Garrett R. McGhee

GRM Photography 3227 McKinney Avenue #20A Dallas, TX 75204

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act from: 14 CFR 21 subpart H- Airworthiness Certificates 14 CFR 45.23(b) - Display of marks; General 14 CFR 61.113(a) and (b) - Private pilot privileges and limitations: Pilot in command 14 CFR 91.7(a) - Civil Aircraft Airworthiness 14 CFR 91.9(b)(2) - Civil aircraft flight manual, marking, and placard requirements 14 CFR 91.103 - Preflight Action 14 CFR 91.109 - Flight Instruction 14 CFR 91.119(b) and (c )- Minimum Safe Altitudes 14 CFR 91.121- Altimeter Settings 14 C.F.R §91.145(b) Management of aircraft operations in the vicinity of major sporting events 14 CFR 91.151(a) - Fuel requirements for flight in VFR conditions 14 CFR 91.405 (a) - Maintenance Required 14 CFR 91.407 (a) (1) - Operation after maintenance 14 CFR 91.409 (a)(1) and (2) - Inspections 14 CFR 91.417(a) and (b) Maintenance Records

References: 1. FAA Exemption No. 12803, Regulatory Docket No. FAA-2015-2606 2. FAA Exemption No. 12796, Regulatory Docket No. FAA-2015-2626 3. FAA Exemption No. 12446, Regulatory Docket No. FAA-2015-0820

Attachments: 1. DJI Phantom 2 User Manual 2. DJI Phantom 3 User Manual 3. DJI Inspire 1 User Manual

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, GRM Photography, hereby applies for an exemption from the Federal Aviation Regulations detailed below to allow commercial operation of small Unmanned Aircraft Systems (sUAS).

Commercial operation of sUAS would be utilized for the following purposes: 1. Aerial Photography and/orvideo for public and/or private use, including real estate, advertising, architecture, land surveys, engineering, construction, and other related professional needs. 2. Aerial inspection/photography of residential and/or commercial structures under contract with the owners and/or local government authority.

Tuesday, September 15, 20153. Aerial video/photography and/or providing live video feed and potentially other capabilities to assist with search and rescue operations in cases of an emergency as requested by local authorities.

As described in detail below, the requested exemption would allow for safe and cost effective commercial flight operations through utilization of a sUAS at low altitudes within the U.S. national airspace system when compared to a manned aircraft. GRM Photography sUAS operations will be performed when requested by and with the authorization and permission of clients in order to drive commerce as well as educate and raise awareness to the safe application of sUAS in everyday life. AII operations will be limited, controlled, and predefined.

The sUAS that will be utilized are multi-rotor aircraft weighing substantially less than 551bs. with all necessary equipment included. Normal operating speeds are

—15 MPH and limited to 4S MPH or about 40 Knots. Maneuverability allows for vertical and horizontal movement simultaneously while taking photographs and/or video. Operators will maintain visual line of sight at all times during planned flights and will adhere to all other local and federal regulations. Any additional stipulations outlined in the exemption requirements will be strictly adhered to. The approval of this application presents no risk to national security and will aid in the education of the general public, reduce emissions and environmental, impact, and will drive local commerce.



## The FARs The Petitioner seeks exemption from the above-mentioned FARs for the following reasons:

14 CFR 215ubpart H- Airworthiness Certificates Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Par[ 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the planned environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder are less than 55 Ibs. fully loaded, carries neither a pilot or passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

Tuesday, September 15, 201514 CFR 45.23(b) - Display of marks; General

This section requires that "When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 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.

Although the sUAS will have no airworthiness certificate an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in reasonably sized letters if deemed necessary to be in compliance with §45.29 (f).

14 CFR 61.113(a) and (b) - Private pilot privileges and limitations: Pilot in command Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. The sUAS that will be utilized do not carry any pilots, passengers, or property posing far less risks than the risk levels inherent in the manned aircraft commercial activities outlined in 14 CFR 61. Additionally, should this exemption be granted, the PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate, and exemption is specific to the "for compensation or hire" portion of this section.

14 CFR 91.7(a) - Civil Aircraft Airworthiness This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should this exemption be granted, there will be no airworthiness certificate issued for the aircraft and no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. Props with locking mechanisms have been applied to sUAS, which further the airworthiness of the systems.

14 CFR 91.9(b)(2) - Civil aircraft flight manual, marking, and placard requirements This regulation requires that "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 the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof." Due to the size and configuration of sUAS, there is no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot onboard, but because there is no cockpit in which to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the operator flying the sUAS will have immediate access to it. In addition, the DJI Pilot app has all documentation indicated in the hard copy manual, electronically stored in the application on the operator's smart phone or tablet.

