Attn: Docket Operations

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue SE, Room W12­140

West Building Ground Floor

Washington, DC 20590­0001

Re: Exemption Request of the Communications Office of Friends’ Central School under Section

333 of the FAA Reform Act; Part 11 of the Federal Aviation Regulations; 14 CFR 45.23(b); 14

CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109: 91.119; 91.121;

91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b).

Dear Sir or Madame:

Pursuant to Section 333 the FAA Modernization and Reform Act of 2012 and 14 C.P.R. 11. The

Communications Office of Friends’ Central School seeks exemption from the Federal Aviation

Regulations (FARs) contained herein so that the Communications Office be permitted to operate

its small unmanned aircraft ("SUA"), or unmanned aircraft system ("UAS"), commercially in

airspace regulated by the Federal Aviation Administration ("FAA").

The Communications Office conducts standard and aerial photography and video production for

the purposes of documentation, and education. The Communications Office seeks the use of

SUAs or UASs to assist in said documentation, and submits this proposed Petition for Exemption

to the FAA to demonstrate its commitment in complying with the Federal Aviation Regulations

and the National Airspace System ("NAS") in their safe, responsible and limited commercial use

of UASs.

The contact information for Petitioner is as follows:

Geoff Campbell

Digital and Social Media Specialist

Communications Office, Friends’ Central School

1101 City Ave, Wynnewood, PA 19096 Phone: (610) 645­4485

Web: www.friendscentral.org/communications

Email: gcampbell@friendscentral.org

Mr. Campbell has experience as a recreational pilot of UASs, and is aware of the dangers that

unregulated UASs operation presents to persons and property on the ground. The

Communications Office has aptly equipped their UAS for aerial photography and videography,

and applies for an exemption from the FARs to allow operation of its UAS on our campus under

the conditions outlined below, and under such other limitations as may be established by the

FAA as required by Section 333 of the FAA Modernization and Reform Act.

Section 333 of the FAA Modernization and Reform Act of 2012 ("FAAMRA") grants the

authority to the Secretary to establish a policy outlining guidelines until the Unmanned Aircraft

Systems rule is finalized. As the FAAMRA found that because UASs do not pose a threat to
national airspace users or national security, operations of UASs do not need an FAA­issued

certificate of airworthiness.

This Petition for Exemption would permit the operation of small, lightweight, unmanned UASs

under controlled conditions in airspace, in the UASs pilot's line of sight, that is further in limited

and predetermined areas of operation. The Communications Office would allow for controlled

access and would further provide safety enhancements to the already safe operations in the video

production industry presently using conventional aircraft. The Communications Office

acknowledges how essential safety is when operating UASs. The operating specifications and

safety procedures of the UASs, which the Communications Office commits to uphold, ensures

that they do not pose a hazard or threat to other aircraft, national security or public safety.

The Communications Office’s Petition for Exemption coheres with the Secretary of

Transportation's responsibility to integrate UASs into the NAS and to "establish requirements for

the safe operation of such aircraft systems in the national airspace system" pursuant to the FAA

Reform Act§ 333(c).

Considering the foregoing and the Communications Office’s commitment to safety and

regulations of the FAA, the specific regulations from which exemptions under Title 14 of the

Federal Code of Regulations are herein requested are as follows: 14 CFR 45.23(b); 14 CFR Part

21; 14 CFR 61.113(a) & (b).

Exemption Request Section 333 of the FAA Reform Act; Part 11 of the Federal Aviation

Regulations; 14 CFR 45.7; 14 CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2);

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(l);

91.409(a)(2); 91.417(a) & (b).

The Communications Office submits this Petition in accordance with the FAA Reform Act, 112

P.L. 95 §§ 331­334, seeking relief from any currently applicable FARs operating to prevent the

Communications Office’s contemplated photography and videography operations within the

NAS. The Reform Act in Section 332 provides for such integration of civil UASs into our NAS

as it is in the public's interest to do so. The Communications Office’s lightweight UAS meet the

definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of

lightweight UASs are expressly contemplated by the Reform Act.

The size, weight, speed and operational capabilities of the UAS at issue, which the

Communications Office would use, with authorization from the FAA, show that they do not pose

a threat to other aircraft, national security nor public safety. The term "small unmanned aircraft,”

as defined by the U.S. Congress in Section 331, 112 Pub. Law 95, 2014, means "an unmanned

aircraft weighing less than 55 pounds."

The Communications Office’s UAS is a small, lightweight device containing counter­rotating

propellers for optimum balance, control and stability. The UAS the Communications Office

would like to operate Commercially is a DJI Phantom 3 Advanced. It is capable of vertical and

horizontal operations but operate only within the line of sight of the pilot (UAS operator). The
device weighs no more than 55 pounds, including any photography equipment. The

Communications’ Office’s UAS operates at speeds of 50 knots (57 mph) or less and is capable of

hovering less than 400 feet altitude.

