June 1, 2015

Mark D. Dieckmann
3435 Linkwood Drive Houston, TX 77025 Cell (832) 303 0014 Email: mdieckmann@g mail.com

U.S. Department of Tra nsportation Docket Management S ystem 1200 New Jersey Ave. , SE Washington, DC 20590

RE: Exemption Reques t Section 333 of the FAA Reform Act of 2012

References: 1) FAA Exemption No. 11138, Regulatory Doc ket No. FAA20140481 in the matter of the pet ition of DOUGLAS TRU DEAU 2) FAA Exemption No. 11136, Regulatory Doc ket No. FAA

–2014

– 0508 in the matter of the petitio n of ADVANCED AVIA TION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Dock et No. FAA20140355 in the matter of the pet ition of FLYING CAM IN C

Dear Sir or Madam,

In accordance with the FAA ’ s Guidelines for Submitti ng a Petition for Exemp tion
under section 333 of th e FAA Modernization a nd Reform Act of 2012 , I Mark D. Dieckmann, referred to hereafter as the petitio ner, request exemption from the following sections of Title 14, Co de of Federal Regulatio ns §§

61.113(a); 61.113(b); 9 1.119(c); 91.121; 91.15 1(a); 91.405(a); 91.407 (a)(1); 91.409 (a)(1); 91.409(a)(2); 91 .417(a) & (b);

In order to operate sma ll unmanned aircraft systems (UAS) commerc ially in airspace regulated by t he Federal Aviation Ad ministration (FAA) for t he purposes of aerial photography, cin ematography, videogra phy, and other flight op erations that could be performed safely an d more cost effectively with the use of small U AS at low altitude
within the U.S. nationa l airspace system as co mpared to a manned a ircraft. Operations will be performed only at the request of and w ith the authorization an d permission of
clients or their authoriz ed agents in order to fa cilitate commerce and raise awareness of
the beneficial uses of s mall unmanned air sys tems.

So long as such operat ions are conducted with in and under the condit ions
outlined herein or as m ay be established by th e FAA as required by S ection 333. The
conditions identified an d proposed by the petit ioner are drawn from re ferences 1-3.The FARs The petitioner seeks ex emption from the above mentioned FARs for th e following

reasons ;

61.113(a) & (b) ; The petitioner requests relief in order to facilita te the utilization of an e xperienced UAS operator with the addition of a trained ob server. All pre-flight ins pection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT ) for review; with the pu rpose of safely integrat ing civil UAS operation in the Nation al Airspace System.

91.119(c) As discussed in Exemp tion 11138 (DOUGLAS TRUDEAU), operation s conducted closer than 500 feet to the ground may require that the UAbe operated
closer than 500 feet to essential persons, or o bjects that would not be possible without additional relief. The pe titioner requests modifi cation, waiver or exemp tion and clarification concerning the terms “ congested areas ” and “ densely populated ” . The petitioner requests wai ver for this condition to allow reasonable and responsible operations in areas of s ubdivisions and neighb orhoods if required. The petitioner will prima rily operate the UAS be tween ground level and 200 feet. The UAS will be operat ed over designated pro perties with the owner ’ s consent and while maintaining a saf e distance from person s. The petitioner will co mpile flight data from the logs. This datamay assist the FAA in development of regulat ions for commercial operations in low-risk, controlled e nvironments.

91.121 As discussed in Exemp tion 11138 (DOUGLAS TRUDEAU) is inapplic able since
the UAS does not have an altimeter and instea d utilizes electronic GP S with a
barometric sensor for a ltitude information.

91.151(a) As discussed in Exemp tion 11136 (ADVANCE D AVIATION SOLUTIO NS LLC) prior relief has been gr anted for manned aircraft to operate at less th an the prescribed minimums, including E xemption Nos. 2689, 57 45, and 10650. In addit ion, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime,
VFR conditions. The U AS provides battery po wer remaining in perce nt to the PIC. The UA batteries provide ap proximately 25 minutes of powered flight. Infor mation provided in the operating docum ents discusses procedu res regarding remainin g battery power management. Those d ocuments contain a con dition in which the PIC will initiate a landing procedure whe n battery remaining rea ches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The
FAA found that a reduc ed minimum power res erve for flight in daytim e VFR conditions
was reasonable.

91.405(a); 91.407(a)(1 ); 91.409 (a)(1) & (2); 9 1.417(a) & (b)As discussed in Exemp tion 11138 (DOUGLAS TRUDEAU), The petiti oner proposes to inspect an d ensure that the UAS is in a condition for safe flight in accordance with the op erating documents. The FAA found that adhere nce to the petitioner ’ s operating documents and the conditions and limitations specified, d escribing the requirements for m aintenance, inspection, and recordkeeping, we re sufficient to ensure that safety wou ld not be adversely affe cted.

