August 19, 2015

Exemption No. 12532 Regulatory Docket No. FAA

– 2015

– 1921

Mr. Philip Madison
208 Anita Drive Paducah, KY 42003

Dear Mr. Madison :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitati ons of the exemption, including the date it ends.

By letter s dated May 13 and July 30, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption. The petitioner requested to operate an unmanned
ai rcraft system (UAS) to conduct aerial data collection for aerial videography and cinematography

.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom and DJI Phantom 3

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in
reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation
has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA2

finds that the relief from 14 CFR par t 21

, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No . FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in a ll material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by th e Administrator, Mr. Philip Madison is granted an exemption from
14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to
the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Philip Madison is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by
instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exempt ion are limited to the DJI Phantom and
DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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 or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS req uirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and c annot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outli ned 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 revised4

documents to the Administrator or any law enforcement official upon req uest. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exempt ion, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenan ce or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may onl y be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all pote ntial discrepancies, e.g.

, inoperable components, items, or equipment. 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
U AS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and
aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a
current FAA airman medical certificat e or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which th e PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasi ve and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of trainin g the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this e xemption. However, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC mu st operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as
denoted in the curre nt FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwi se permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct th e intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must b e identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 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 time the aircraft is operating.
These documents must be made available to the Adminis trator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UA and/or debris in the event of an accident. T he 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 in a manner ensuring the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property wi th permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that trans gresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FA A'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.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditio ns and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a w ritten Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities
must include at least the fo llowing:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the lis t of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over wh ich filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in t he exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption termi nates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely,
/ s/
John S. Duncan Director, Flight Standards Service

EnclosuresPhilip	Madison

208	Anita	Drive Paducah,	KY	42003

270.392.1952

May	13,	2015

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

Re:	Exemption	Pursuant	to	Section	333

To	whom	it	may	concern;

I	am	seeking	relief	from	the	following	portions	of	14	CFR’s:

91.7(a) 91.119(c)

91.121 91.151(a) 91.405(a) 91.407(a)(1) 91.409(a)(1)&(2) 91.417(a)&(b)

I	intend	to	operate	the DJI	Phantom	1	and DJI	Phantom	3	Professional “ quad

- copter style ” unmanned	aircraft	system s (UAS)	in	the	western	Kentucky	region	for	the	purpose
of aerial	data	collection to	produce images/video	for	use	in aerial

v ideography/cinematography	and	augmenting	real	estate	listing	videos	(or	s imilar operations) ,	commercial adv ertisings,	educational	videos,	industrial	training/safety programs	and	educational	products.

As	for	my accreditations with	model	aircraft,	I am	a	current	and active	member	in	the Academy	of	Model	Aeronautics	(AMA)	since March	9,	2005	and	hold	a	AMA	Turbine Waiver	(#FW	9880)	for	fixed	wing	turbine	powered	aircraft	since	September	12,	2008. Over	the	past	several	years	I	have	also	earned	the	status	of	Contest	Director	for	the AMA	and	held	the	responsibility	of	numerous	model	aircraft	events	with	zero	incident s.

I	am	currently	employed	in	the	video	production	industry,	with	over	16	years	on	the	job experience	in	all	aspects	of	video	production. It	is	my intent to	include	the	products	of aerial	videography	and	cinematography	from	the	UAS	platform	into	current production work.		Throughout	the	past	two	years	I	have	practiced	at	the	hobby/recreation	level	UAS2 activities	with	the	DJI	Phantom	1	platform	and	have	accumulated	more	than 40+	hours of	flight	time,	WITHOUT	INCIDENT.

Following	are	the	justifications	as	to why	I	am	seeking	relief	from	each	section:

91.7(a)

– It	is	my	understanding	that	no	FAA	regulation	standard	exists	for	determining the	airworthiness	of	the	UAS	I	intend	to	operate,	the	regulation	is	inapplicable.

91.119(c)

– The	intended	operations	unde r	this	exemption	would	need	to	occur	at
altitudes fewer	than	400	feet	and	closer	than	500	feet	to	person,	objects	or	structures.

91.121

– The	manufactured	platform	intended	uses	a	barometric	altimeter,	GPS	derived
altitude	and	ultrasonic	reference	relativ e	to	ground	capabilities	to	establish	altitude while	the	FAA	requires	any	altitude	reported	to	be	in	feet	AGL.

