the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 stat9s the following, in part: (a) In General.--Notwithstandingany other requirementof this subtitle, andnot later t han 180 days after the date of enactment of thisAct, the Secretary of Trans portation shall determine 

### if certain unmannedaircraft systems may operate safely in the nationalairspace system before completion of theplan and rulenlaking required bysection 332 of thisActor the guidance required by section 334 of thisAct. (b) AssessmentofUnmannedAircraftSystems. --In making the determination under subse 1 ction (a), the Secretary shalldetermine, ata minimum-- / 

### (rJ.) which types of unmannedaircraftsystems, 

### if any, as a result of their size, weight, speed, operational capability ,proximity to airports and populatedareas, andoperationwithin visual line of sightdo not create a hazard to users of the national airspace system or thepublic orpose a threat to nationalsecurity; and (i

) whether a certificate of waiver, certificate of authori zation, or airworthiness certification under section 44704 of title 49, United States Code, is requiredfor the operation of unmannedaircraftsystems identified underparagraph (I). (c) Requirements for Safe Operation. --If the Secretary determines under this section that certain unmannedaircraftsystems may operate safely in the nationalairspace system, the Secretary shall establish requirements for the safe operation of such aircraftsystems in the nationalairspace system. 

### In seeking this exemption, Buckley Thomas Burkhardt submits that the Pl And 3DRS UAS's can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthePl and 3DRS UAS's; (b) the pilot certification requirement; and (c) the specific operating limitations
.

a. The Specifications OfThe Pl and 3DRS UAS's Demonstrate Its Safe Characteristics. The Pl and 3DRS UAS's do not create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.
1. Technical Specifications OfThe Pl and 3DRS UAS's. 18The technical specifications ofthe 

### PI and 3DRS UAS's are set forth by the 

### Pl and 3DRS Specifications and Data Sheet, attached hereto as Exhibit A and B
. ii. 

### The Pl and 3DRS UAS's Autonomous FlightAnd Navigation Modes Enable The UAS's To Remain Within A Defined Operational Area. The 

### Pl may be operated in both manual and fully Advanced flight modes. The 3DRS I may be operated in both manual and fully autonomous flight modes.


### Iii. The Pl and 3DRS UAS's Are Designed For Automatic Return To Home Point Or HoverIn The Event OfLoss OfThe Control Link Or Navigation. When the Control Link is lost, the 

### Pl UAS and 3DRS will remain stationary in flight, for 3 seconds or more. If, after 3 seconds, the 

### Pl and 3DRS due not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., failsafe 

### mode) via GPS, 

### and will descend to the takeoffposition and shutdown
.


### b. Flight Operations OfPl and 3DRS UAS's Are Limited To The Line Of Sight OfA Certificated Pilot in Command With A Safety Observer. Ralph William Graham will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilotin command (PIC) ofthe 

### Pl And 3DRS UAS's. Additionally, a safety observer will assist all pilots during flight operations.



### c. Flights OfPl and 3DRS UAS's Will Be Conducted Pursuant To Specific OperatingLimitations. In seeking this exemption, Ralph William Graham proposes to commercially operate 

### Pl and 3DRS UAS's for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuant to the following specific operatinglimitations: 1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS's we1ghing less than 55 pounds maximum gross weight: PI and 3DRS 

### 19Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant. 2
. UAS operations underthis exemption will be limited to conducting operations for the purpose ofaerial video and photography
. 3. The UA may notbeflown at an indicated airspeed exceeding 20 knots. 4. The UA mustbe operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UA's must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC'sFAA-issued airman medical certificate.
6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted
. 7. All operations must utilize a safety observer (SO). The 

### SO 

## may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC mustbe able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannottransfer his orher designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other airtraffic and other ground based obstacles/obstructions and is not permitted to operatethe camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. Itis the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also presentupdated and revised documents ifit petitions for extension or amendment to the grant ofexemption
. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be


### 20contacted ifquestions arise regarding updates or revisions to the operating documents. 10. Priorto each flight the PIC must inspect the UAS to ensure that itis in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found tobe in a condition for safe flight. The Ground Control Station must be included in the preflightinspection
. All maintenance and alterations mustbe properly documented inthe aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation orflight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12
. The pre-flight inspection must account for all potential discrepancies, e.g.inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents
. 13. The operator mustfollow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14
. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents
.Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UAS's operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third-class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistentwith how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C
.F .R. §61.51 (b). Flights for the purposes oftraining the operator's PIC's are permitted under the terms ofthe exemption
. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA
21with appropriate distance from nonparticipants in accordance with 14 C.F
. R. 

