Daniel J. Smith

Resolution Multimedia

PO Box 22041

Charleston, SC 29413

(814) 734­7427

info@resolutionmultimedia.com

U.S. Department of Transportation February 26, 2016

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam

I am submitting this petition on my own, on the behalf of my company Resolution Multimedia,

without the aid of legal council.

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

and 14 C.F.R. Part 11, Resolution Multimedia (RM) which is owned and operated by Daniel J.

Smith, a sole proprietor, operating in the State of South Carolina and the State of Pennsylvania.

Resolution Multimedia who has been building and operating Small Unmanned Aircraft Systems

for the past 5 years, wishes to apply for an exemption from the Federal Aviation Regulations

(FAR) listed below to allow operation of our sUAS commercially in airspace regulated by the

Federal Aviation Administration (FAA) so long as such operations are conducted with and under

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

The requested exemption would permit RM to pursue its commercial interests in providing

services to companies interested in aerial data that can only be captured by using newly

developed sUAS in the following areas:

­Surveying and 3D aerial mapping

­Agriculture crop assessment and growth patterns

­Golf course management

­Insurance company claim assessment

­Aerial photography and videography

­Special events

­Construction site and ecological impact assessment

RM asserts that all sUAS flights that will occur over private or controlled access property will do

so with the property owner’s consent and knowledge and that only people who have consented

or otherwise have agreed to be in the area where flight activity is taking place. Additionally, I

have extensive flight time logged with sUAS devices. Our observers will attend ground school to

be taught the rules and regulation as they pertain to operating private aircraft under Visual Flight
Daniel J. Smith

Resolution Multimedia

PO Box 22041

Charleston, SC 29413

(814) 734­7427

info@resolutionmultimedia.com

Rules (VFR) over civilian population areas as described and set forth in the Aeronautical

Information Manual.

The substance of this request is essentially the same as that granted to Falcon Sky Cam

Regulatory Docket No. FAA­2014­0884​in that RM is engaged in aerial photography and

videography of land, buildings, and insurance claims, by using remote controlled sUAS to see

the condition of fields, crops, ecological impact, and financial losses do to destruction by fire and

other natural disasters, without the need to drive over or climb on the property being so

assessed.

RM has a sUAS equipped with cameras for aerial photography including video and still pictures

and special lens adaptations to make them very accurate in the 3 D mapping activity. By doing

so we have the ability to produce high­resolution photography of remote locations that would be

difficult or dangerous to reach on foot. This would be especially problematic while doing loss

claim work for insurance companies.

RM exemption request would permit us to operate lightweight, unmanned (remotely controlled in

line of sight) sUAS’s in tightly controlled and limited airspace. Predetermined, specifically

marked areas of operation as well as Global Positioning Satellite (GPS) navigation maps which

incorporate restricted, no fly zones and control zones of airports, will allow RM to operate within

current safety parameters as well as the new ones being implemented.

The Extent of Relief RM Seeks and Its Justification for Such Relief:

Regulation from RM request exemption:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. (91.401­91.417)
Daniel J. Smith

Resolution Multimedia

PO Box 22041

Charleston, SC 29413

(814) 734­7427

info@resolutionmultimedia.com

Unmanned Aircraft System

sUASs are seen as a better photographic platform to helicopters because these smaller devices

are less expensive, they produce less noise, and they have much less environmental impact

and are less likely to cause injury to the public and or property.

I am petitioning for exemption to enable RM to operate DJI Inspire 1 and DJI Phantom 3, both in

which are equipped with a proprietary 3 axis gimbal and camera system. This sUAS has a built

in capacity to limit the height it flies above the ground, to limit the radius of the distance it flies

from the operator and to exclude it for Class B, C, and D airspace including No Fly Restricted

Zones. The DJI Inspire 1 and DJI Phantom 3 also have a failsafe feature of the Naza­M

autopilot system which means when the communication between the main controller and the

transmitter is lost, the DJI Inspire 1 and DJI Phantom 3 will return to the home starting point and

land safely.

The above specifications meet with the Model Aircraft Operating Standards as set below:

­ The petitioner will only operate its sUAS in line of sight of a pilot/observer and will operate at

sites that are sufficient distance from populated areas within the sterile area described in the

FOPM. Such operations will insure that the sUAS will not create a hazard to users of the

national airspace or the public.

­ When flying sUAS within 3 miles of an airport, airport operators will be notified and the

operator will give the right of way to avoid flying in the proximity of full scale aircraft.

­ Maximum flight time for each operational flight will be 25 minutes.

­ Flights will be terminated at 25% battery power reserve should that occur prior to the 30

minute limit. The sUAS will be programmed so it will not be operated at an altitude of no more

than 400 feet AGL, and not more than 200 feet above a fixed platform from which operations

are conducted.

­ The minimum crew for each operation will consist of the sUAS pilot and the Visual

Observer.

­ The sUAS will weigh less than 55 pounds including its payload of camera and gimbal.

­ The sUAS will fly no more than 50 knots and can hover plus move horizontally and

vertically.

­ Given the small size of the sUAS, and the restricted airspace within which it will operate, I

believe our sUAS operations will comply with both the spirit and the rules intended by the

Reform Act safety requirements.
Daniel J. Smith

Resolution Multimedia

PO Box 22041

Charleston, SC 29413

(814) 734­7427

info@resolutionmultimedia.com

As a part of this request for exemption, RM gives assurance that all persons involved in aerial

operations have completed sUAS education and training including all applicable regulations and

guidance documents.

I respectfully request exemption under Section 333 to enable RM to operate efficient, limited,

low risk commercial sUAS operations for the activities stated, respecting at all times, the space

and privacy of citizens and property as we keep our skies safe.

Sincerely yours,

Daniel J. Smith

Resolution Multimedia

PO Box 22041

Charleston, SC 29413

(814) 734­7427

info@resolutionmultimedia.com