Nov ember 29 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave SE Washington, DC 2059

RE: Exemption Request Pursuant to Section 3 33 of the FAA Modernization and Reform Act of 2012,

49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemptio n under section 333 of

the FAA Moder nization and Reform Act of 2012, I, Keith Young , referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations:

61.101 (e)(4) & (5) ; 61.113(a) & (b) ; 91.9(b); 91.119 (b) & (c ); 91.121; 91.151(a); 91.215(b); 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (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 ae rial 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 c ompared 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 aerial 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; 61.23(a) & (c), 61.101 (e) (4) & (5) & 61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a Recreational or Sport Pilot (or greater) certificate and the i r appropriate medical clearance

. 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.

91.9(b); A ll operating documents, manuals, authorizations and exemptions will be kept in a binder co

located with the UAS Pilot in C ommand (PIC)

, the intent of the reg ulations are therefore achieve d with an equivalent level of safety.

91.109(a); The majority of UAS by design are developed with single operational control t hrough the use of pre

- determined GPS enabled waypoints programmed before or during flight in addition to the use of a single hand held transmitter or control station controlled by the PIC. The design does not allow for dual controls during flight training and therefore the exemption is requested to train operators, build experience, and maintain proficiency. An equal level of safety will be achieved by conducting all training in a stile environment. Training sessions will be accomplished separately from fligh ts
conducted for c ompensation or hire

91.119 (b) & (c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conductedclos er 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 conce rning 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

ha s been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditi ons. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 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 redu ced minimum power reserve for flight in daytime VFR conditions was reasonable.

91.215(b); The UAS to be used in the proposed operation does not come equipped with a transponder. No transponder exists for the UAS, which can be installed. The petitioner requests relief from the exemption t o the extent required to operate in areas in which a transponder is required according the applicable regulations in this part. The PIC will achieve an equivalent level of safety by complying with all provisions of the COA under which operations are to be conducted. By issuing appropriate

NOTAMS and prior ATO coordination, an equivalent level of safety can be achieved as other manned aircraft, which receive authorization to fly in airspace where a transponder is required but not operable. In order to give p roper notice to the ATO, the PIC will comply with the p rovisions of 91.215(d)(3). The UAS flown under this exemption will comply with all altitude limits and airport standoff distances required by COA, which mitigate hazards to aircraft controlled by the ATO in congested airspace.

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 i s 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 rec ord keeping, were sufficient to ensure that safety would not be adversely affected.

The UAS

The petitioner plans on utilizing separate, but similar airframes from the DJI product line . The DJI Inspir e 1 /Pr o and DJI Phantom 3 Advanced/ Professional . These airframe s are a "pro

- sumer" grade small rotorcraft in the quadcopter configuration powered by electric motors each.

DJI Inspire 1

– Weight 6.47lbs. Transmitter Frequency 2.4

- 2.83Ghz

DJI Phantom 3 Professional

– Weight 2.82lbs. Transmitter Frequency 2.4

- 2.83Ghz

These airframes utilize an internal inertial measuring unit (IMU) wi th integrated barometric sensoraugmented with global positioning system (GPS) to maintain its geospatial orientation and positi on. 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 operat or and/or PIC to monitor battery level, GPS signal strength, alt itude (AGL), distance from P IC, camera imagery, and control camera angle.

Failsafe modes of operation for either loss of signal (RC or GPS) or batt ery level. Altitude is limited and pre

- programmed to not exceed 400ft AGL. Battery life limits flight t imes to approximately 20

- 25 minutes for each airframe. The onboard flight controller will warn the p ilot via telemetry and external lighting cues before reaching a low battery state. An automatic termina tion of flight and landing will

be initiated when t he battery reaches a predetermined low state. It i s anticipated that flights will usually last less than 15 minutes. More information is availab le in product manuals which are

identified below and accessible at the DJI support page ( http:// www.dji.com/support )

Risk Mitigation

The petitioner has reviewed FAA exemptions reference’s 1

- 3 Conditi ons 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 to ensure that th e 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 ti m e on failure

- prone components. If inspection reveals a condi tion that affects the safe operation of the UAS, it will be grounded immediately and prohibited from operating until maintenance is perfo rmed and the UAS is found to be airworthy. The petitioner also holds an Airline Transport Pilot rating with a Class One Medical Certificate, and participate s in an active drug testing progr am. As such I will maintain the highest safety standards, continue with constant hands on training in a controlled area away from the public, and utilize flight simulators. I wi ll also maintain awarenes s of curre nt airspace closures, Prohibited Areas

and “NO DRONE ZONES”

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 co nducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to fa cilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or t heir designees seeking an enhanced perspective for characteristics, amenities , and benefits of their desired photographic subjects that cannot be displayed through ground level v ideography/photography. Aerial photography is a valuable marketing tool that can lead to increase d commerce and enhance personal photography. Crop surveying applications could lead to decreased use o f pesticides and fertilizer and conservation of water as well as increased crop yields and decreas ed costs. Aeri al surveying and

ins pections can increase work site efficiency, improve volumetric est imations 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 b e utilized. Liabi lity 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 concer ning any deviations from normal operati ons 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 mean s, e.g. COA Monthly Reports, or other means as required.Conclusion

The petitioner i s requesting this exemption for the purposes of “aeri al photography, cinematography, videography, mapping, crop surveying, inspections and other fligh t operations”. 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 opti on 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.

Adding to the level of safety and experience in these operations, the p etitioner has experience in the

radio control model aircraft hobby, 16 years of experience in general an d military aviation and holds

th e following FAA Licenses and Ratings: Airline Transport Pilot Certificate (AMEL) Certified Flight Instructor

- Multi Engine Land, Instrument Airplane

Private Pilot License (ASEL)

If you have any questions or w ish for me to amend this request please do not hesitate to contact me.

Tha nk you in advance for your time and consideration.

Respectfully

,

Keith Young 335 Red Oak Airpark Cabot, AR 72023

Manuals Used For Operations: 1) DJI Inspire 1 User Manual v1.8 2) DJI I nspire 1 Maintenance Manual v1.8 3) DJI Inspire 1 Safety Guidelines v1.0 4) DJI Phantom 3 Professional User Manual v1.6 5) Intelligent Flight Battery S afety Guidelines v1.4

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