### § 91.119. 19. UAS operations may notbe conducted during night, as defined in 14 C.F.R. 

### § 19.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closestto proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20
. The UA may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport' s management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter ofagreementwith the airport management must be made available to the Administrator upon request.
21. The UA may not be operated 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
. 22
. 

### If

### the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land orbe recovered in accordance with the operating documents. 23
. The PIC must abort the flight inthe event ofunpredicted obstacles or emergencies in accordance with the operating documents
. 24
. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 25% battery power remammg. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under the grant ofexemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than48 hours priorto the operation
. All operations shall be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements
. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C
.P
.R. part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. part 45 , Subpart C. Markings mustbe as large as practicable
. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### 2228. The documents required fewer than 14 C.F.R 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any time the UAS is operating
. These documents must be made available to the Administrator or any law enforcement official upon request 29. The UAS must remain clear and yield the right ofway to all manned aviation operations and activities at all times
. 30. The UAS may not be operated by the PIC from any moving device orvehicle. 31
.Flight operations must be conducted at least 500 feet from all non participating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event ofan accident The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; 

### b. The aircraft is operated near vessels 1 vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32. All operations shall be conducted overprivate or controlled-access property with permission from the land owner/controller orauthorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33
. Any incident, accident, orflight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA mustbe reported tothe FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb
.12:m: . 2. Reasons Why An Exemption From The Requirements 

### OfSection 61.113(a) And (b) Would Not Adversely Affect Safety. Ralph William Graham submits thatthe equivalentlevel ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Pl and 3DRS UAS's unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the Pl or 3DRS UAS in 

### 23a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Ralph William Graham's proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercial pilotrequirements (See Exemption No. II062); and the airmanship skills necessary to safely operate the PI or 3DRS UAS , Ralph William Graham submits that the additional manned airmanship experience of
a commercially certificated pilot would not correlate to the airmanship skills necessary for Ralph William Graham' s specific proposed flight operations. The FAA has previously granted relieffrom Section 61.I13(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e
.g. Exemption Nos. 

### 11062, 11063, 11064, 11065, 11066, 11067, 11080, I1109 1 11110, 11112,11136,11138, 11I50, I1153, I1156, I1158, 11I59, 11I60, 11I6I). Ralph William Graham will not allow any PIC to operate the PI or 3DRS UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements ofthe PI or 3DRS UAS training and currency requirements, that the PIC is able to safely operate the PI or 3DRS UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances.from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with I4 C.F
.R. 

### § 61.5I(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model of UAS to be used for operations underthe exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). 

### 24As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience thatwas obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during Ralph William Graham's proposed operations. The Administrator has held that prior documented flight experiencethatwas obtained in compliance with applicable regulations would ensure safe operations, stating as follows : In Exemption No
. 11062, the FAA required that prior to conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including atleast 10 hours logged as a UAS pilot with a multi

-rotor UAS
.Priorto operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations underthe exemption. For clarification, theFAA considers these minimum hourrequirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti-rotor time and the 10 hours may be included in the total 25 hours ofUAS rotorcraft time
. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, 

### the flight-hour requirements in ExemptionNo. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conductthe petitioner's proposed operations. The FAA also finds thatprior documented flight experience thatwas obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

-buildingflights can also be conductedunder the grant ofexemptionto accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C
.F
.R 91.119. Exemption No
. 11138 at page 15. Accordingly, Ralph William Graham will ensure safe operations by not allowing any PIC to operate the Pl or 3DRS UAS unless thatPIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the PI or 3DRS UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 3. Reasons Why An Exemption From The Requirements OfSection 91.7(a) Would NotAdversely Affect Safety. 

