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. --Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan and 

rulenlaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems. --In making the determination under 

subse1

ction (a), the Secretary shall determine, at a minimum--

/ 

(rJ.) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and 

(i) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is requiredfor the operation of unmanned aircraft systems 

identified under paragraph (I). 

(c) Requirements for Safe Operation. --If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace 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 ofthe Pl and 3DRS UAS's; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

a. The Specifications Of The Pl and 3DRS UAS's Demonstrate Its Safe 

Characteristics. 

The Pl and 3DRS UAS's do not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

1. Technical Specifications Of The Pl and 3DRS UAS's. 

18 
The technical specifications of the 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 Flight And 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 Hover In The Event Of Loss Of The 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 takeoff position and shutdown. 

b. Flight Operations OfPl and 3DRS UAS's Are Limited To The Line Of 

Sight Of A 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 pilot in command (PIC) of the 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 Operating Limitations. 

In seeking this exemption, Ralph William Graham proposes to commercially 

operate Pl and 3DRS UAS's for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations: 

1. Operations authorized by this grant of exemption 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 

19 
Unmanned Aircraft Systems. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UA may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no 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 of sight (VLOS) of the 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's FAA-issued 

airman medical certificate. 

6. The use of first 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 must be 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 cannot transfer his or her 

designation for the duration of the 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 air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption 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. It is the operator's responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for amendment to 

its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be 

20 
contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a 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 of the operating documents. 

13. The operator must follow 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 of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the 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 of the 

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 consistent with 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 of training the operator's PIC's are 

permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

21 
with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

19.1. All operations must be conducted under visual meteorological 

conditions (VMC). If flight at night is required, a special request will be made 

at the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA published 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 of agreement with 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 or be 

recovered in accordance with the operating documents. 

23 . The PIC must abort the flight in the 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 (A TO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under 

the grant of exemption. This COA will also require the operator to request a 

Notice to Airman (NOT AM) not more than 72 hours in advance, but not less 

than 48 hours prior to the operation. All operations shall be conducted in 

accordance with airspace requirements in the ATO issued COA including class 

of airspace, 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 must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UAS must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

22 
28. The documents required fewer than 14 C.F.R 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the 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 of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

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 of an 

accident The operator must ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or; 

b. The aircraft is operated near vessels1 vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and 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, 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 over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

33 . Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the 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 Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety. 

Ralph William Graham submits that the equivalent level of safety 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 

23 
a 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 of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (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 relief from 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, I11091 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 of the 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 of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

24 
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Ralph William Graham's proposed operations. The 

Administrator has held that prior documented flight experience that was 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 of motion 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 at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model ofUAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-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 Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner's proposed 

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under 

the grant of exemption to 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 that PIC 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 Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

25 
The equivalent level of safety 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 in the conditions and limitations herein. Additionally, 

the FAA has previously granted relief from 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 Of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the 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 of the flight path and altitude. This altitude information, 

combined with Ralph William Graham's operation of the P1 and 3DRS UAS's within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. The altitude information will be generated by GPS equipment installed on 

board the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UAS's at ground level. 

The FAA has previously granted relief from 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 Of Section 

91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.P.R. Section 91.15l(b) as a result of (1) the technical specifications of the Pl and 

26 
3DRS 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 power to fly for a total duration of 10 minutes to the first 

point of intended 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 of the P1 and 3DRS 

UAS's the limitations on the proposed flight operations and the location of the proposed 

operations, will ensure an equivalent level of safety 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 of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91 .151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS 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 Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &(b) 

Would Not Adversely Affect Safety. 

27 
In seeking this exemption, Ralph William Graham submits that the equivalent 

level of safety with regard to the 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 met because 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 equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the Pl and 

3DRS User Manuals are attached hereto as Exhibit C and D; a copy of the PI and 

3DRS UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption 

sought will 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 of safety 

Established by Sections 91.407, 91.417(a) and 91.417(b ), because all maintenance of the 

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 of the 

UAS are considered. 

28 
In consideration ofRalph William Graham's proposed operating limitations, the 

operating documents, and the technical aspects of the 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). The FAA has previously granted relief 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). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 (Fl\1RA) and 14 C.F.R. § 21.16 entitled Special Conditions, Ralph William Graham 

requests that the FAA prescribe special conditions for the intended operation of 

the P 1 and 3DRS U AS's, which contain such safety standards that the administrator 

finds necessary to establish a level of safety 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 of the UA's for the limited purpose of conducting 

aerial video and photography over certain areas of the United States for compensation or 

hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the 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 of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§21.16, for operation of the Pl and 3DRS UAS's, since the airworthiness regulations of 

29 
14 C.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel 

or unusual design features of the aircraft. Section 21 .16, entitled Special Conditions, states 

the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the 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 of this chapter 

and contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety 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 of safety equivalent to that established by 

14 C.F.R Part 21, 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), and 91.41 7(a) & (b). 

A Brief Description Of The Nature Of The Exemption Ralph William Graham 

Seeks: 

This exemption will permit Ralph William Graham to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support 

Ralph William Graham's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 

30 
(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Ralph William Graham request for 

exemption may be granted pursuant to the 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 of the 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. 

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 of the NAS, or the 

public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, Ralph William Graham seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 

(FMRA), which will permit safe operation of the P1 and 3DRS UAS's commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial video 

and photography over certain areas of the United States. By granting this Petition, the 

FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of2012, while also advancing the interests of the 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 

FAA Modernization and Reform Act of2012, Section 333, Ralph William Graham 

respectfully requests that the Administrator grant this 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), 

31 
9I.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 of the United States. 

Dated: December I, 20I5 

Respectfully submitted, 

~~~ APPENDICES: 

A- PI Specifications 

B - 3DRS Specifications 

C - P 1 User Manual Internet Link 

D - 3DRS User Manual Internet Link 

E -Monthly maintenance Log 

32 
APPENDIX-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 2400mAH LiPo Battery 

1.1.1.2 Weight, Flight -4 lbs 6 oz (3345g) 

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 -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 Communication Distance (unobstructed) FCC Compliance 500m 

1.1.2.2 Transmitter Power FCC Compliance 125m W 

33 
APPENDIX-B 

3DRS TECHNICAL SPECIFICATIONS 

Ralph William Graham only utilizes safe and reliable UAS's. 3DR is an industry leader in 

small UAS production. 3DR UAS's are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight 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 via the 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 - Go Pro Hero 

1.1.1. 9 Operating Frequency 2.400GHz - 2.462GHz 

1.1.2.1 Communication Distance (unobstructed) FCC Compliance 500m 

1.1.2.2 Transmitter Power FCC Compliance 125m W 

34 
Hours: 

Airframe 

Motors 

Propellers 

!Flight 

!Control 

!Update 

Gimbal 

Mise 

APPENDIX-C 

P1 Manufacturer's User Manual 

can be reviewed at: 

www. dj i. com/productlphantom/download?www=v1 

APPENDIX-D 

3DRS Manufacturer's User Manual 

http://3drobotics.com/solo/ 

APPENDIX-E 

Ralph William Graham Monthly Maintenance and Repair Log 

Aircraft: 

Date: 

Date Issue Date Issue Issue Decription/Maintance Conducted Repair/Maintance 

Discovered Resolved Performed By 

35