**Todd E Andrews (UAVKC) Belton, Mo –**

Section 333 Exemption Petition

December 1, 2015

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

Re **: Exemption Request Section 333 of the FAA Reform A ct of the Federal Aviation**  **Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a);**  **91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1);**  **91.409(a) (2); 91.417(a)&(b)**

**Dear Sir or Ma’am,**

**I,** Todd E Andrews (UAVKC) **, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained wit**  **hin 14 C.F.R. 11, to request that I,** Todd E Andrews (UAVKC) **, an owner and operator of small unmanned aircraft, be**  **exempted from the Federal Aviation Regulations (“FA Rs”) listed below so that I,**  Todd E Andrews (UAVKC) **, may operate my small ultra lightweight unmanned a ircraft system**  **(“UAS”) commercially in regulated airspace by the F ederal Aviation Administration (“FAA”).** 

**Following exemption and approval by the FAA, I,** Todd E Andrews (UAVKC) **, will primarily use my professionally built DJI Inspire 1**  **, DJI Phantom 3, and Custom built RSD X8 and RSD Y6 UAS equipped with cameras for the follow**  **ing applications: Closed-Set Film Operations on Film and Television Productions, as w**  **ell as Aerial Videography/ Cinematography to safely enhance Films and commerci**  **als; augmentation of real estate listing videos; and the creation of visual and topo**  **graphy layout videos for search and rescue (SAR) missions for state and local agencies, educat**  **ion, agricultural inspections and building and construction zone inspections.** 

**My,** Todd E Andrews (UAVKC) **’s, exemption request would permit the operation of ultra**  **lightweight, unmanned (i.e. piloted by remote contr ol) UAS’s for the development of**  **community and government use videos, permissible wi thin property boundaries for**  **individual homeowners and within in tightly control led, limited airspaces predetermined in**  **areas away from the general public, airports, helip orts and vehicular traffic. Currently, similar**  **lightweight, remote controlled UAS's are legally op erated by unmonitored amateur hobbyists**  **with no safety plan or controls in place to prevent catastrophe. Furthermore, it is my intent to**  **assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific**  **video and photography usage by sharing information with the FAA as I,**  Todd E Andrews (UAVKC) **, record flight data and other pertinent informatio n gained through permitted flight**  **operations.**

**In addition, granting my,** Todd E Andrews (UAVKC) **’s, exemption request will comply with the Secretary of Transportation’s (FAA Adminis**  **trator’s) instructions to not only integrate 2** 

**2 UAS's into the national airspace system, but to “..**  **.establish requirements for the safe operation of such aircraft systems [UAS's] in the n**  **ational airspace system” under Section 333(c) of the Reform Act specific to the us**  **e of UAS's for real estate/realtor purposes, educational videos, Search and Rescue, la**  **nd/trusts inspections, agricultural field monitoring, film/video productions, closed-set mot**  **ion picture film operations and television, and structure inspections, to aid state and local a**  **gency’s.**

**Further I,** Todd E Andrews (UAVKC) **, will conduct my operations in compliance with the protocols described herein or as otherwise establis**  **hed by the FAA. For the reasons stated below, I,**  Todd E Andrews (UAVKC) **, respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote co**  **ntrolled UAS’s to aid academic community awareness, to benefit/stimulate attractio**  **n to the Honolulu, Hawaii area and to enhance personal and public video feeds. A grant th**  **at will ultimately allow UAS’s to play a more positive role in our local community by increa**  **sing employment opportunities, heightening security measures and decreasing govern**  **ment expenditures by reducing the need for heavier manned aircraft, containing costly**  **, combustible fuel- a potential public**

**hazard in and of itself.**

I. Contact Information:

**Todd E Andrews**

**UAVKC**

**505 East 165 th**  **Street Belton, Mo 64012** 

**Phone: 816-529-8374 todd@uavkc.com** 

II. The Specific Sections of Title 14 of the Code o f Federal Regulations From Which Todd E Andrews (UAVKC) Requests Exemption are:

**A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Cer tificates, Manuals and The Like.** 

**14 C.F.R. 21, Subpart H, entitled Airworthiness Cer tificates, sets forth requirements for**  **procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The**  **size, weight and enclosed operational area of my,** Todd E Andrews (UAVKC) **’s, UAS’ permits exemption from Part 21 because my UAS meets**  **(and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act**  **. The FAA is authorized to exempt aircraft from the airworthiness certificate require**  **ment under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces**  **of legislation permit the FAA to exempt UAS's from the airworthiness certificate requiremen**  **t in consideration of the weight, size, speed, maneuverability and proximity to areas such**  **as airports and dense populations. My,** Todd E Andrews (UAVKC) **’s, current and projected UAS meet or exceed each o f the** 

**elements.**

**14 C.F.R. 91.7(a) prohibits the operation of an air craft without an airworthiness certificate.**  **As no such certificate will be applicable in the fo rm contemplated by the FARs, this**  **Regulation is inapplicable. 3** 

**3 14 C.F.R. § 91.9 (b) (2) requires an aircraft fligh**  **t manual in the aircraft. As there are no on board pilots or passengers, and given the size of t**  **he UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by m**  **aintaining a safety/flight manual delineating areas of where safety can be defined.**  **The FAA has previously issued exemptions to this re gulation in Exemption Nos. 8607, 8737,**  **8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 1060 2, 10700 and 32827.** 