The Communications Office does not operate its UAS near airports. To date, the

Communications Office has only operated its UAS on areas under the complete control of

Friends’ Central School. The Communications Office only operates its UAS in predetermined

areas.

Petitioner further and specifically seeks authorization to use a UAS, which is equipped with

cameras and sensors, in order to perform photography, audio and video filming by air for public

and private uses, including: advertising, promotions, or public events.

The Communications Office’s operation of its UAS will not "create a hazard to users of the

national airspace system or the public." 112 P.L. 95 § 333(b). Given the small size and weight of

the Communications Office’s UAS, combined with their operation in cordoned off and wellcontrolled areas, the Communications Office’s UAS falls within Congress's contemplated safety

zone when it promulgated the FAA Reform Act and the corresponding directive to integrate

UASs into the NAS. The Communications Office’s UAS does not pose any threat to the general

public or national security.

Maintenance of the UAS will be performed by the operator, in accordance with the aircraft's

flight and operating manual. The operator agrees to ensure the UAS is inspected before each

flight, to perform all required maintenance and to maintain a log of all maintenance and repairs

performed on all unmanned aircraft systems.

The Communications Office’s UAS is battery powered and creates no emissions. If the UAS

crashes there is no fuel to ignite and explode. The impact of the Communications Office’s

lightweight UAS is far less than a full size helicopter, notwithstanding the statistically

noteworthy safety record of full size helicopters used in motion picture capture.

To further explain why the Communications Office’s exemption will not adversely affect safety

or how granting the Communications Office’s exemption request will provide a level of safety at

least equal to existing rule:

The Communications Office’s exemption will not adversely affect safety. Permitting the

Communications Office to log more flight time in FAA controlled airspace will allow the

Communications Office to innovate and implement new and as of yet undiscovered safety

protocols. Additionally, the Communications Office proposes the following safety procedures

and restrictions if granted an exemption:

• The Communications Office’s UAS will weigh no more than 55 pounds, including any

photography or cinematic equipment;

• The Communications Office will only operate its UAS at an altitude of 400 feet or less;
• The Communications Office shall limit the UAS operation to thirty (30) minute flights, or

ceasing operation at 25% battery;

• The Communications Office remote control pilots operate its UAS only within line of sight;

• The Communications Office remote control pilots have video backup should they somehow

lose sight of its UAS;

• The Communications Office only operates its UAS in secured areas that are strictly controlled,

are away from airports;

• The Communications Office shall conduct an inspection of its UAS before each flight;

• The Communications Office shall obtain all necessary consent and permissions prior to

operation in the designated filming area prior to filming taking place.

• The Communications Office employs a GPS system within each UAS allowing the UAS return

to a predetermined location within the private or controlled­access property of Friends’ Central

School if it loses its GPS signal.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

FEDERAL REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following sections in Title 14 of the Code of Federal

Regulations: 14 C.F .R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.P.R. §§ 61.113 (a) and (b); 14

C.P.R. § 91.7(a); 14 C.P.R. § 91.9(b)(2); 14 C.P.R.§ 91.103(b); 14 C.P.R.§ 91.109; 14 C.P.R.§

91.119; 14 C.P.R. § 91.121; 14 C.P.R. § 91.151(a); 14 C.P.R. §§ 91.203 (a) and (b); 14 C.P.R. §

91.405(a); 14 C.P.R. § 91.407(a)(1); 14 C.P.R. § 91.409(a)(2); 14 C.P.R. §§ 91.417 (a) and (b) to

commercially operate its small lightweight unmanned aircraft in photography and video

operations.

The exemption will reduce current risk levels and thereby enhance safety. Currently, motion

picture image capture relies primarily on the use of larger aircraft running on combustible fuel.

The Communications Office’s UAS does not contain potentially explosive fuel, is smaller,

lighter and more maneuverable than conventional motion picture aircraft. Further, the

Communications Office’s UAS operates at lower altitudes and in controlled airspace.

There are no people on board the Communications’ Office’s UAS and therefore the likelihood of

death or serious bodily injury is significantly limited. The Communications Office’s operation of

its UAS, weighing less than 55 pounds and traveling at speeds no more than 50 knots in

designated areas on Friends’ Central School property will provide at least an equivalent level of

safety as that achieved under current FARs.

Therefore, the Communications Office respectfully respects that the FAA grant its exemption

request without delay.

Respectfully submitted,

Geoff Campbell

Digital and Social Media Specialist, Friends’ Central School