Page 1

December 8 , 2015

U.S. Department of Transportation , Docket Operations 

### West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE Washington, D.C. 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11

- I ( Robert Kennon Williamson ) hereby apply for an exemption from the listed Federal Aviation Regulations (FARs) to conduct commercial operation of designated Unmanned Aircraft Systems (referred to as UAS), provided such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Commercial operations of my UAS, equipped with camera(s) and sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other relat ed professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events, landscape cinematography and network news imaging.

3. Aerial inspection/photography of residential/commercial structures under con tract with the owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safety for current and future UAS operations within the National Airspace System (NAS).Page 2

As described below, the requested exemption would permit the operation of a designated UAS as

set forth i n this document under controlled conditions in the NAS that would be compliant with all local, state, and federal regulations. Approval of this exemption would further the positive public image of UAS operations in a safe and responsible manner and further the seamless integration of these aircraft types into the National Airspace System. Additionally, because of the electric propulsion systems and their reduced impact on the environment (both in economic terms and ecological disruption s), a reasonable leve l of benefit to the public good would also be provided as

I would be able to operate on a significantly minimized infrastructure while providing the same level of safety and service currently performed by convention al aerial photogra phy and filming

aircraft.

The name and address of the applicant is:

Robert Kennon Williamson (Private Pilot Certificate: 3477943 )

1835 Russell Rd
Bolivar, Tennessee 38008

Phone: 731

- 609

- 4432

Em ail: bobwill0817@gmail.com

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a)

14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

It is my request to operate the following model type of UAS:

DJI Phantom 3 Professional (ple ase refer to the complete specifi cations on the next page)Page 3

UAS DJI Phantom 3 Professional Specifications :

Type Quad rotor, fixed gear and propellers Weight (Including Battery And Propellers) 1280 g Diagonal Size (Including Propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s

Hover Accuracy

• Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m

• Horizontal: +/

- 1.5 m

Max Speed 35 miles per hour, or 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m Operating Temperature 0 ° to 40 ° C Gps Mode GPS/GLONAS

Camera Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8,

focus at ∞ Iso Range 100

- 3200 (video) 100

- 1600 (photo) Shutter Speed 8s

- 1/8000s Image Max Size 4000 x 3000 Still Photography Modes

o Single Shot

o Burst Shooting: 3/5/7 shots

o Auto Exposure Bracketing (AEB): 3/5

o Bracketed Frames at 0.7EV Bias

o Time

- lapse Video Recording Modes

Phantom 3 Professional

• UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

• FH D: 1920x1080p 24/25/30/48/50/60

• HD: 1280x720p 24/25/30/48/50/60 Supported Sd Card Types Micro SD Max capacity 64 GB Class 10 or UHS

- 1 rating required

Max Bit rate Of Video Storage 60 Mbps Supported File Formats

• FAT32/ex FAT

• Photo: JPEG, DNG

• Video: MP4, MOV (MPEG

- 4 AVC/H.264) Operating Temperature 0 ° to 40 ° C

Gi mbal Controllable Range Pitch

- 90° to +30°

Stabilization 3

- axis (pitch, roll, yaw) Vision Positioning (VPS) Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 30cm

- 300cm Operating Range 30cm

- 300cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)Page 4

DJI Phantom 3 Remote Controller Specifications :

Operating Frequency 2.400 GHz

- 2.483 GHz

Max Distance 2000m (outdoors and unobstructed) Video Output Port USB Operating Temperature 0°C

- 40°C Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone Receiver Sensitivity (1%Per)

- 101 dBm ±2 dBm

Transmit ter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm Working Voltage 1.2 A @7.4 V

Battery Charger Specifications :

Battery Charger Voltage 17.4 V

Rated Power 100 Watts Intelligent Flight Battery Capacity 4480 mAh Voltage 15.2 V Battery Type LiPo 4S Energy 68 Wh Net Weight 365 g (per battery) Max Flight Time Approximately 23 minutes Operating Temperature

- 10°C to 40°C 

### Max Charging Power 100 W

Mob ile Viewing Device Specifications :

App / Live View Mobile App

DJI Pilot Eirp 100mW Live View Working Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating Systems iOS 8.0 or later , Android 4.1.2 or later