14 CFR 91.103 - Preflight Action This regulation requires each pilot in command become familiar with all available information concerning that flight, to insure the safety of said flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The operator will take all actions including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Before the aircraft takes flight, a home GPS location

Tuesday, September 15, 2015will be set in the event that the aircraft becomes disoriented in flight, and the aircraft can return safely

to the home point.

14 CFR 91.109 - Flight Instruction Section 91.109 requires that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, inherently do not have fully functional dual controls. Flight control is accomplished using a remote controller that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of sUAS (Hayes-12803). The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the limited size and speed of the aircraft.

14 CFR 91.119(b) and (c )- 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 the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption requests authority to operate sUAS at altitudes up to 400 feet Above Ground Level (AGL) or not more than 100 feet above the subject which is being filmed, whichever is higher. The sUAS will not operate at , higher than 400 AGL except under the circumstances where the sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, which then the sUAS will not be operated more than 100 feet above the highest point on the structure. It also may be operated over open water close or sparsely populated areas as indicated in Section 91.119 (c).

The equivalent level of safety is achieved due the limited size, weight, speed of the sUAS as well as the location where it is operated. No flight will occur without the permission of the property owner or local officials, where required. Because of the advance notice to the property owner and participants in the filming activity, all afFected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 551bs and carrying flammable or explosive fuel, any risk associated with these operations is far less than those presented by conventional aircraft operating at or below 400 AGL. In addition, the low-altitude operations of the sUAS will ensure safe distance between the sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR 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 before departure." As the sUAS do not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed from this regulation. An equivalent level of safety will be achieved by the operator through live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before and during flight. The DJI Phantom 2 utilizes GPS tracking, requiring 6 or more satellite links prior to flight, which feeds the altitude information to the operator. The DJI Phantom 3 and the Inspire 1 use DJI Vision Positioning in addition to GPS. It is a positioning system that uses ultrasonic and image data to help the aircraft identify its current position. With the help of Vision Positioning, the Phantom 3 and Inspire 1 can hover in place more precisely when there is no GPS signal available. The main components of DJI Vision Positioning are located on the bottom, which include two sonar sensors and one monocular camera. This provides an additional level of safety when combined with the GPS.

Tuesday, September 15, 2015 414 C.F.R §91.145(b) Management of aircraft operations in the vicinity of aerial demonstrations and

major sporting events This regulation requires that in deciding whether a temporary flight restriction is necessary for an aerial demonstration or major sporting event not listed in paragraph (a) of this section, the FAA considers the following factors: (1) Area where the event will be held. (2) Effect flight restrictions will have on known aircraft operations. (3) Any existing ATC airspace traffic management restrictions. (4) Estimated duration of the event. (5) Degree of public interest. (6) Number of spectators. (7) Provisions for spectator safety. (8) Number and types of participating aircraft. (9) Use of mixed high and low performance aircraft. (10) Impact on non-participating aircraft. (11) Weather minimums. (12) Emergency procedures that will be in effect.

In the event that GRM Photography is contacted by potential clients to create videos and photographs of sporting events using sUAS, coordination with the FSDO prior to the event will occur to ensure absence of any other aircraft at the event. Event flight operations will only be conducted if the event is deemed safe and particular consideration will be given to the factors listed above when making the determination of safety. Exemption from this regulation may be necessary to provide services to
customers.

14 CFR 91.151(a) - Fuel requirements for flight in VFR conditions This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed -(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

The batteries powering the sUAS provide approximately 30 minutes of powered flight. To meet the 30- minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to less than 10 minutes in length. Given those limitations on the sUAS, proposed flight area and the location of proposed operations within a predetermined area, a longer period for flight in daylight or twilight VFR conditions is necessary to perform and provide services to customers at a reasonable rate. Exemptions from 14 CFR §91.151(a) have been provided to prior applicants (Kupla-12446 and Moore-12796).

Operating the sUAS, in a tightly controlled area where only people and property owners or official representatives will be allowed, with less than 30 minutes of reserve fuel, does not generate the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sUAS. Additionally, limiting sUAS flights to less 10 minutes would greatly reduce the utility for which the exemption will be granted. Petitioner believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 30% of battery power— whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone and is factored into the decision to operate prior to taking flight.