### 25The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Ralph William Graham will ensure that the P1 or 3DRS UAS is in an airworthy condition based upon the UAS's compliance with operating documents and as stated inthe conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements OfSection 91.121 Would NotAdversely Affect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe P1 and 3DRS UAS's will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with Ralph William Graham's operation ofthe P1 and 3DRS UAS's within visual line ofsight, at orbelow 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed on boardthe aircraft. Priorto each flight, a zero altitude initiation point is automatically established by the UAS's at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Requirements OfSection 91.151(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 

### C.P.R. Section 91.15l(b) as a result of(1) the technical specifications ofthe Pl and 263DRS UAS's; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Ralph William Graham will ensure that he will safely operate the battery powered PI and 3DRS UA's during daylight hours in VFR conditions, with enough battery powerto fly for a total duration of 10 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 2
.5 minutes
. Here, as in Exemption No. III09, the technical specifications ofthe P1 and 3DRS UAS's the limitations on the proposed flight operations and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C
.F.R. Section 91.I51(b). Furthermore, safety will be ensured as the PI and 3DRS UAS's Controller provide audible, visual and tactile warnings to the PIC at the GCS when the UA's experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the PI and 3DRS UAS ' s will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 9I.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate atless than the minimums prescribed in Section 91
.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAAhas previously granted relief from Section 91.151 specific toUAS in circumstances similar in all material respects to those presented herein (e.g. Exemption Nos
. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161)
. 6. Reasons Why An Exemption From The Requirements OfSections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &(b) 

### Would Not Adversely Affect Safety. 27In seeking this exemption, Ralph William Graham submits that the equivalent level ofsafety with regard tothe regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be metbecause Ralph William Graham will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in the operating documents i.e., the Operations Manual, Monthly Maintenance Log, and Pl and 3DRS Instruction Manual. Furthermore, Ralph William Graham will document and maintain all maintenance records for the Pl and 3DRS UAS's. Since the Pl and 3DRS UAS's will be inspected as prescribed by the operating documents, Ralph William Graham will maintain the equivalentlevel ofsafety established by Sections 

### 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe Pl and 3DRS UserManuals are attached hereto as Exhibit C and D; a copy ofthe PI and 3DRS UAS Maintenance LOGis attached hereto as Exhibit E. Likewise, the exemption soughtwill not adversely affect safety because Ralph William Graham will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety Established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe P2V+ and 3DRS UAS's will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log
. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(I), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered.
28In consideration ofRalphWilliam Graham's proposed operating limitations, the operating documents, and the technical aspects ofthe PI and 3DRS UAS's, Ralph William Graham submits that safety will not be adversely affected by granting exemption from 14 C.F
.R
. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a) (2), and 91.417(a) and (b)
. TheFAAhas previously granted relief specific to UAS in circumstances similar, in all material respects, tothose presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161 ). 

### 7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAAModernization and Reform Act of 2012 (Fl\1RA) and 14 C.F
.R. 

### § 21.16 entitled Special Conditions, Ralph William Graham requests that the FAAprescribe special conditions for the intended operation of the P 1 and 3DRS UAS's, which contain such safety standards that the administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part21 , SubpartH, and 14 C.F
.R 

### §§ 61.113(a) & (b), 91.7 (a), 91.121 , 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UA's for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States for compensation or hire
. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security and further, provides the authority for such 

### UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in the NAS
. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F
.R. §21.16, for operation ofthe Pl and 3DRS UAS ' s, since the airworthiness regulations of 

### 2914 C
.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel
orunusual design features ofthe aircraft. Section 21
. 16, entitled Special Conditions, states the following: 

### Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, orpropeller because ofa novel orunusual design feature ofthe aircraft, aircraft engine or propeller, it may prescribe special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAAfinds necessary to establish a level ofsafety equivalent to that established in the regulations. See 14 C.F.R. 

### § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R 

### § 21.16, the FAA may prescribe special conditions for Buckley Thomas Burkhardt's intended operation ofthe P1 and 3DRS UAS 's, which contain such safety standards that the administrator finds necessary to establish a level ofsafety equivalentto that established by
14 C.F.R Part21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register stating: The Rules From Which Ralph William Graham Seeks Exemption: Ralph William Graham seeks exemption from the requirements of 14 CF.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(J), 91.409(a)(J) & (a)(2), and91.41 7 (a) & (b). A BriefDescription OfThe Nature OfThe Exemption Ralph William Graham Seeks: This exemption willpermitRalph William Graham to commercially operate an UnmannedAircraftSystem (UAS)for thepurpose of conducting aerial video and photography over certain areas of the UnitedStates. G. Any Additional Information, Views, Or Arguments Available To Support Ralph William Graham's Request. This Petition is made pursuant to the FAAModernization and Reform Act of2012