**14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes**  **electronic global positioning systems with a barome tric sensor or controlled GPS**  **“geofencing”**

**14 C.F.R. § 91.203 (a) and (b) provides for the car rying of civil aircraft certifications and**  **registrations. They are inapplicable for the same r easons described above. The equivalent**  **level of safety will be achieved by maintaining any such required certifications and**  **registrations by me,** Todd E Andrews (UAVKC)

**.**

**B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require airc**  **raft to be marked according to certain specifications. My UAS can be marked with the appro**  **priate “N” number once this “N” number has been given.** 

**C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations.**  **Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial**  **operations. I,** Todd E Andrews (UAVKC) **, The sUAS Pilot in Command must possess at least a sport pilot certificate and a driver's lice**  **nse. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which t**  **he PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.** 

**D. 14 C.F.R. 91.119: Minimum Safe Altitudes.**

**14 C.F.R. § 91.119 prescribes safe altitudes for th e operation of civil aircraft. It allows**  **helicopters to be operated at lower altitudes in ce rtain conditions. My UAS will never operate**  **at an altitude greater than 300ft AGL; safely below the standard of 400 AGL. I,**  Todd E Andrews (UAVKC) **, will however operate my UAS in safe areas away fr om public and**  **traffic, providing a level of safety at least equiv alent to or below those in relation to minimum**  **safe altitudes. Given the size, weight, maneuverabi lity and speed of my UAS, an equivalent**  **or higher level of safety will be achieved.**

**E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.** 

**The above-cited Regulations require, amongst other things, aircraft owners and operators to**  **“have [the] aircraft inspected as prescribed in sub part E of this part and shall between**  **required inspections, except as provided in paragra ph (c) of this section, have discrepancies**  **repaired as prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft**  **with an airworthiness certificate. They will not, t herefore, apply to my,**  Todd E Andrews (UAVKC) **'s, UAS. However, as a safety precaution I inspect my UAS before and after each**  **flight. 4** 

**4** III. The Extent of relief Todd E Andrews (UAVKC) Se eks and the Reason He Seeks

Such Relief:

**I,** Todd E Andrews (UAVKC) **, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-**  **334, seeking relief from any currently applicable FARs operating to prevent me,**  Todd E Andrews (UAVKC) **, conducting commercial cinematic, academic and other flight ope**  **rations within the national airspace system. The Reform Act in Section 332 provides for**  **such integration of civil unmanned aircraft systems into our national airspace system**  **as it is in the public’s interest to do so. My,** Todd E Andrews (UAVKC) **’s, ultra lightweight UAS meets the definition of “ small** 

**unmanned aircraft” as defined in Section 331 and th erefore the integration of my ultra light**  **weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra**  **lightweight UAS prior to the time period by which t he Reform Act requires the FAA to**  **promulgate rules governing such craft. Thereby, pro viding direct experience and valuable**  **information for formal regulation that can be admin istered uniformly to all related UAS aerial**  **video and photography. The Reform Act guides the Se cretary in determining the types of**  **UAS's that may operate safely in our national airsp ace system. Considerations include: The**  **weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated**  **near airports or heavily populated areas; and, Whet her the UAS will be operated by line of**  **sight. 112 P.L. 95 § 333 (a).**

**Each of these items reflect in favor of an exemptio n for me,**  Todd E Andrews (UAVKC) **. My UAS’s utilize eight (8) or less rotating propellers**  **for balance, control and stability. My UAS’s are equipped with the following via video and data**  **telemetry:**

**1) Altimeter 2) Attitude indicator**  **3) Ground Speed indicator 4) Magnetic compass**  **5) Heading indicator 6) Vertical speed indicator**  **7) Course deviation indicator 8) Radio magnetic indicator**  **9) GPS location 10) Battery consumption and Battery Left with appro**  **ximate time. 11) Loiter and circle mode.**  **12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology.** 

**Each UAS weighing less than thirty** (35) **pounds (far below the maximum 55 pound limit); Including camera(s) with or without gimbal (a camer**  **a stabilizer). I,** Todd E Andrews (UAVKC) **, considers safety as foremost with each flight. My small unmanned aircrafts are**  **designed to hover in place, circle in a specific pl ace or loiter via GPS, and can be operated**  **in winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financial loss I will**  **not fly in winds exceeding 21.7 knots (25 mph). Bui lt in safety systems include a GPS mode**  **that allows my UAS to hover/circle in place or land when radio controls are released.** 

**With three (3) modes to choose from, I will fly wit h the modes safest to complete the videos**  **for aerial videography/photography and have the abi lity to choose the safest, most reliable**  **and stable mode to prevent accident and hazard. Whe n pilot communication from the radio**  **control is lost, UAS is designed slowly descend to point of takeoff and or to land at point of** **5**

**5 launch after ascending to a pre-set altitude to ens**  **ure the UAS will clear any obstacles that may be between the takeoff point and the current po**  **sition of the UAS. This failsafe altitude**