91.151(a)

– The	manufactured	system	does	not	have	the	ability	to	adhere	to	this regulation.

91.405(a)

– This	section	does	not	apply	to	UAS.

91 .407(a)(1)

– This	section	does	not	apply	to	UAS.

91.409(a)(1)&(2)

- This	section	does	not	apply	to	UAS.

91.417(a)&(b)

- Thi s	section	does	not	apply	to	UAS,	however	it	is	my	intent	to	keep	a flight	log	with	basic	information	about	each	activity/flight	of the	UAS	involved.

It	is	my	intent	to	comply	with	the	following	conditions	of	UAS	operations	for	the

purpose:

1. All	operations	authorized	by	this	gran t of exemption	are	limited	to	the	platform
aircraft	as described in	their	respective	operating	guidelines	and	documents	from	the
manufacturers for	the	DJI	Phantom	1	and	DJI	Phantom	3	Professional.

2.		Each	aircraft	will	NOT	exceed	55	pounds	in	weight. (Estimated	approximate	weight for	each individual aircraft	is	less than	4.5	pounds.)

3.		The	UAS	will	not	fly	in	excess	of	an	indicated	airspeed	of	35	knots.

4.		The	UAS	will	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.

5. UAS	operations	may	not	be	conducted	during	night,	as	defined	in	14	CFR	1.1.	All operations	must	be	conducted	under	visual	meteorological	conditions	(VMC). All	UAS3 operations	will	be	conducted	during	a	minimum	of		“fair”	weather	situations	deemed
safe by	the	operator.

6 .		The	UAS	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	Pilot	In	Command (PIC)	at	all	times. This	requires	the	PIC	to	be	able	to	use	human	unaided	vision	by	any
device	other	than	corrective	lenses.

7

. ALL	operations	must utilize	a	visual	observer	(VO).		The	UAS	will	be	operated	within the	VLOS	of	the	VO	at	all	times.		The	VO	may	be	used	to	satisfy	the	VLOS	requirement	as long	as	the	PIC	always	Maintains	VLOS	capability.		The	VO	and	PIC	must	be	able	to communicate	verbally at	all	times.		The	PIC	must	be	designated	before	the	flight	and cannot	transfer	the	designation	for	the	duration	of	the	operation.		The	PIC	must	ensure that	the	VO	is	capable	to	perform	the	functions	prescribed.

8

. The	operating	documents	and	this	grant of	exemption	must	be	accessible	during	UAS operations	and	made	available	to	the	Administrator	upon	request.	lf	a	discrepancy	exists between	the	conditions	and	limitations	in	this	exemption	and	the	procedures	outlined	in the	operating	documents,	the	condit ions	and	limitations	herein	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.	lt	is the	operator's	responsibility	to	t rack	such	revisions	and	present	updated	and	revised
documents to	the	Administrator	upon	request.	The	operator	must	also	present	updated and	revised	documents	if	he	petitions	for	extension	or	amendment	to	this	grant	of exemption.	lf	the	operator	determines that	any	update	or	revision	would	affect	the basis	upon	which	the	FAA	granted	this	exemption,	then	the	operator	must	petition	for amendment	to	its	grant	of	exemption.	The	FAA's	UAS	lntegration	Office	(AFS

- 80)	may	be contacted	if	questions	arise	regarding	u pdates	or	revisions	to	the	operating	documents.

9. Prior	to	each	flight,	the	PIC	must	inspect	the	UAS	to	ensure	it	is	in	a	condition	for	safe flight.	lf	the	inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the UAS	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	documente d	in	the	aircraft	records.

10. Any	UAS	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	fl ight	must	make	an	entry
in	the	aircraft	records.

11. The	operator	must	follow	the	UAS	manufacturer's	aircraft/component, maintenance,	overhaul,	replacement,	inspection,	and	life	limit	requirements.

12. The	operator	must	carry	out	its	maintenance,	inspe ctions,	and	record	keeping requirements,	in	accordance	with	the	operating	documents.	Maintenance,	inspection,4 and	alterations	must	be	noted	in	the	aircraft	records,	including	total	flight	hours, description	of	work	accomplished,	and	the	signature	of	the	au thorized	person	returning
the	UAS	to	service.