Tuesday, September 15, 201514 CFR 91.405 (a) - Maintenance Required; 14 CFR 91.407 (a) (1) - Operation after maintenance;

14 CFR 91.409 (a)(1) and (2) — Inspections; 14 CFR 91.417(a) and (b) Maintenance Records These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shalrbetween required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...," and others shall inspect or maintain the aircraft in compliance with Part 43. Due to these sections and Part 43 only applying to aircraft with an airworthiness certificate, these sections will not apply to the petitioner should the exemption from the requirement of Airworthiness certificates be granted.Exemptions from these regulations have been granted to prior applicants (Moore-12796 and Hayes12803). The operator, pursuant to the flight manual and operating handbook of the sUAS, will perform maintenance. An equivalent level of safety will be achieved because these sUAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods. If inechanical issues arise, the sUAS can land immediately and will be operating no higher than 400 feet AGL. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.



## The small Unmanned Aircraft Systems GRM Photography intends on utilizing the following 3 small Unmanned Aircraft Systems and has included the aircraft specifications for each. In addition, the Manufacturer User Manuals will be included with the exemption letter request for more detailed specifications.

1. DJI Phantom 2

Weight (Battery 

### & Propellers) 1000g

Hover Accuracy (Ready To Fly) Vertical: 0.8m;
Horizontal: 2.5m Max Yaw Angular Velocity 200°/s Max Tilt Angle 35°
Max Ascent 

### / Descent Speed Ascent: 6m/s; Descent: 2m/s Max Flight Speed 15m/s(Not Recommended) Diagonal Length 350mm Flight Time 25mins Take-Off Weight 51300g Operating Temperature -10°C 

### — 50°C Supported Battery D11 Smart Battery

2. DJI Phantom 3

Weight (Battery 

### & Propellers) 1280 g

HoverAccuracy (ReadyTo Fly) Vertical:0.lm; Horizontal: 1.5m

Tuesday, September 15, 2015Max Yaw Angular Velocity 200°/s Max Tilt Angle 35°
Max Ascent

### / Descent Speed Ascent: 5m/s; Descent: 3m/s Max Flight Speed 16 m/s (ATTI mode, no wind) Diagonal Size (Including Propellers) 590 mm

Flight Time 25mins Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

3. DJI Inspire 1 M od el T600

Weight (Battery Included) 2935 g Hovering Accuracy (GPS Mode) Vertical: 0.5 m/ Horizontal: 2.5 m Max Angular Velocity Pitch:300°/s Yaw:150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Wind Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes
Motor Model DJI 3510 Propeller Model DJI 1345 Operating Temperature Range -10° to 40° C Indoor Hovering Enabled by default Diagonal Distance 559 to 581 mm
Dimensions 438x451x301 mm Power Spectral Density 9.06mW/MHz

Risk mitigation The petitioner has reviewed FAA exemption references 1-3 Conditions 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 will be developed and employed to ensure that the sUAS airworthiness will be verified before each launch. Airworthiness will be maintained through performance of routine inspections before each flight, maintaining flight and maintenance logs to record life of time-sensitive components. These documents will be made available to the FAA and SOT to assist in future implementation of safety standards and regulations, per their request. Flight plans will be predetermined to limit the sUAS flight time and limit safety concerns. The petitionerwill take into account distance from persons and potential flight obstacles prior to flight operations. sUAS operation will always be within VLOS of the PIC and the observer.

Tuesday, September 15, 2015 7Public interest

Use of small Unmanned Aircraft Systems lieu of a manned aircraft will offer enhanced safety forthe public and reduced impact on the environment. Manned aircraft systems generate greater risk to public safety due to size/weight, carrying a crew, and the flammable/explosive fuel. Additionally, use of the sUAS in order to facilitate commerce could lead to economic growth and offer a new industry for the youth of our nation to study and take interest in. Operations under this exemption will enable small, local business owners the opportunity to afford services that were once only available to the most successful businesses resulting in trickle down growth beyond just the aerial photography/videography services industry. Aerial photography/video is a valuable marketing tool that provides perspective not often attained by the average individual creating demand in the market for not only the aerial photography/video service but also the products of the customers of this industry. Aerial surveying and inspections can increase work site safety and efficiency, improve volumetric estimation accuracy and reduce employee risks. A visual observer will be utilized during flight operations. Flight data including sUAS flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of sUAS as part of this application.

Conclusion The petitioner is requesting this exemption forthe purposes of aerial photography, videography, inspections, and otherflight operations. This request is phrased in a general manner to allow for the future safe applications of small unmanned aircraft systems. This is to prevent the repetitiveness and turnaround time that would result if additional exemptions were requested as new business applications are undertaken by GRM Photography. This offers the petitioner flexibility in business strategy and horizontal integration, maximizing the utility of the current systems. The petitioner's business model is based on offering clients sUAS services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has refrained from engaging in commercial use of the sUAS. The primary purpose of seeking this exemption is to obtain the capability to ofFer those services while remaining in compliance federal regulations. Thank you for your consideration.

Respectfully, 

# Aw1w

Garrett McGhee

Tuesday, September 15, 2015