**will not be set more than 200ft and is determined b efore each flight.** 

**I,** Todd E Andrews (UAVKC) **, will not operate my UAS near airports, hospitals nor police**  **heliports, and do not operate near areas where gene ral public is within fifty to one hundred**  **(50-100) yards depending on location, conditions an d weather. I am constantly on alert for**  **any manned aircraft (police/medical helicopters, et c.) and prepared to land/abort**  **immediately to the nearest and safest ground point should a manned aircraft approach my**  **location or I suspect manned aircraft may approach near my location. My UAS’s are capable**  **of vertical and horizontal operations, and is flown only within my line of sight, as the remote**  **control pilot. My UAS's are also flown with a secon d operator who aids in watching for any**  **obstacles, including manned aircraft, within the fl ight zone of the UAS. Utilizing battery**  **power rather than combustible fuels, flights genera lly last between three (10) to fifteen (25)**  **minutes, with an altitude under one hundred fifty ( 150) feet. (3 )Smart Mode includes,**  **position hold, self-leveling, altitude command, GPS , return home feature, and safety control** 

**to return home or land in the event of communicatio n interruption between RC transmitter** 

**and UAS.**

**I,** Todd E Andrews (UAVKC) **, utilize a fresh fully charged battery with each f light as a**  **safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as**  **tested. I do not operate my UAS at or below manufac turer recommend minimum charge**  **levels for operation; preferring to remain well wit hin a safe operating range to insure**  **adequate communication between radio control and UA S to eliminate potential for crash,** 

**loss of control or hazard. Reserve batteries are at hand with each exercise to insure**  **replacement for sufficient safe level of operation. I do not believe in taking risk that may**  **cause a crash, that could create hazard to the publ ic/property/manned aircraft, and have no** 

**desire to lose an investment. I have clocked numero us practice flights in remote areas as a**  **hobbyist simulating flights for future commercial u se to gain familiarization with the**  **characteristics of this specific UAS's performance under different temperature and weather**  **conditions. I also practice computerized simulated flights to maintain adequate skills and**  **response reflex time. All for the sake of safety.**

**I,** Todd E Andrews (UAVKC) **, am extremely cautious when operating of my UAS/ul tra**  **lightweight unmanned aircraft and will not “create a hazard to users of the national airspace**  **system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it**  **falls well within Congress’s contemplated safety zo ne when it promulgated the Reform Act**  **and the corresponding directive to integrate UAS's into the national airspace system.**  Todd E Andrews (UAVKC) **’s UAS, used in hobby flight, has a demonstrable sa fety record and**  **does not pose any threat to the general public or n ational security.** 

IV. How Todd E Andrews (UAVKC)’s Request Will Benef it the Public as a Whole:

**Aerial videography for geographical awareness, edu cation, search and rescue, land**  **management, structure inspections and for real esta te marketing has been around for a long**  **time through manned fixed wing aircraft and helicop ters. For small budget companies,**  **average homeowners and property owners the expense of such aerial videography is cost**  **prohibitive. Only large companies and high end Real tors or luxury homeowners can afford to**  **absorb such expense; depriving non-luxury owners an d lower budget companies from a** **6**

**6 valuable marketing tool. Manned aircraft pose a thr**  **eat to the public through potential**

**crashes that the United States has experienced in the past with mili**  **tary aircraft, touring helicopters, and news helicopters crashes. Many of**  **them resulting in loss of life.**

**Each aircraft has combustible fuel that burns on i mpact adding to the already present**  **danger in the event of a crash. My,** Todd E Andrews (UAVKC) **'s, UAS poses no such**

**threat since size and lack of combustible fuel alle viates any potential threat to the public.**  **Congress has already proclaimed that it is in the p ublic’s interest to integrate commercially**  **flown UAS's into the national airspace system, henc e the passing of the Reform Act.** 

**Granting my,** Todd E Andrews (UAVKC) **’s, exemption request furthers the public interest through academic/visual awareness of the g**  **eographical benefits in and around the Honolulu area. My ultra light weight UAS is battery**  **powered and creates no emissions that can harm the environment. The consequence of my ult**  **ra light weight UAS crashing is far less than a full size helicopter or fixed wing airc**  **raft; which are heavy, contain combustible fuel and can cause devastation to the public. The p**  **ublic’s interest is furthered by minimizing ecological and crash threat by permitting aerial vi**  **deo/photo capture through my battery operated ultra lightweight UAS's.** 

**Permitting me,** Todd E Andrews (UAVKC) **, to immediately fly within national air space furthers economic growth. Granting my exemption req**  **uest substantially furthers the economic impact for the Honolulu and the surroundin**  **g community for companies looking to**

**relocate or build around Honolulu as well as indivi duals looking to relocate for career**  **advancement through academic and geographical aware ness. Both of which serve as a**  **stimulus to the community.**

V. Reasons Why Todd E Andrews (UAVKC)’s Exemption W ill Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

**My,** Todd E Andrews (UAVKC) **’s, exemption will not adversely affect safety. Qui te the**  **contrary, for the reasons stated permitting me,** Todd E Andrews (UAVKC) **, to log more flight time in FAA controlled airspace, with commun**  **ication with the FAA, will allow me to contribute to the innovation and implementation of**  **new and novel, as of yet undiscovered safety protocols for realtors, land, and structure**  **owners. For development in cooperation**