The UAS

The DJI Phantom 2 Vis ion Plus is a highly suc cessful consumer grad e small rotorcraft in the quadcopter configu ration with an advertise d weight of less than 44 Ounces (1242g) designed primarily to c arry aloft a high definiti on camera. It has an ad vertised maximum speed of less than 30 k nots (15m/s) and a max imum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electr ic motors with a distanc e between motors of less than 14 inches ( 350mm). It utilizes an in ternal inertial measurin g unit (IMU) with integrated barometric s ensor augmented with global positioning syste m (GPS) to maintain its geospatial orientation and position . It is controlled primari ly through an FCC certified radio control (R C) unit. Real time video and telemetry informat ion is transmitted back to a ground contro l station allowing the op erator and/or PIC to mo nitor battery level, GPS signal stren gth, altitude (AGL), dist ance from PIC, cameraimagery, and control camera angle. I t has failsafe modes ofoperation for either los s of RC or GPS signal. Altitude ca n be limited by the onb oard flight controller an d maximum altitude can be preprog rammed by the PIC. Ba ttery life limits flight tim es to approximately 25 minu tes. The onboard flight controller will warn the pilot via telemetry and external lighting cu es before reaching a lo w battery state. An auto matic termination of flight and landing wil l be initiated when the b attery reaches a prede termined low state. It is anticipated th at flights will usually las t less than 12 minutes. More information
is available in attachme nt 1.

Risk mitigation The petitioner has revie wed FAA exemptions r eference ’ s 1-3 Conditions and

Limitations section and believes th at the procedures spec ified therein are reason able
and will be utilized in o rder to manage and mi tigate risk and ensure p ublic safety. A preflight checklist will b e developed and emplo yed to ensure that the U A airworthiness
will be verified before la unch. Airworthiness wil l be maintained by perf ormance of routine inspections bef ore each flight, maintai ning flight and mainten ance logs to record time on failure prone co mponents. These docu ments will be made ava ilable to the FAA
and SoT to assist in fut ure implementation of s afety standards and reg ulations. The petitioner will only operate the UAS over desig nated properties with th e owner ’ s consent. Flight plans w ill be predetermined to limit the UASs flight tim e and limit safety concerns. The petitione r will take into account distance from persons and potential flight obstacles prior to opera ting the UAS. UAS ope ration will always be wi thin VLOS of the
PIC and the observer.

Public interest
Use of the UAS in lieu of a manned aircraft wo uld enhance safety and reduce theenvironmental impact a s compared to similar o perations conducted w ith manned aircraft of greater proportions, carrying a crew and fla mmable fuel. Additiona lly, use of the UAS
in order to facilitate com merce could lead to ec onomic growth. Operat ions for this petition will enable serv ice for property owners or their designees see king an enhanced perspective for charact eristics, amenities, and benefits of their desire d photographic subjects that cannot be displayed through grou nd level videography/p hotography. Aerial photography is a valua ble marketing tool that can lead to increased c ommerce and enhance personal phot ography. Aerial surveyi ng and inspections can increase work site efficiency, improve volu metric estimations and reduce risks. The petiti oner will provide clients with photograph ic data for these purpos es on a ‘for hire ’ basis acting as an independent contractor . A visual observer will be utilized. Flight data including UA flight time, Control Unit oper ation time, incident, acc ident, and details conce rning any
deviations from normal operations will be avai lable to FAA for use in collecting data regarding the use of UA S as part of this applica tion. This data may be submitted to FAA
via traditional means o r other means as requi red.

Conclusion The petitioner is reques ting this exemption for the purposes of “ aerial photography, cinemato graphy, videography, in spections and other flig ht operations ”

. The reason for such a general and broad bas ed request is that the p etitioner wishes to
utilize a business strate gy of horizontal integra tion and maximize econ omies of scope in order to capitalize on o pportunities as they ma y arise in the future wit hout the long
turnaround time associ ated with additional exe mptions. The petitioner 's business model
is based on the idea ofoffering ad hoc small U AS services to individu als or companies who wish to employ the se services as a safe, e ffective, and legal optio n to enhance their business or hobby . The petitioner has refr ained from engaging in commercial use of the UAS. The primary purpose of seeking th is exemption is to obtai n the capability to
offer those services wh ile remaining in complia nce. The petitioner has 4 years of experience in the radio control model aircraft h obby.

Respectfully submitted
Mark D. Dieckmann