.417(a) & (b).
In order to operate sma ll unmanned aircraft systems (UAS) commercially in ai r space regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, inspections of: construction sites, solar panels, structures, roofs, real estate photography, and other flight oper at ions that could be perfomted safel y and more cost effectivel y witlt the use of small UAS at low altitude within tlte US National Airspace System as compared to a manned aircraft. Operations 

### will be performed to faci l itate commerce and raise awareness of beneficial uses of small UAS. So long as such operations are conducted witltin and wtder tlte conditions outlined herein or as may be established by the FAA as r equ ired by section 333. The conditions identified and proposed by the pet i tioner is drawn from references 1 -3.

### Th e FARs The 

### petitioner requests exemption from the above mentioned F ARs 

### for the following reasons. 6 1.11 3(a) & (b). 

### The petit i oner , requests re lief in orde r to facilitate the u tilization of pilots, who h o l

d a pilo t (o r g r eater) cer t i

fi ca te. Any pilots op e rat ing und er this exempt i on would be required to comply with any cond ition s us set forth and in a similar fash i on to the previously granted exemptions. A Visual Observer will be used at all times while under this requested exemption. 91.1 19( c ) As discussed in Exemption 11 138 (DOUGLAS TRUDEAU), operati ons conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver o r exemption and clarification concerning the tcm1s "congested areas" and '"densely populated "

. The petitioner requests waiver for this condition to allow reasonable and responsible operati ons with safety as my main concern in area s of subdivisions an d neighborhoods if

### requ i red. 9 1.1 2 1 As discussed in Exemption 11 138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and inst ead util i/.es electronic GPS with a barometric sensor for a l titude infonnation. 9l.1 5 l (a) As discussed in Exemption 1 I 136 (ADVANCE D AVIATION SOLUTIONS LLC) prior relief has 

### been granted for manned aircmft to operate at less than the prescribed minimums, including E xemption Nos. 2689, 5745, and I 0650. In addition, simi Jar UAS speci fie reliefhas been granted in Exemption Nos. 88 I I , I 0808 , and I 0673 for daytime, VFR conditions . The UAS p rovides battery power remaining in p ercent to the PIC. The UA bat teries prov i de approximately 25 minutes ofpowered fl ight. Information provided in the operating documents discusses procedures regarding remaining bartery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of t h ose proposed operations, Th e FAA f ound that a reduced minimum power reserve for flight in 

### daytime VFR conditions was reasonable. 91. 4 05(a). 9 1.4 0 7(a}( l ). 9 1.409 (a)(l) & 

### (2). 9 1

. 4 17( a) & (b) As 

### discussed in Exemption 11138 (DOUGLAS mUDEAU), the petitioner proposes to inspect and e nsure that the UAS is in a cond ition for safe fl i ght i n acco rdance wi th the operating documents. The FAA found that adherence to the petitioner operating documents and the conditions and limitations specified , describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to 

### ensure that safety would not be adversely affected. Th cUAS The 

# on Phantom 3 Professional is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised "'eight ofJess than 45 ounces (12 80g) designed primarily to 

### carry aloft a high definition camera. It 

### has an advertised maximum speed of les s than 30 kno ts (16m /s) and a m a

xim um climb mte of l ess than 1200 feet per minute (6m/s). It 

### is powered b y four e l ect ri c motors with a distance between motors ofJess than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented wit h global posit i oning system (G PS) to maintai n its geospa ti a l o ri entation an d po sition. 

### It is contro lle d p ri mari ly t h

rough an FCC certified radio control (RC) unit. Real time v ideo and t elemetry info r mation is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level , GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle

. It has fail safe modes of operation for either loss ofRC or GPS signal. Altitude can be limited by the on board fl i ght cont roller and maximum altitude can be preprogrammcd by the PIC

. Battery life l i mi ts fli ght times to a

pproximately 25 minutes. The onboard flight contro ll er will warn the pilot v ia telemetry and externa l lighting cues before reaching a low battery state. i\n automatic termination of flight and landing will be initialed when the battery reaches a predetermined low

**~1atc.** It is anticipated that flight s will usually last less than I0 minutes. More information is available in attacluncnt I. Risk mitig ation The petitioner has reviewed FAA exemptions reference's 1-3 Conditions and Limitation s section and believe that the procedures specifi ed therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UAS's airworthiness will be verified before launch. Airworth i n ess will be maintained by perfo rmance of r outine i nspections be fo re each fl ight, mai n taini ng flig h t and maintenance logs to record time on failure prone componen t s. The petitioner requests that in a manner similar to reference 4, be allowed to operate within 5 miles of an airport provided that: "The VA may not operate in Class B, 

### C , or D airspace w ithout wrillen approva l from the FAA. The VA may not operate within 5 nautical miles of/he geographic center of a non towered airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with thar airport 's management is obtained, and the operation is conducted in accordance with a NOTA..M as required by the operator ' s COA. The Ieifer of agreement with the airport management must be made available to the Administrator upon request

. " Operations within 5 miles of an ai rport ar e not anticipated to be routine but I am requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise

. Operations within class B airspace are not requested due to the lack of mode C transponder. Publi c int erest Use of the UAS in l ieu of a manned aircraft would enhance safety and reduce environmental impact compared to similar operations conducted with much larger fuel laden manned aircrafl In addition, the use of UAS to facilitate commerce can help to encoumge economic growth. Operations for this petition will enable service for property owners or their d esignees seeking an e n hanced perspective f or characteristics, amenities , and benefits of their des ir ed photog r a

phi c subjects that cann ot be disp l ayed through gr

ound level videography/photography. Aerial photography is a valuable marketing t oolthat can facilitate increased commerce and enhance personal photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risk. The petitioner 

### will provide clients with the photographic data for these purposes 

### in a for hire basis acting as an independent contractor. A visual observer will be utilized. Flight data inc lud ing UA flight time, Control unit operation time , incident, accident, and details concerning any dev iati ons from normal operations will be available to the FAA for use 

### in collecting data regarding the use ofUAS as a part of this application. This data can be submitted to the FAA via reports as required by the FAA. Flight data including UAS flight time, Control Unit operation time, incident, and details will be recorded for each flight and made available to the FAA at any time needed. Any deviations from norma l operations will also be recorded and made availabl e to FAA. Conclu si on The petitioner is requesting this exemption for the purposes of aerial photography, cinematography , videography, mapping, real estate photography, inspections and other flight operations. The reason for such a general and broad based request is that the petitioner wishes to utilize a strategy that allows maximum flexibility to utilize the UA to its fullest potential within the constraints of this request, without the long turnaround time associa ted with additional exemptions. The peti tioner plans to offer services to i nd ividuals or companies seek ing to enhance their business in a sa fe and lawti.ll way. Respectfully submitted,

Theresa Searer I Phoenix Professional Productions

Attachments: I. Phantom 3 Professional Quick Start Guide http ;'dn"'nlmd dmnpoyjlltQnS

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