**with the FAA.**

**In addition I,** Todd E Andrews (UAVKC) **, submit the following representations of enhancements to current aerial videography and phot**  **ography: My UAS’s weigh between 6- 34 lbs. complete with batteries and cameras; I only**  **operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the**  **FAA Modernization and Reform Act of 2012); My UAS only operate for 8-30 minutes per fli**  **ght; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot**  **my UAS through remote control only by line of sight; and have live video feed for a se**  **condary pilot to monitor video recording; I receive a live telemetry feed from my UAS during al**  **l flights which include remaining battery voltage, distance, altitude, and any anomalies that**  **may occur during flight; My UAS’s Command and Control utilizes spread spectrum 2.4Ghz**  **-2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft**  **use; My UAS’s camera system utilizes 5.725Ghz-5.875Ghz frequencies in accordance with CF**  **R 47, Part 15; My UAS’s have a GPS controlled flight controller- a flight safety f**  **eature whereby it hovers or circles and then 7** 

**7 lands at the GPS takeoff point if communication wit**  **h the remote control pilot is lost; The DJI Inspire 1 and DJI phantom 3 UAS feature a flight co**  **ntroller app that actively records and analyzes flight data through that can be used to up**  **date and enhance safety protocols; I only operate in reasonably safe environments that are st**  **rictly controlled, are away from power lines, elevated lights, airports and actively popul**  **ated areas; I conduct extensive preflight inspections and protocols during which safety carri**  **es the utmost importance; I always obtain all necessary permissions prior to operation; and,**  **I have procedures in place to abort flights in the event of safety breaches or potential danger** 

**.**

**My,** Todd E Andrews (UAVKC) **’s, safety protocols provide a level of safety equa l to or**  **exceeding existing rules. It is important to note t hat absent the integration of commercial**  **UAS into our national airspace system, helicopters are the primary means of aerial video**  **and photography for community awareness real estate , structured inspections, land**  **management and search and rescue. While the safety record of such helicopters is**  **remarkably astounding, there have been local incide nts involving loss of life as well as**  **extensive property damage; it is far safer to opera te a battery powered lightweight UAS.**  **First, the potential loss of life is diminished bec ause UAS's carry no people on board and I**  **only operates my UAS in specific areas away from ma ss populations. Second, there is no**  **fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third,**  **the small size and extreme maneuverability of my UA S allow me to remotely pilot away from**  **and avoid hazards quickly and safely. Lastly, given its small size and weight, even when**  **close enough to capture amazing images, my UAS need not be so close to the objects they**  **are focused on through the technology and use of po st editing software allowing pan and**  **zoom. Accordingly, my UAS has been experimentally o perated for**  **familiarization/competency and will continue to ope rate at and above current safety levels.** 

VI. A Summary The FAA May Publish in the Federal Re gister

**In summary,** Todd E Andrews (UAVKC) **seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.2**  **3(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R**  **. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.**  **151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1);**  **14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b)**  **to commercially operate my,** Todd E Andrews (UAVKC)’ **s, small unmanned vehicle/lightweight unmanned airc raft vehicle in**  **community awareness, education, structural inspecti on land management, search and**  **rescue and real estate operations, and to develop e conomic platforms for the**  **aforementioned to enhance the experience of those s eeking to relocate, rebuild, reevaluate** 

**and to find in the Honolulu area.**

VII. Additional FAA Required Operating Conditions a nd Limitations

**When not covered elsewhere in this Operations Manua l, the following conditions and**  **limitations apply:**

**1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and**  **equipment**

**2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.** **8**

**8 3. Flights must be operated at an altitude of no**  **more than 500 feet above ground level (AGL), as indicated by the procedures specified in**  **the operator's manual. All altitudes reported to ATC must be in feet AGL.** 

**4. The UAS 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 visio n unaided by any device other than**  **corrective lenses, as specified on the PIC's state driver’s license.** 

**5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the**  **VLOS requirement, as long as the PIC always maintai ns VLOS capability. The VO and PIC**  **must be able to communicate verbally at all times.**

**6. If a discrepancy exists between these limitatio ns and any procedure outlined elsewhere**  **in this operations manual, the conditions and limit ations herein take precedence and must** 

**be followed.**

**7. Prior to each flight, the PIC must inspect the UAS to ensure 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 nec essary maintenance has been performed** 

**and the UAS is found to be in a condition for safe flight. The Ground Control Station, if**  **utilized, must be included in the preflight inspect ion. All maintenance and alterations must**  **be properly documented in the aircraft records.**

**8. Any UAS that has undergone maintenance or alte rations that affect the UAS operation**  **or flight characteristics, e.g. replacement of a fl ight critical component, must undergo a**  **functional test flight in accordance with the opera tor's manual. The PIC who conducts the**  **functional test flight must make an entry in the UA S aircraft records of the flight.** 

**9. The operator must follow the manufacturer's UA S aircraft/component, maintenance,**  **overhaul, replacement, inspection, and life limit r equirements. When unavailable, aircraft**  **maintenance/component/overhaul, replacement, and in spection/maintenance requirements**  **must be established and identified in the operator' s manual. At a minimum, the following**  **must be included in the operator's manual:**

**a. Actuators / Servos**

**b. Transmission (single rotor)**

**c. Powerplant (motors)**

**d. Propellers**

**e. Electronic speed controller**

**f. Batteries**

**g. Mechanical dynamic components (single rotor)**

**h. Remote command and control**

**i. Ground control station (if used) 9** 

**9 j. Any other components as determined by the oper**  **ator**

**10. The Pilot in Command (PIC) must possess at leas t a sport pilot certificate and at least a** 

**current state driver’s license. The PIC must also m eet the flight review requirements**  **specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.** 