Recommended Devices

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2,

iPad mini 2 Wi

- Fi + Cellular, iPad Air 2 , iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad

mini 3 Wi

- Fi + Cellular. Th is app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3,

Nubia Z7 miniPage 5

Operations and Reg ulatory Compliance Specifications

The UAS will be operated in full compliance with all manufacturer guidelines, but not to exceed any limit ations or restrictions as defined by approved op erating documents or Federal Aviati on Regulations. The mobile viewing device used with the controller s hall be of a type that is specifi cally recommended for use by the manufacturer . Software and/or fi rmware updates will also be completed as required to ensure optimal operation of the system.

Due to the small size of my UAS aircraft and the restricted environment within which they will
operate, my UAS operations will remain well within the Reform Act’s safety requirements. Secondly, due to the small size of the UAS platform and the predetermined are as in which it will operate, approval of this application presents no national security issues. Based upon the elevated level of safety surrounding the proposed operations, the significant public benefi t of these enhanced safety procedures, and the reducti on in environmental impacts (reduced emissions and noise), the grant of the requested exemption is believed to be in the public interest. Accordingly, I respectfully request that the FAA grant the requested 333 exemption.

The appli cant proposes that the exemption requested apply to UAS that have the characteristics and that operate with the limitations listed. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory st ructure because the proposed operations represent a safety enhancement to the existing aerial photography and aerial fi lming

for movie and television filmi ng operations conducted with conventional aircraft.

These limitations and conditions to which I agree to be bound when conducting commercial operations under an FAA issued 333 exemption include, but are not limited

to :

1. Operations authorized by this grant of exemption will be limited to the DJI Phantom 3 series and a ramp weight of less than 55 pounds, including payload. Proposed commercial

oper ations of any other UAS type b y myself will require a new petition or a n amendment to this exemption.

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour). The pilot may use either groundspeed or calibrated airspeed (as presented via telemetry data on the mobile viewing device) to determine com pliance with the 87 knot speed restriction. In no case will the Phantom 3 be operated at airspeeds greater than the maximum operating air speed recommended by the aircraft manufacturer.

3. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL).Altitude must be reported in feet AGL (as presented via telemetry data on the mobile viewing device) .

4. The UA will be operated within visual line of sight (VLOS) of the PIC at all times.

5. All operations will utilize a visu al observer (VO). The UAS will be operated within visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be

able to communicate verbally at all times. The PIC m ust ensure that the VO is qualifi ed to perform the duties required of the VO.

6. This exemption and the operating documents needed to operate this UAS must be accessiblePage 6

during all operations, and if a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein will take precedence.

7. If the approved UAS has undergone maintenance or alterations that affect the U AS operation

or fli ght character istics, e.g., replacement of a fl ight component, it must undergo a functional

test fl ight prior to conducting further operations under t his exemption. Functional test fl ights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people or structures. The test fl ight must be conducted in such a manner so as to not pose a

hazard to persons and property.

8. The operator will be responsible f or maintaining and inspecting the UAS to ensure that it is in an airworthy condition for safe operation.

9. Prior to each fl ig ht, the PIC will conduct a pre

- fl ight inspection and determine the UAS is in a condition for safe flight. The pre

- fl ight inspect ion will be used to determine if any potential discrepancies, e.g., inoperable components, items, or equipment exists. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the nec essary maintenance and/or corrective action has been performed and

the UAS is determined to be in a condition for safe fl ight.

10. I will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life

limit r equirements for the aircraft and aircraft components.

11. Each UAS operated under this exemption will comply with all manufacturer safety bulletins.

12. The PIC must hold a t least a private pilot certifi cate or FAA recogniz ed equivalent . The PIC

must also hold a c ur rent FAA airman medical certifi cate or a valid U.S. driver’s licen se. The PIC must also meet the flight review requirements specifi ed in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certifi cate.

13. I will not permit any PIC to commence operations unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining approp riate distances from persons, vessels, vehicles and structures.

14. PIC qualification fl ight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). During training, profi c iency, and experience

- building fl ights, all persons not

ess ential for fl ight operations are considered nonparticipants, and the PIC will operate the

UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night as part o f this exemptio n, as defi ned in 14 CFR § 1.1 . All operations will be conducted under visual meteorological conditions (VMC).