13. Each	UAS	operated	under	this	exemption	must	comply	with	all	manufacturer	Safety
Bulletins.

14. The	UAS may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	as
denoted	on	a	current	FAA

- published	aeronautical	chart.

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

16.		I f	the	UA S loses	communications	or	loses	its	GPS	signal,	it	must be	designed	to
return	to	a	pre

- determined	location	within	the	planned	operating	area	and	land	or	be recovered	in	accordance	with	the	operating	docu ments.

17.		T he	PIC	must	abort	the	flight	in	the	event	of	unpredicted	obstacles	or	emergencies in	accordance	with	the	operating	documents.

18. 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	UA S with 25 %	battery	power	remaining.

19. All	aircraft	operated	in	accordance	with	this	exemption	must	be	identified	by manufacturers	applied	and	recorded	serial number.

20. Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	and
control	of	the	UA S must	comply	with	the	Federal	Communications	Commission	(FCC)	or other	appropriate	government	oversight	agency	requirements.

21.		Documents	re lating	to	the	manufactures	operating	manual,	usage	guide, maintenance	recommendations	and	granted	exemption	notice	must	be	available	to	the PIC	at	all	times.		These	documents	must	be	made	available	to	the	Administrator	or	any law	enforcement	official	upon request.

22.		T he	UAS	must	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation operations	and	activities	at	all	times.

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

24. The	UA	may	not	be	operated	over	congeste d	or	densely	populated	areas	without prior	notice	of	activity	and	purpose	to	responsible	party	involved.

25. All	operations	shall	be	conducted	over	private	or	controlled

- access	property	with permission	from	the	land	owner/controller	or	authorized	represen tative.	Permission5 from	land	owner/controller	or	authorized	representative	will	be	obtained	for	each operation to	be	conducted.

26.		The	operator	must	have	a	motion	picture	and	television	operations	manual (MPTOM)	as	documented	in	this	grant	of	exemption.

27.		At	least	3	days	before	aerial	filming,	the	operator	of	the	UAS	affected	by	this exemption	must	submit	a	written	Plan	of	Activities	to	the	local	Flight	Standards	District Office	(FSDO)	with	jurisdiction	over	the	area	of	proposed	filming.	The	3

- day	no tification may	be	waived	with	the	concurrence	of	the	FSDO.	The	plan	of	activities	must	include	at least	the	following:

1. Dates	and	times	for	all	flights;

2. Name	and	phone	number	of	the	operator	for	the	UAS	aerial	filming	conducted under	this	grant	of	exempti on; 3. Name	and	phone	number	of	the	person	responsible	for	the	on

- scene	operation of	the	UAS;

4. Make,	model,	and	serial	or	N−Number	of	UAS	to	be	used;

5. Name	of	UAS	PICs	involved	in	the	aerial	filming;

6. A	statement	that	the	operator	has	obtained	permission	fro m	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;

7. Signature	of	exemption	holder	or	representative;	and

8. A	description	of	the	flight activity,	including	maps	or	diagrams	of	any	area,	city, town,	county,	and/or	state	over	which	filming	will	be	conducted	and	the altitudes	essential	to	accomplish	the	operation.

28. Flight	operations	may	be	conducted	closer	than	500	feet	from	participating	persons consenting	to	be	involved	and	necessary	for	the	filming	production,	as	specified	in	the exemption	holder’s	MPTOM.

2 8

. Any	incident,	accident,	or	flight	operation	that	tran sgresses	the	lateral	or	vertical boundaries	of	the	operational	area	as	defined	by	the	within	this	operational	exemption must	be	reported	to	the	FAA's	UAS	lntegration	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.gov.6 Along	with	this	petition,	I	submit	the	following	for	review	as	indicators	for	operation	of the	UAS	prescribed	for	approval	in	this	exemption:

- DJI Phantom	Flying	Flow	Chart

- DJI	Phantom	Quick	Start	Manual

- DJI	Phantom	User	Manual

- DJI	Phantom	3	Professional	Quick	Start	Guide

- DJI	Phantom	3	Professional User	Manual

- Proposed Motion	Picture	and	Television	Flight	Operation	Manual

If	more	information	o r	documentation	is	needed	to	approve	this	exemption for	the
intended	use	of	the	UAS ,	please	contact	me	at	270.392.1952.