**11. Prior to operations conducted for the purpose o f motion picture filming (or similar**  **operations), the PIC must have accumulated and logg ed, in a manner consistent with**  **14CFR § 61.51 (b), a minimum of 200 flight cycles a nd 25 hours of total time as a UAS**  **rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single**  **blade or multirotor). Prior documented flight exper ience that was obtained in compliance**  **with applicable regulations may satisfy this requir ement. Training, proficiency, and**  **experience-building flights can also be conducted u nder this grant of exemption to**  **accomplish the required flight cycles and flight ti me. During training, proficiency, and**  **experience-building flights, all persons not essent ial for flight operations are considered non**  **participants, and the PIC must operate the UAS with appropriate distance from non**  **participants in accordance with 14 CFR § 91.119.**

**12. Prior to operations conducted for the purpose o f motion picture filming (or similar**  **operations), the PIC must have accumulated and logg ed, in a manner consistent with**  **14CFR § 61.51 (b), a minimum of five hours as UAS p ilot operating the make and model of**  **UAS to be utilized for operations under the exempti on and three take-offs and three landings**  **in the preceding 90 days. Training, proficiency, ex perience-building, and take-off and**  **landing currency flights can be conducted under thi s grant of exemption to accomplish the**  **required flight time and 90 day currency. During tr aining, proficiency, experience-building,**  **and take-off and landing currency flights, all pers ons not essential for flight operations are**  **considered non-participants, and the PIC must opera te the UAS with appropriate distance**  **from non-participants in accordance with 14 CFR § 9 1.119.** 

**13. Prior to any flight operations authorized by th is grant of exemption, the PIC and visual**  **observer (VO) must have successfully completed a qu alification process, as outlined in the**  **operator’s manual. As this is a requirement stipula ted by the operator, the test must be**  **developed and implemented by a qualified person des ignated at the sole discretion of the**  **operator. A record of completion of this qualificat ion process must be documented and**  **made available to the Administrator upon request.**

**14. Prior to operations conducted for the purpose o f motion picture filming (or similar**  **operations), a flight demonstration, administered b y an operator-approved and -qualified**  **pilot must be successfully completed and documented . This documentation must be**  **available for review upon request by the Administra tor. Because the knowledge and**  **airmanship test qualifications have been developed by the operator, and there are no**  **established practical test standards that support a jurisdictional FAA FSDO evaluation and**  **approval of company designated examiners, the petit ioner will conduct these tests in**  **accordance with the operator’s manual.**

**15. The UAS may not be operated directly over any p erson, except authorized and**  **consenting production personnel, below an altitude that is hazardous to persons or property** 

**on the surface in the event of a UAS failure or eme rgency.** 

**16. Regarding the distance from participating perso ns, the operator’s manual has safety**  **mitigations for authorized and consenting productio n personnel. At all times, those persons** **10**

**10 must be essential to the closed-set film operations**  **. Because these procedures are specific to participating persons, no further FSDO or Aviati**  **on Safety Inspector (ASI) approval is necessary for reductions to the distances specified**  **in the petitioner’s manuals. This is consistent with the manned aircraft procedures desc**  **ribed in FAA Order 8900.1, V3, C8, S1**

Issue a Certificate of Waiver for Motion Picture an d Television Filming

**.**

**17. Regarding distance from non-participating perso ns, the operator must ensure that no**  **persons are allowed within 500 feet of the area exc ept those consenting to be involved and**  **necessary for the filming production. This provisio n may be reduced to no less than 200 feet**  **if it would not adversely affect safety and the Adm inistrator has approved it. For example, an**  **equivalent level of safety may be determined by an aviation safety inspector’s evaluation of**  **the filming production area to note terrain feature s, obstructions, buildings, safety barriers,**  **etc. Such barriers may protect non-participating pe rsons (observers, the public, news media,**  **etc.) from debris in the event of an accident. This is also consistent with the same FAA**  **Order 8900.1, V3, C8, S1.**

**18. If the UAS loses communications or loses its GP S signal, the UA must return to a pre**  **determined location within the security perimeter a nd land or be recovered in accordance**  **with the operator’s manual.**

**18. If the UAS loses communications or loses its GP S signal, the UA must return to a pre**  **determined location within the security perimeter a nd land or be recovered in accordance**  **with the operator’s manual.**

**19. The UAS must abort the flight in the event of u npredicted obstacles or emergencies in**  **accordance with the operator’s manual.**

**20. Each UAS operation must be completed within 30 minutes flight time or with 25%**  **battery power remaining, whichever occurs first.**

**21. The operator must obtain an Air Traffic Organiz ation (ATO) issued Certificate of Waiver**  **or Authorization (COA) prior to conducting any oper ations under this grant of**  **exemption. This COA will also require the operator to request a Notice to Airman (NOTAM)**  **not more than 72 hours in advance, but not less tha n 48 hours prior to the operation.** 

**22. All aircraft operated in accordance with this e xemption must be identified by serial**  **number, registered in accordance with 14 CFR part 4 7, and have identification (N-Number)**  **markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as**  **practicable.**