16. My UAS will not operate within 5 nautical miles of an airport reference point (ARP) as denoted

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement (LOA) with that airport’s management is obtained or otherwis e permitted by a COA issued to the exemption holder.

17. The UAS will not operate less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC and VO.

18. If the UAS loses communi cations or loses its GPS signal, the PIC will initiate a Return to Home (RTH) to it s known takeoff point. Further, the UAS will utilize the manufacturer’s fail

safe fl ight profi le that requires the UAS to initiate a climb to the maximum altitude (400 feetPage 7

AGL),then proceed to the pre

- determined home point, and then initiate a vertical descent to landing to avo id potential obstacles along it s return path.

19. The P IC will immediately abort the flight in the event of unpredicted obstacles or emergencies.

20 . The PIC will not operate the UAS unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate

after that for at least fi ve minutes or with the reserve power recommen ded by the manufacturer if greater. Low power warning will be set to 25% (termination of operations and

an immediate return to the takeoff point), and critical power will be 10% (automatic auto land sequence is initiated).

21. All operations shall be cond ucted in accordance with an ATO (air traffi c organization)

- issued COA (certifi cate of waiver or authorization). I will appl y for a new or amended COA if I intend to conduct operations that cannot be conducted under the terms of the attached COA.

22. All UAS operated in accordance wit h this exemption will be identifi ed by serial number, registered in accordance with 14 CFR part 47, and have identifi cation (N

− Number) markings

in accordance with 14 CFR part 45, Subpart C. Markings wil l be as large as practicable.

23. All documents and manuals used to ensure the safe operation and fli ght of the UAS as well as any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time it is operating. These documents and manuals will be presented to the Administ rator or any law enforcement offi cial upon request.

24. The UAS will remain clear and give way to all manned aviation operations and activities at all

times.

25. The UAS will not be operated by the PIC from any moving device or vehicle.

26. All fli ght operations will be conducted at least 500 feet from all nonparticipating persons,
vessels, vehicles, and structures unless:

A. Barriers or structures are present that suffi ciently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protec tion and a re wi thin 500 feet of the UA, li ght operations will cease immediately to ensure the safety of nonparticipating persons.

B. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects a nd the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue

hazard. The PIC, VO, operator trainees or essential persons are not considered non participating persons under this ex emption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representa tive will be obtai ned for each fl ight to be conducted. Any incident, accident, or fl ight operation that transgresses the lateral or vertical boundaries of the ope ration al area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Offi ce (AFS

− 80) wi thin 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:www.ntsb.gov.

28. If operations for television fi lming and production are approved, the following additional

condi tions and limitations will apply.Page 8

29. I must have exemption permits for operations for the purpose of closed

- set motion picture and

television fi lming.

3 0

. The operator must have a motion picture and television operations manual (M PTOM) as documented in this grant of exemption.

3 1

. At least 3 days before aerial fi lming, I will submit a written Plan of Activities to the loc al Flight

Standards District Offi ce (FSDO) with jurisdiction over the area of proposed f ilming. The 3

- day

notifi cation may be waived with the concurrence of the FSDO. The plan of activities will include at least the following:

a. Dates and times for all fl ights; b. Name and phone number of the operator for the UAS aerial fi lming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS;
d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certifi cate number of U AS PICs involved in the aerial fi lming;

f. A statement that the operator has obtained permission from property owners and/or local

officials to conduct the fi lming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemptio n holder or representative; and h. A description of the fl ight activity, including maps or diagrams of any area, city, town,

c ounty, and/or state over which fi lming will be conducted and the altitudes essential to accomplish the operation.

3 2

. Flight ope rations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specifi ed in the exemption holder’s MPTOM.

3 3

. Unless otherwise specifi ed in this grant of exemption, the UAS, the UAS PIC, and the UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts
45,47, 61, and 91.

3 4

. The UA S will only operate within a defi ned boundary area throughout all phases of fl ight. Security will be moni tored by the operator and designated security personnel.