### 30(FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, Ralph William Graham request for exemption may be granted pursuant tothe authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Ralph William Graham will operate the P1 and 3DRS UAS's safely in the NAS, without creating a hazard to users ofthe NAS, or the public, or otherwise pose a threat to national security. CONCLUSION As set forth herein, Ralph William Graham seeks an exemption pursuantto 14 C.F.R. § 11.61 and Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe P1 and 3DRS UAS's commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States
. By granting this Petition, the FAA Administratorwill be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing Ralph William Graham to safely, efficiently, and economically operate the PI and 3DRS 

### VAS's commercially within the

### NAS. WHEREFORE,in accordance with the Federal Aviation Regulations and the FAAModernization and Reform Act of2012, Section 333, Ralph William Graham respectfully requests that the Administrator grantthis Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 319I.407(a)(I), 91.409(a)(l) & (a)(2), and 91.4I7(a) & (b), and permit Ralph William Graham to operate the PI and 3DRS UAS's commercially for the purpose of conducting aerial video and photography over certain areas ofthe United States. Dated: December I, 20I5 Respectfully submitted,



# ~~ **~**
APPENDICES :

A- PI Specifications B

- 3DRS Specifications C

- P 1UserManual Internet Link D

- 3DRS User Manual InternetLink E -Monthly maintenance Log



### 32APPENDIX-A Pl TECHNICAL SPECIFICATIONS Ralph William Graham only utilizes safe and reliable UAS's
. DJI is an industry leader in small UAS production. 1.1 Phantom 1 V 1.1. 1 1.1. 1 Aircraft 1
. 1.1.1 Batteries 2400mAHLiPoBattery 1.1.1.2 Weight, Flight -4 lbs 6 oz (3345g) 1.1.1.3 HoverAccuracy-Vertical: +/-.8m; Horizontal: +/-2
.5m 1.1
. 1.4 Max Tilt Angel -35deg 1
. 1.1.5 Max Ascent/Descent Speed -6rn/s 1.1.1.6 Max Flight Speed -15m/s (NOT RECOMMENDED) 1
. 1.1
.7 Max Flight Time Appx 23 Min 1.1.1.8 Camera-Go Pro Hero 3+Black 1.1.1.9 Operating Frequency 2.400GHz- 2.462GHz 1.1.2
. 1 CommunicationDistance (unobstructed) FCC Compliance 500m 1.1.2.2 TransmitterPowerFCC Compliance 125mW



### 33APPENDIX-B 3DRS TECHNICAL SPECIFICATIONS Ralph William Graham only utilizes safe and reliable UAS's. 3DRis an industry leader in small UAS production. 3DRUAS 's are loaded with groundbreaking software enablingthe user to set parameters which will not allow flight into controlled airspace
. Parameters can also be set to limitflight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, 3DR software provides real-time altitude and location infoiTilation to the PIC viathe linked GoPro Camera
. This UAS Was released in June 2015 and is the most advanced devise on the market today in the Prosumer market.


### 2
.2 30 Robotics Solo 2.2.1 Aircraft 1.1.1.1 Batteries 14.8v 5200mAHLiPoBattery 1.1.1.2 Weight, Flight -4 lbs 0 oz (1800g) 1.1.1.3 Hover Accuracy-Vertical: +/-
.8m; Horizontal: +/-2.5m 1.1.1.4 Max Tilt Angel -35deg 1. 1.1.5 Max Ascent/Descent Speed -6m/s 1.1.1.6 Max Flight Speed -55 MPH 1
. 1.1.7 Max Flight Time Appx 20 Min 1.1
.1.8 Camera

- GoProHero 1.1.1.9 Operating Frequency 2.400GHz

- 2.462GHz 1.1.2.1 CommunicationDistance (unobstructed) FCC Compliance 500m 1.1.2
.2 TransmitterPowerFCC Compliance 125m W



### 34Hours:

Airframe Motors Propellers !Flight !Control !Update Gimbal Mise 

### APPENDIX-C P1 Manufacturer's User Manual can be reviewed at: www.

### dji.com/productlphantom/download?www=v1



### APPENDIX-D 3DRS Manufacturer's UserManual http://3drobotics.com/solo/



### APPENDIX-E Ralph William Graham Monthly Maintenance and RepairLog
Aircraft: Date: Date Issue Date Issue IssueDecription/MaintanceConducted Repair /Maintance Discovered Resolved Performed By



### 35