**23. The operator must develop procedures to documen t and maintain a record of the UAS**  **maintenance, preventative maintenance, alterations, status of replacement/overhaul**  **component parts, and the total time in service of t he UAS. These procedures must be added**  **to the operator’s manual.**

**24. Each UAS operated under this exemption must com ply with all manufacturer Safety** 

**Bulletins.**

**25. The operator must develop UAS technician qualif ication criteria. These criteria must be**  **added to the operator’s manual. 11** 

**11 26. The preflight inspection section in the operato**  **r’s manual must be amended to include the following requirement: The preflight inspection**  **must account for all discrepancies, i.e. inoperable components, items, or equipment, not cov**  **ered in the relevant preflight inspection sections of the operator’s manual.** 

**27. Before conducting operations, the radio frequen cy spectrum used for operation and**  **control of the UAS must comply with the Federal Com munications Commission (FCC) or**  **other appropriate government oversight agency requi rements.** 

**28. At least three days before scheduled filming, t he operator of the UAS affected by this**  **exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over**  **the area of proposed filming. The 3-day notificatio n may be waived with the concurrence of**  **the FSDO. The plan of activities must include at le ast the following:**  **a. Dates and times for all flights**

**b. Name and phone number of the person responsibl e for the UAS filming production**  **under this grant of exemption c. Name and phone number of the person responsibl**  **e for the on-scene operation of the**

**UAS. d. Make, model and serial or N-number of the UAS**  **to be used**

**e. Name and certificate number of the UAS PIC's i nvolved in the filming production event**  **f. A statement that the operator has obtained permi ssion from property owners and/or local**  **officials to conduct the filming production event; the list of those who gave permission must**  **be made available to the inspector upon request. g. Signature of exemption-holder or representativ**  **e**

**h. A description of the flight activity, includin g maps or diagrams of any area, city, town,**  **county, and/or state over which filming will be con ducted and the altitudes essential to**  **accomplish the operation**

**29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the**  **PIC at the ground control station of the UAS any ti me the aircraft is operating. These** 

**documents must be made available to the Administrat or or any law enforcement official**  **upon request.**

**30. The UAS must remain clear and yield the right o f way to all other manned operations**  **and activities at all times (including, but not lim ited to, ultralight vehicles, parachute activities,**  **parasailing activities, hang gliders, etc.).**

**31. UAS operations may not be conducted during nigh t, as defined in 14 CFR § 1.1. All**  **operations must be conducted under visual meteorolo gical conditions (VMC). Flights under**  **special visual flight rules (SVFR) are not authoriz ed.** 

**32. The UAS cannot be operated by the PIC from any moving device or vehicle.** 

**33. The UAS may not be operated less than 500 feet below or less than 2,000 feet**  **horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.** 

**34. The UAS may not operate in Class B, C, or D air space without written approval from the**  **FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered** **12**

**12 airport as denoted on a current FAA-published aeron**  **autical chart unless a letter of agreement with that airport’s management is obtaine**  **d, 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 th**  **e Administrator upon request.**

**35. Any 1) incident, 2) accident, or 3) flight oper ation that transgresses the lateral or vertical**  **boundaries of the operational area as defined by th e applicable COA must be reported to**  **the Federal Aviation Administration’s (FAA) UAS Int egration Office (AFS-80) within 24**  **hours. Accidents must be reported to the National T ransportation Safety Board (NTSB) per** 

**instructions contained on the NTSB Web site: www.nt sb.gov. Further flight operations may**  **not be conducted until the incident, accident, or t ransgression is reviewed by AFS-80 and**  **authorization to resume operations is provided.**

VIII. Conclusion

**Currently, the aforementioned aerial videography/p hotography relies primarily on the use**  **of larger aircraft running on combustible fuel. Pos ing potential risk to the public. Granting** 

**my,** Todd E Andrews (UAVKC) **’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craf**  **t do not contain potentially explosive fuel, is smaller, lighter and more maneuverable tha**  **n conventional video and photographic aircraft with much less flight time.** 

**Further, I operate at lower altitudes and in contr olled airspace eliminating potential public**  **risk flying to and from established airfields. I,** Todd E Andrews (UAVKC) **, have been informally analyzing and recording flight informati**  **on and will compile safety protocols and the implementation of a flight operations manual fo**  **r usage that exceeds currently accepted means and methods for safe flight. Formal collectio**  **n of information shared with the FAA will enhance the FAA's internal efforts to establish pro**  **tocols for complying with the FAA**

**Modernization and Reform Act of 2012. There are no personnel on board my,**  Todd E Andrews (UAVKC) **’s, UAS and therefore the likelihood of death or se rious bodily injury is**  **significantly diminished. My,** Todd E Andrews (UAVKC) **’s, operation of my UAS, weighing less than forty (40) pounds and traveling at lower**  **speeds within limited areas low to the ground will provide an equivalent level of safety a**  **s that achieved under current FARs. Accordingly I,**  Todd E Andrews (UAVKC) **, respectfully request that the FAA grant my exemption request and am willing to cooperate in sh**  **aring information to benefit the FAA, safety of manned aircraft, and the general public a**  **t large.**

**Respectfully submitted,**



# Todd E Andrews

Todd E Andrews **(UAVKC) Todd@uavkc.com** 

**505 East 165 th**  **Street Belton, Mo 64012** **13**

**13** Appendix A



### List of Aircraft

No. Make and Model Description Serial No. Registration

No.