3 5

. A preflight briefi ng will be conducted in regard to the day’s planned UAS operations. All personnel who will be performing duties within the boundaries of the safety perimeter be
present for thi s briefing. Preflight briefi ng items will include, but are not limited to:

a. Authorized UAS fl ight operations, mission plan of activities, and special provisions issued by t he Flight Standards District Offi ce having jurisdiction over the photo / fi lming area. b. Radio communications (if required for operations permitted within 5 miles of an airport). c. Takeoff procedures. d. Maneuvering of the UAS to be conducted during the event. e. Approach and landing procedures. f. Alternate landing zone in the event of emergency or security breach. g. Weather and special considerations. h. Emergency procedures.

i. Safety briefi ng for participating personnel. j. Safety procedures of non

- participating persons.

k. Defi nition of operational boundaries. l. Regulatory req uirements: local, state, or federal.Page 9

m. Any additional limitations or procedures unique to the operations.



### Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

4 C.F.R. Part 21, Subpart H:

Airworthiness Certifi cate s 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certifi cates, establishes the procedural requirements for the

issuance of airworthiness certifi cates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section333 of

the Reform Act both authorize the FAA to exempt aircraft from the requirement for an

airworthiness certifi cate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all c ases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certifi cate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fi xed wing or rot orcraft) operating with an airworthiness certifi cate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. including payload, carries neither a pilot nor passenger, carries no explosive materials or

fl ammab le liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is

now done with conventional fi lming. The FAA will have advance notice of all operations. These safety enhancements, which al ready apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to the public and property owners than conventional operations con ducted with airworthiness certifi cates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or fl ammable liquid fuels, and inability to carry aPage

10 substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or expe rimental or provisionally certifi cated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Even though the UAS w ill

have no airworthiness certifi cate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word Experimental” can be placed. Given the
size of the sUAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be provided by having the sUAV marked o n its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identifi cation of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 101 67

and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft

tha t carries the pilot and passengers, the UAS is remotely controlled with no souls on board. The area of operation is cont rolled and restricted, and all fl ights are planned and coordinated in advance as set forth in the Manual. The level of safety provided e xceeds that provided by a single individual holding a commercial pilot’s certifi cate operating a conventional aircraft. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contem plated by Part 61 when drafted, that allowing operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness The regulation r equires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certifi cate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining air wort hiness. Given the size of the aircraft and the requirements contained in the Manufacturers Operating

Manual for maintenance and use of sa fety check lists prior to each fl ight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in t he aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof

. The UAS, given

its size and confi guration has no ab ility or place to carry such a fl ight manual on the aircra ft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the fl ight manual at the ground control point where the pilot fl yi ng the sUAS will have immediate access to it. ThePage

11 FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738,
9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827,and 10700.

14 C.F.R. § 91.103: Prefl ight Action This regulation requires each pilot in command to take certain actions before fl ight to insure the safety o f fl ig ht. As FAA approved rotorcraft fl ight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing current wea ther
conditions and forecasts, fl ight time and battery requirements, establishing a clear takeoff and landing zone, and aircraft perf ormance data before initiating fl ight.

14 C.F.R. §91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

b alloon) that is being used for fl ight instruction unless that aircraft has fully functioning dual controls. UASs and remotely piloted aircraft, by their design do not have fully f unctional dual controls. Flight control is accomplished through the use of a control box that communicates with

the aircraft via radio communications. The F AA has approved exemptions for fl ight training without fully functional dual controls fo r a number o f aircraft and for fl ight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety can be achieved as neither a pilot nor passengers will be carried in the aircraft in addition to the small size and low speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating

t he helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is not a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above a n elev ated platform from which fi lming is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the loc ation whe re it is operated. No fl ight will be taken without the permission of the property owner or local offi cials. Because of the advance notice to the property owner and participants in the fi lming activity, all

affected individual s will be aware of the planned fl ight operations. Compared to fl ight operations with aircraft or rotorcraft weighing more than the maximum 55lbs.proposed herein and the l ack of

a fl ammable fuel source, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C. F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available be fore departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, by receiving alt itude information via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- screen display. This altitude information will be generated by equipmentPage

12 installed on board the aircraft, using GPS triangulation, or dig itally encoded barometric altimeter, or radio altimeter, or any comb ination thereof. Prior to each fl ight, a zero altitude initiation point will

be es tablished and confi rmed for accuracy by the pilot.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits a n individual from beginning “a fl ight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) the re is enough fuel to fl y to

the fi rst point of intended landing, and, assumi ng normal cruising speed

– (1) During the day, to fl y after that for at least 3 0 minutes; or (2) At night, to fl y after that for at least 45 minutes.”The battery powering a small UAS provides appro ximately 23 minutes of powered fl ight. To meet the 30

minute reserve requ irement in 14 CFR §91.151, UAS fl ights of this type would not be possible.

