Bradley C. Lorance

8649 Jacksboro Rd

McMinnville, TN 37110

M: 623-224-7617

E: Lorance11@gmail.com

August 16, 2015

US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in 

the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 

in the matter of the petition of ADVANCED AVIATION SOLUTIONS 

LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in 

the matter of the petition of FLYING CAM INC

Dear sir or madam,

In accordance with the FAA's guidelines for submitting an application for 

exemption under section 333 of the FAA Modernization and Reform Act of 

2012, I Bradley Lorance, referred to hereafter as the petitioner, request 

exemption from the following sections of Title 14, Code of Federal 

Regulations.

61.113 (a)

61.113 (b)

91.119 (c)

91.121

91.151 (a)

91.405 (a)

91.407 (a) (1)

91.409 (a) (1)
91.409 (a) (2)

91.417 (a)

91.417 (b)

In order to operate small unmanned aircraft systems (UAS) in airspace 

regulated by the Federal Aviation Administration (FAA) for the purpose of 

aerial photography, videography, survey, mapping, inspections, and other 

flight operations that may be performed more safely and more costeffectively with the use of a small UAS at low altitude within the U.S. 

National Airspace System in comparison to a manned aircraft. Operations 

will be performed only at the request and with the authorization of clients 

and/or their authorized agents. All such operations shall be conducted 

within conditions outlined herein or as may be established by the FAA as 

required by Section 333.

Requested Exemption

The petitioner hereby requests exemption from the aforementioned FAR's 

for the following reasons.

61.113 (a)(b)

The petitioner requests relief in order to facilitate the utilization of an FAA 

certified airman, Mr. Bradley Lorance, who holds a Private Pilot certificate 

and a current and valid class 3 medical certificate. Mr. Lorance would be 

required to comply with any conditions set forth and as in a similar fashion 

as to the previously granted exemptions.

91.119 (c)

As discussed in exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UAS be 

operated closer than 500 feet to essential personnel or objects that would 

not be possible without additional relief. The petitioner requests 

modification, waiver, or exemption and clarification concerning the terms 

"congested areas" and "densely populated". The petitioner requests waiver 

for this condition to allow reasonable and responsible operations in areas 

of housing subdivisions and neighborhoods as required.

91.121

As discussed in exemption 11138 (DOUGLAS TRUDEAU) is inapplicable 

as the UAS does not have an altimeter and instead, will use GPS data for 

altitude data.

91.121
As discussed in exemption 11136 (ADVANCED AVIATION SOLUTIONS, 

LLC) prior relief has been granted for manned aircraft to operate at less 

than prescribed minimums including exemption numbers 2689, 5745, and 

10650. In addition, similar UAS specific relief has been granted in 

exemption numbers 8811, 10808, and 10650 for daytime VFR conditions. 

The UAS will provide battery power remaining data reflected as 

percentage of capacity to the PIC. The UAS batteries provide 

approximately twenty five minutes of powered flight. Information provided 

in the operating documentation discusses procedures regarding remaining 

battery power management. These documents contain a condition in which 

the PIC will land the aircraft when the battery power remaining reaches the 

minimum level that will allow a safe return and landing of the aircraft. Given 

the limitations on proposed operations and the location of those proposed 

operations, the FAA found that a reduced minimum power reserve for flight 

in daytime VFR conditions was reasonable.

91.405 (a)

91.407 (a)(1)

91.409 (a)(1)(2)

91.417 (a)(b)

As discussed in exemption 11138 (DOUGLAS TRUDEAU), The petitioner 

proposes to inspect and ensure that the UAS is in a condition for safe flight 

in accordance to the operating documentation. The FAA found that 

adherence to the operating documentation and the conditions and 

limitations specified therein, describing the requirements for maintenance, 

inspection, and record keeping were sufficient to ensure that safety would 

not be adversely affected.

The UAS

The aircraft proposed by the petitioner is the DJI Flame Wheel 550. The 

DJI Flame Wheel 550 is a small rotorcraft in the hexacopter configuration 

with an advertised weight of 2400g designed primarily to carry aloft a high 

definition camera. It has an advertised diameter of 550mm and is powered 

by six electric motors. It uses an advanced flight stabilization system and 

GPS in order to accurately hold position. It also has altitude limiting 

software as well as a flight radius limiting function which prevents the 

aircraft from exceeding altitude and distance from ground station limits. 