1 **DJI InspireONE Electric powered, 4 rotor, small**
**unmanned multirotor helicopter W13DCI05** 

**040587 Pending** 



### 2 **DJI S1000 Electric powered, 8 rotor small**
**unmanned multirotor helicopter Ordered,** 
**Awaiting**

**arrival, will**
**update Pending** 

Aircraft 1: DJI INSPIRE ONE:
**The operation of the DJI INSPIRE ONE (the flight co ntroller operation manual is NOT explained** 
**in this letter but can be found in Appendix C, Sect ion 1).** 

**1. Build Materials**

**I. Plastic**

**II. Aluminum**

**III. Carbon Fiber**

**2. Motor Configuration**
**I. The DJI Inspire ONE achieves flight in a 4 motor quadcopter setup.** 

**3. Payload**
**I. The DJI INSPIRE ONE flies it’s own light-weight integrated camera.** 
**II. Maximum All-up weight- 6lbs**

**4. Maintaining the DJI INSPIRE ONE**
**I. Before each flight:**
**1. Check all hardware to ensure it is securely tigh tened.** 
**2. Check that the motor is level and locked in plac e.**  **3. Check the propeller to ensure it is tight and th ere are no visible signs of** 

**cracks, stress.**
**4. Check all wiring to motors, motor controllers, b atteries, and flight controller for** 
**signs of stress or frays.**
**5. Check all navigational lighting to ensure it is properly working.** **14**

**14 II. After 45 hours of flight** 

**1. Remove and check all motors and motor mounts for signs of wear and tear.** 
**Replace as necessary.**
**2. Remove motor controllers and visually inspect an d check for damage. Replace** 

**as necessary. 3. Remove flight controllers and visually inspect a**  **nd check for damage. Replace**
**as necessary, and/or chips. Replace the propeller i f questionable.** 
**4. Check for cuts, fraying, cracks, and/or loose/co ld solder connections. Fix** 
**before flying.**
**5. Check for updates to flight controller firmware. If available, install and perform** 
**a minimum of 15 test flights before conducting comm ercial work.** 

Aircraft 2: DJI S1000:
**The operation of the DJI S1000 multirotor system ar e as follows (the flight controller operation** 
**manual is NOT explained in this letter but can be f ound in Appendix C, Section 5).** 

**1. Build Materials**

**I. Carbon Fiber**

**II. ABS Plastic**

**III. Stainless Steel Hardware**

**2. Motor Configuration**
**I. S1000 configuration utilizing 8 motors. The moto rs are configured with 1 motors per** 

**arm, and a total of 8 arms.**

**II. In this configuration the DJI S1000 can handle up to two (2) motors failing and still be** 
**able to fly.**

**3. Payload**
**I. The DJI S1000 will carry the Freefly Systems MoV I M5, M10, or M15 camera gimbal.** 

**II. The cameras that will be flown on the DJI S1000 include, but are not limited to, Canon** 
**5DMKIII, Canon 1D-C, RED Epic, RED Dragon, and Sony FS700.** 
**III. Maximum All-up Weight- 34lbs**

**4. Maintaining the DJI S1000**
**I. Before each flight:**
**1. Check all hardware to ensure it is securely tigh tened.** 
**2. Check that the motor is level and locked in plac e.**  **3. Check the propeller to ensure it is tight and th ere are no visible signs of** 

**cracks, stress.**
**4. Check all wiring to motors, motor controllers, b atteries, and flight controller for** 
**signs of stress or frays. 15** 

**15 5. Check all navigational lighting to ensure it is**  **properly working.**

**II. After 45 hours of flight**
**1. Check all hardware to ensure it is securely tigh tened.** 
**2. Check that all motors are level and locked in pl ace.**  **3. Check all propellers to ensure they are tight an d there are no visible signs of** 
**cracks, stress, and/or chips. Replace if any propel ler is questionable.** 
**4. Check all wiring to motors, motor controllers, b atteries, and flight controller for** 
**signs of cuts, fraying, cracks, and/or loose/cold s older connections. Fix before** 
**flying.**
**5. Check all navigational lighting to ensure it is properly working.** 

**6. Remove and check all motors and motor mounts for signs of wear and tear.** 
**Replace as necessary.**
**7. Remove motor controllers and visually inspect an d check for damage. Replace** 

**as necessary. 8. Remove flight controllers and visually inspect a**  **nd check for damage. Replace**
**as necessary. Check for updates to flight controlle r firmware. If available, install** 
**and perform a minimum of 15 test flights before con ducting commercial work.** **16**

**16** Appendix B

Personal Protocols/Controls/Flight Manual

Protocols and Controls

TODD E. ANDREWS (UAVKC), Belton, Missouri.