Given the lim itations on the UAS’s proposed fl ight area and the location of its proposed operations within a predetermined area, a longer time frame for fl ight in daylight or night VFR conditions is

reasonable. I believe that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

comp liance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where onl y people and property owners or offi cial representatives who have signed waivers will be allowed,

with less than 30 minutes of reserve fuel, does not engender the t ype of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. I believe that an equivalent level of safe ty can be achieved by limiting fl ights to 23 minutes or 25% of battery

power, whichev er happens fi rst. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Civil Aircraft: Certifi cates Required The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certifi cate. . . . (b) No person may operate a civil aircraft unless the airworthiness certifi cate required by paragraph (a ) of this section or a special fl ight authorization issued under §91.715 is displayed at

the cabin or cockpit entrance so that it is legible to passengers or crew. A small UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certifi cation and registration documents or to displa y them on a sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot fl ying the sUAS will have immediate access to them, to the extent they are applicable to the UAS. The FAA has issued num erous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665,9789, 9789A,
9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Requirements and

In spections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepanci es repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.Given that these section and Part 43 apply only to aircr aft with an airworthiness certifi cate, these sections will
not ap ply to a UAS operated by myself . Maintenance will be accomplished b y the operator pursuant to the fl ight manual and operating handbook. As the manu facturer does not providePage

13 specifi c maintenance instructions, maintenance will be “on condition” for all aircraft and each aircraft will have a maintenance log. An equivalent level of safety will be maintained because small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight as part of a detailed p refl ight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator will be the individual most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If the operator encounters a
maintenance issue which cannot be addressed, the UAS will be returned to the manufacturer or a qualifi ed repair facility where such repairs or maintenance can be performed. These repairs will

also be noted in t he aircraft maintenance log.

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: Applicant ( Robert Kennon Williamson ) seeks an exemption from the fo llowing rules:14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 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) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to commercially operate a small unmanned aerial system (55lbs or less) in aerial photography and aerial fi lming operations. Approval of exemptions allowing commercial operations of sUASs in the aerial photo and fi lm industry will enhance safety by reducing r isk. Conventional fi lm operations, using jet or piston power aircraft, operate at extremely low altitu des close to the subject being fi lmed and in near proximity to people and structures and present the risks associated with vehicles that weigh in excess o f 3000 pounds and carry large amoun ts of fuel. Such aircraft must fl y to and f rom the fi lm location. In contrast, a small UAS weighing less than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combu stible fuel carried on bo ard. The UAS is carried to the

fi lm set or location and not fl own. The small UAS will also carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft fl ights. The operation

of a sm all UAS weighing less than 55 pounds, conducted in the strict conditions outlined above, will provide an equivalent or increased level of safety supporting the grant of the exemptions requested herein, including the exemption of the applicant from the requ irements of Part 21 and allowing commercial operations. These small, unmanned aircraft operate at slow speeds in close proximity to the ground, as well as in a restricted environment. As a result, a small UAS in commercial operations is far safer than oper ations conducted with conventional helicopters or aircraft operating in similarly close proximity to structures and personnel.

In the matter of privacy, all fl ights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Filming will be of people who have also consented to being fi lmed or otherwise have agreed to be in the area where fi lming will take place.Page

14 In cl osing , I will ensure that all regulatory requirements are met and/or exceeded in the best interests of professionalism and safety. I am committed to this philosophy, and will gladly provide feedback and additional data to further the development of this emerging industry.

If you have any questions or require any additional information, please contact the undersigned

at (731) 609

- 4432 or bobwill0817@gmail .com.

Sincerely yours,

Robert Kennon Williamson ( Pilot Certificate 3477943 )