There is a ‘return to home’ function as well. If communication with the 

aircraft is disrupted, the onboard computer will automatically send the 

aircraft back to its home position immediately where the pilot can attempt 

to regain link and arrange for a safe recovery of the aircraft. In addition, the 

PIC can initiate the return to home function by flipping a switch. The 
aircraft will be controlled primarily through a standard FCC certified model 

aircraft transmitter. Real time video and telemetry information are 

transmitted back to a ground control unit allowing the operator and 

observer to monitor battery level, GPS signal strength, altitude, distance 

from PIC, camera imagery and control camera angle. Battery life limits 

flight times to approximately 25 minutes or less. The onboard flight 

controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. 

Risk Mitigation

The petitioner has reviewed FAA exemptions reference's 13 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 UA airworthiness will be verified before 

launch. A visual observer will be utilized in order to provide a high level of 

situational awareness. Liability insurance will be obtained commensurate 

with the granting of this request for exemption. Airworthiness will be 

maintained by performance of routine inspections before each flight, 

maintaining flight and maintenance logs to record time on failure prone 

components. The petitioner requests that in a manner similar to reference 

3, he be allowed to operate within five miles of an airport provided that:

"The UA may not operate in class B, C, or D airspace without written 

approval from the FAA. The UA may not operate within five nautical miles 

of the geographic center of a non-towered airport 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 NOTAM as required by the operator's COA. The letter 

of agreement with the airport management must be made available to the 

Administrator upon request."

Operations within five miles of an airport are not anticipated to be routine 

but the petitioner is requesting a mechanism to facilitate such activities 

without requesting a new and separate exemption(s) should the need 

arise.

Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and 

reduce the environmental impact as compared to similar operations 
conducted with manned aircraft of greater proportions, carrying a crew and 

flammable fuel. Additionally, use of the UAS in order to facilitate commerce 

can lead to economic growth. Operations for this petition will enable 

service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired 

photographic subjects that cannot be displayed through ground level 

photography/videography. Aerial photography is a valuable marketing tool

that can lead to increased commerce and enhance personal photography. 

Crop surveying applications could lead to decreased use of pesticides and 

fertilizer and conservation of water as well as increased crop yields and 

decreased costs. Aerial surveying and inspections can increase worksite 

efficiency, improve volumetric estimations, and reduce risks. The petitioner 

will provide clients with photographic data for these purposes on a ‘for hire’ 

basis acting as an independent contractor. Flight data including UA flight 

time, control unit operation time, incident, accident, and details concerning 

any deviation from normal operations will be available to the FAA for use in 

collecting data regarding the use of UAS as part of this application. This 

data may be submitted to FAA via traditional means, e.g. COA Monthly 

Reports, or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of aerial 

photography, videography, mapping, crop surveying, inspections and other 

flight operations. The request for several uses of the UAS is to allow for 

future demand to be met without the need for additional exemptions to be 

filed. There is already a high demand for real estate photography, crop 

surveying, and aerial inspection of property. Use of a UAS would ultimately 

provide a tool that is far safer, more cost effective, and more timely than 

other methods. The primary purpose of seeking this exemption is to obtain 

the capability to offer those services while remaining in compliance with 

the FAA regulations.

Summary

The petitioner requests exemption for himself, Bradley C. Lorance, from 

Title 14, Code of Federal Rules pertaining to the safe, commercial usage 

of unmanned aerial systems (UAS) in controlled secured video and 

photographic production areas. Exemption from sections of CFR part 

61.113(a)(b), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 

91.409(a)(1), 91.409(a)(2), 91.417(a)(b) are requested. The petitioner 

supports his request with the following information. 1. Unmanned Aircraft 

System (UAS); this section describes the UAS capabilities and the failsafe 
mechanisms that are programmed into the UAS; 2. Risk Mitigation; this 

section describes proposed safety measures to be utilized in order to 

mitigate risk to persons and/or property including operational procedures 

and areas of flight to be taken into consideration; 3. Public Interest; this 

section outlines the advantages of UAS operations to both the particular 

customer and the population as a whole. 

Sincerely, 

Bradley Lorance