**Safety for public on the ground as well as manned a ircraft above is an essential and utmost** 
**consideration for aerial videos and photography. As such, safety protocols and controls must be** 
**implemented through pre-flight preparation and duri ng flight. Pre-Flight Protocol:** 

**-Check batteries with voltage meter to insure fully charged and ready for use.** 

**-Inspect batteries for damage or leakage that may a ffect proper operation.** 

**-Inspect propellers for cracks, chips or damage tha t may cause sudden loss of propulsion or** 
**unmanageable/uncontrolled flight.**

**-Check all GPS and Telemetry connections prior to f light.** 

**-Check weather forecasts for wind advisory or other conditions that my impact flight.** 

**-Consult Sky Vector aeronautical Charts (Skyvector. com) for airport vicinity and flight paths of** 
**possible air traffic.**

**Contact respective airport to advise of estimated f light time, estimated flight duration, estimated** 
**elevation of flight, and any other pertinent inform ation.** 

Inspect flight area for
**Vicinity of public safety helipads/heliports**
**Vicinity of medical helipads/heliports**
**Vicinity of light poles vicinity or utility wires**
**Vicinity of trees flocks of birds that may cause in terference and potential flight impact** 
**Vicinity of any elevated obstructions that may pose potential flight hazard** 
**Vicinity of roadways with moderate to heavy traffic that can distract the public** 
**Gatherings that may attract viewers optional point of control for best visual site of UAS** 
**while in flight**
**Emergency landing areas**

Takeoff and landing

**Inspect area for best and safest point of takeoff a nd landing** 

**If in a subdivision or area that is within 150 feet of a residential street, post warning** **17**

**17 Sign(s)/stand(s) "Attention Aerial Photography In P**  **rogress, Remain Back 150 Feet "**

Flight Protocol: **takeoff and land from same location have alternate landing areas in case of** 
**emergencies) remain alert to birds, sound or aircra ft, curious public, and approaching vehicles** 
**do not allow anyone to engage in conversation or di stract the remote control pilot restrict flight to** 
**minimal elevation sufficient to acquire desired res ults remained prepared for emergency landing** 
**at all times pay attention to flight time – warning meter for low voltage.** 

**Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut** 
**down propulsion immediately following landing – pri ority of disconnecting batteries** 

Post flight:

**1. Disconnect battery to prevent accidental activat ion of propulsion system** 

**2. Secure UAS in a safe location**

**3. Remove all warning signs from public access area s** 

**4. Emergency or Suspected Hazard:**

**Immediate land UAS at safest and closet ground loca tion in the event** 

**Manned aircraft is heard or seen in vicinity of fli ght** 
**There is a public gathering within established safe ty boundary wanting to observe flight** 
**Pilot is being distracted from focusing on flight a nd safety** 
**Sudden change in weather (wind bursts)**
**Sudden increase in vehicular traffic in vicinity of flight** 
**Birds enter into proximity of flight**
**Any sudden unsafe event that can cause collision, d istraction or interruption of control** 

**Safety for public on the ground as well as manned a ircraft above is an essential and utmost** 
**consideration for aerial videos and photography.**

**Maintaining a record of safe flight for FAA request and for determining future UAS safety** 
**protocols is imperative. 18** 

**18** Sample Flight Log Recorded:

**Date:____________________ Time: ______________**

**Location:__________________________________________**

**_________**

**Pre-flight Inspection: ____ Yes _____ No**

**Comment: __________________________________________**

**_______**

**Elements**

**Proximity to airport: _______________ (attached map pinpointing approximate location of flight)** 

**Airport notified: ____ Yes _____ No Phone Number: _______________________** 

**Contact Name:___________________________________**

**Nearest major intersection: _______________________**

**_______________________________**

**Proximity to medium traffic road: _________________**

**_________________________________**

**Proximity to heavily traveled roadway road: _______**

**__________________________________**

**Proximity to congested population: ________________**

**________________________________**

**Approx. Local Takeoff Time: ______________ GMT: ___**

**_______**

**Weather Good Fair Poor Comment: ___________________**

**____________________________**

**Visibility Good Fair Poor Comment: ________________**

**_______________________________**

**Wind Speed: ___mph ___Gusts/MPH ___avg/MPH Comment : _________________________** 

**Approx. Landing Time: ______________ GMT: _________**

**_**

**Estimated Elevation Ground level: ____________ Elev ation Above Sea Level: _____________** 

**Safety Concerns: __________________________________**

**____________________________**

**Additional Comments: ______________________________**

**____________________________ 19** 

**19** TODD E. ANDREWS (UAVKC), Belton, Missouri.

Appendix C



### Aircraft Manuals

**This Appendix includes UAS manufacturer's user manu als, maintenance instructions, and**  **illustrated parts catalogs. These manuals may be at tached to the docket when submitted.**  **Information regarding design, aircraft performance, fail-safe features, operating limitations,**  **normal and emergency procedures, and maintenance an d inspection procedures is contained**  **within the manuals and supplemental information doc uments listed below:** 

**1. DJI Inspire Manual V1.8 https://www.dji.com/product/inspire-1/download** 

**2. Inspire 1 Maintenance Manual v1.0**  **https://www.dji.com/product/inspire-1/download**

**3. Intelligent Flight Battery Safety Guidelines v 1.4**  **https://www.dji.com/product/inspire-1/download**

**4. Inspire 1 Safety Guidelines https://www.dji.com/product/inspire-1/download** 

**5. DJI S1000 Professional Manual V1.0 http://dl.djicdn.com/downloads/s1000/en/S1000_User**  **_Manual_v1.10_en.pdf**

**For more information or questions about any of the above listed information and manuals please** 

**contact:**

Todd E Andrews

505 East 165th Street

816-529-8374
todd@uavkc.com