Russell A. Graves June 2, 2015

PO Box 68

Childress, Texas 79201

Cell 806.28-.8007

Email: russell@russellgraves.com

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Inspire 1 User Manual (EN) v1.2 2015.3

 2) Inspire 1 Safety Guidelines v1.2 2015.31 

 3) Inspire 1 Quick Start Guide (EN) v1.2 2015.3

 4) Inspire 1 Maintenance Manual v1.0 2015.2

 5) Phantom 2 Vision+ User Manual v1.8 2015.1 

 6) Phantom 2 Vision+ Pilot Training Guide v1.1 2014.4

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in 

 the matter of the petition of DOUGLAS TRUDEAU 

 2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 

 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 

 3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in 

 the matter of the petition of FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, I Russell Graves, 

referred to hereafter as the petitioner, request exemption from the following sections of 

Title 14, Code of Federal Regulations §§ 

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 

(a)(1); 91.409(a)(2); 91.417(a) & (b);
In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, cinematography, videography, mapping, crop 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. national airspace system as compared 

to a manned aircraft. Operations will be performed only at the request of and with the 

authorization and permission of clients or their authorized agents in order to facilitate 

commerce and raise awareness of the beneficial uses of small unmanned air systems. 

So long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. The conditions 

identified and proposed by the petitioner are drawn from references 1-3. 

The FARs 

The petitioner seeks exemption from the above mentioned FARs for the following 

reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, 

who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this 

exemption would be required to comply with any conditions as set forth and in a similar 

fashion to the previously granted exemptions. 

91. 119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

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 or exemption and 

clarification concerning the terms “congested areas” and “densely populated”. The 

petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since 

the UAS does not have an altimeter and instead utilizes electronic GPS with a 

barometric sensor for altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UASspecific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. The UAS provides battery power remaining in percent to the PIC. The 

UA batteries provide approximately 17 minutes of powered flight. Information provided 

in the operating documents discusses procedures regarding remaining battery 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 those proposed operations, The 
FAA found that a reduced minimum power reserve for flight in daytime VFR conditions 

was reasonable. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in 

Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and 

ensure that the UAS is in a condition for safe flight in accordance with the operating 

documents. The FAA found that adherence to the petitioner’s 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. 

The UAS 

UAS 1: The DJI Inspire One is a highly successful consumer grade small rotorcraft in 

the quad copter configuration with an advertised weight of less than 7 pounds (2935g) 

designed primarily to carry aloft a high definition camera. It has an advertised maximum 

speed of less than 30 knots (14m/s) and a maximum climb rate of less than 1200 feet 

per minute (5 m/s). It is powered by four electric motors with a distance between motors 

of less than 24 inches (607mm) It utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information 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 failsafe modes of operation for either loss of RC or GPS 

signal. Altitude can be limited by the onboard flight controller and maximum altitude can 

be preprogrammed by the PIC. Battery life limits flight times to approximately 17 

minutes. The onboard flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state. An automatic termination of flight and 

landing will be initiated when the battery reaches a predetermined low state. It is 

anticipated that flights will usually last less than 12 minutes. More information is 

available in attachment 1 or http://www.dji.com/product/inspire-1/download 

UAS 2: The DJI Phanton 2 Vision+ is a highly successful consumer grade small 

rotorcraft in the quad copter configuration with an advertised weight of less than 3 

pounds (1,242g) designed primarily to carry aloft a high definition camera. It has an 

advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of 

less than 1200 feet per minute (6m/s). It is powered by four electric motors with a 

distance between motors of less than 14 inches (350mm) It utilizes an internal inertial 

measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) unit. Real time video 

and telemetry information 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 failsafe modes of 

operation for either loss of RC or GPS signal. Battery life limits flight times to 
approximately 17 minutes. The onboard flight controller will warn the pilot via telemetry 

and external lighting cues before reaching a low battery state. An automatic termination 

of flight and landing will be initiated when the battery reaches a predetermined low 

state. It is anticipated that flights will usually last less than 12 minutes. More information 

is available in attachment 1 or http://www.dji.com/product/phantom-2-vision-plus/

download

Risk mitigation 

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes that the procedures specified 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 UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure-prone components. 

The petitioner request that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that;

 “The UA may not operate in Class B, C, or D airspace without written 

 approval from the FAA. The UA may not operate within 5 nautical miles of 

 the geographic center of a nontowered airport as denoted on a current 

 FAA-published aeronautical chart unless a letter of agreement with 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 anticipated to be routine but the petitioner 

is 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. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and 

enhance personal photography. Crop surveying applications could lead to decreased 
use of pesticides and fertilizer and conservation of water as well as increased crop 

yields and decreased costs. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. The petitioner will provide 

clients with photographic data for these purposes on a ‘for hire’ basis acting as an 

independent contractor. A visual observer will be utilized. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. Flight data 

including UA flight time, Control Unit operation time, incident, accident, and details 

concerning any deviations from normal operations will be available to FAA for use in 

collecting data regarding the use of UAS as part of this application. This data may be 

submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as 

required.

Conclusion

The petitioner is requesting this exemption 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 strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the 

future without the long turnaround time associated with additional exemptions. 

The petitioner's business model is based on the idea of offering ad hoc small UAS 

services to individuals or companies who wish to employ these services as a safe, 

effective, and legal option to enhance their business or hobby. The petitioner’s own 

market research shows pent up demand for these services currently exists in the real 

estate market and other markets are just beginning to emerge. Although videography 

and photography are included in the request, the primary objective will be aerial survey 

of farm crops for precision agriculture. The petitioner has identified universities and 

other agencies that could benefit from the operation requested in this application. A 

quick internet search will show that many are currently operating similar UAS in exactly 

this fashion without, it is assumed, FAA authorization. The petitioner has refrained from 

engaging in commercial use of the UAS. The primary purpose of seeking this exemption 

is to obtain the capability to offer those services while remaining in compliance. 

Sincerely,

Russell Graves