Thank	you,

Philip	MadisonPhilip	Madison

208	Anita	Drive Paducah,	KY	42003

270.392.1952 July	30,	2015

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

Re: Additional	Information	Requested	for	Docket FAA

- 2015

- 1921

To	whom	it	may	concern;

Pursuant to	the	FAA	Modernization	and	Reform	Act	of	2012	I	am writing in	request	for an	exemptions	from	the	current	Federal	Aviation	Regulations	(“FARs”)	listed	below	so that	I	may	operate	small	ultra	light	weight	unmanned	aircraft	system	(“UAS”) commercially	in airspace	regulated	by	the	Federal	Aviation	Administration	(“FAA”).		I believe	that	such	activity	is	already	occurring	by	“unauthorized”	operators	and	it	is	my goal	to work with	the FAA	through	this exemption request	to	operate	within	the
constraints	of	the	current	FAR

.

I	have	over	15+	years	experience	in	televis ion/film	production	as	well	as	10+	years experience	in	remote	control	models,	all	without	incident.		The	opportunity	to integrate
such	UAS aerial	platforms	in	a	safe	and	controlled	manor	through	this	exemption,	if approved,	will aid	in	the	developm ent	of	an	already “ booming ” media industry.

Data	collected	by	the	operation	o f	this	exemption	is	intended	for	use	as	images/video for	videography/cinematography,	real	estate, web

- based	videos/websites, commercial advertisings,	educational	videos,	training/safety	videos and	potentially	search	and rescue	operations	if	necessary	and	requested	by	local	area	agen cies.

PUBLIC	GOOD

With	this	exemption	I	plan	to	provide	a	plat form	for	aerial	data/imaging	in	a	manor	that is	not	cost	prohibitive	as	has	been	historically	with	manned	aircraft.		Congress	has already	decided	that	it	is	in	the	public’s	interest	to	integrate	commercially	flown	UAS into	the	national	airspace	system	and passed	the	Reform	Act.

Aerial	videogr aphy	for	geographical	awareness, real	estate	marketing and	video production has	been	around	for	a	long	time	through	manned	fixed	wing	aircraft	and helicopters.	But	for	small	business	owners,	its	expense	has	been	cost-pr ohibitive. Granting	this	exemption will allow me to	provide	this	service	at	a	much	lower	cost.Further,	the	small	UAS	being	utilized	in	this	application	will	pose	no	threat	to	the	public given	its	small	size	and	lack	of	combustible	fuel	when	compared	to	l arger	manned
aircraft. The	UAS	is	battery	powered	and	creates	no	emissions	that	can	harm	the

environment. The	operation	of	this	UAS	will	minimize	ecological	damage	and	promote economic	growth	by	providing video	based information	to	businesses	&	individual s	in
the a rea.

This	exemption,	if	granted,	will	also	further	economic impact	for	the	area	by	providing an	opportunity	for	companies	looking	to	build	and	individuals	looking	to	relocate	for careers	to	have	information	available	to	them	through	academic	and geographical awareness.		These	serve	as	a	stimulus	to	the	community.

CONCLUSION

Finally,	I	am	requesting	this	exemption	to	perform	safe	operations	of	the	listed UAS	at
low

- level	altitudes	and	only	around	those	completely	informed	and	agreed	upon	the operation,	thus	virtually	eliminating	the	potential	risk	to	the	public.		The	systems	that	I operate	keep	very	accurate	data	logs	that	will	also	allow	me	to	constantly evolve	my personal	guidelines	under	this	exemption	and	be	information	that	can	eventually	be transferred	along	to	the	FAA	for	review	in	efforts	to	enhance	the	efforts	on	future protocols	in	complying	with	the	FAA	Modernization	and	Reform	Act	of	2012.

The UAS	platforms	I	intend	to	operate	have	no	personnel	on	board,	and	therefore	any
likelihood of	death	or	serious	injury	is significantly diminished.

All	UAS	used	are	very	lightweight	and	operated	at	very	low	speeds	within	limited	areas, which	again	provide s	a	great	level	of	safety.

I	hope to	operate	the	UAS	in	a	safe	manor and	to	utilize	such	a	platform	in	the
advancement	of	aerial	data	collection. If	more	information	or	documentation	is	needed to	approve	this	exemption for	the intended	use	of	the	UAS ,	please	contact	me	at

270.392.1952.

Thank	you,

Philip	Madison