Ryan	Roberts	Videography

3616	CR	192	East Kilgore,	TX	75662 903/746

- 2942

Email

- RRobertsvideo@gmail.com

Docket Management Facility c/o US Department of Transportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

Petition of	Ryan Roberts	Videography,

For Exemption	Pursuant	to	Section	333

Of the	FAA	Modernization	and	Reform	Act	of	2012

Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of 2012	and	14 CFR	Part	11,	Ryan	Roberts	Videography	is	hereby	requesting	an	exemption	from	the listed	Federal	Aviation	Regulations	to	operate	a	small	Unmanned	Aircra ft System	for the	purpose	of	recording	photography	and	videography	for	compensation	or	hire. This	exemption	would	permit	commercial	operation	by	Ryan	Roberts	Videography, using	a	DJI	Phantom	3	Advanced	UAS	in	order	to	provide	the	following	services:

• Real estate	advertising

• Land surveying

• Agricultural surveying

• Commercial advertisement

• Personal event	photography	and	videography

• Commercial event	photography	and	videography

Ryan	Roberts	Videography’s	operation	under	the	exemption	will	be	subject	to	strict operating	requirements	and	conditions	to	ensure	an	equivalent	level	of	safety	to currently	authorized	operations	using	manned	aircra ft and	under	conditions	as	may be	modified	by	the	FAA	as	required	by	Section	333. Ryan	Roberts	Videography	respectfully	submits	this	request	for	an	exemption	due to	its	use	of	sUASs/UASs.	Approval	of	this exemption	would	enhance	safety	and fulfill	the	Secretary	of	Transportation’s	responsibilities	under	Section	333(c)	of	the Reform	Act	to	“establish	requirements	for	the	safe	operation	of	such	aircra ft systems	in	the	national	airspace	system.” Ryan	Roberts	V ideography	has	organized	this	exemption	request	as	follows:I.	Petitioner’s	Description II.	Relevant	Statutory	Authority III.	Qualifications	for	Approval	Under	Section	333	of	the	Reform	Act IV.	Description	of	Proposed	Operations V.	Regulations	from	which Exemption	is requested

VI.	Public	Interest VII.	Privacy VIII.	Federal	Registry	Summary

IX.	Conclusion

I.	Petitioner’s	Description Ryan	Roberts	Videography,	located	in	Kilgore,	TX,	is	a	company	that	provides	aerial drone	footage	for	consumers	and	busine sses	alike.	The	services	we	provide	include

but	are	not	limited	to:

• Real estate	advertising

• Land surveying

• Commercial advertisement

• Personal event	photography	and	videography

• Commercial event	photography	and	videography

Ryan	Roberts	Videography’ s	goal	is	to	operate	in	an	accident

- free	environment while	serving	our	community. Ryan	Roberts	Videography	is	owned	&	operated	by	myself	with	over	5	years	of combined	UAS/UAV/Drone	experience:

Ryan	Roberts

3616	CR	192	East Kilgore,	TX	75662 (903)	746

- 2942 rrobertsvideo@gmail.com

II.	Relevant	Statutory	Authority This	petition	for	exemption	is	submitted	to	fulfill	Congress’	goal	in	passing	Section 333(a)	through	(c)	of	the	Reform	Act.	Congress	has	directed	the FAA	“to	safely accelerate	the	integration	of	civil	unmanned	aircra ft systems	into	the	national airspace	system.”	Pursuant	to	Section	333	of	the	Reform	Act,	the	FAA	Administrator

is	to	consider	whether	certain	unmanned	aircra ft systems	may	operate	safely	in the National	Airspace	(“NAS”)	before	completion	of	formal	UAS	legislation,	based	on	the following	considerations: •	The	UAS’s	size,	weight,	speed,	and	operational	capability; •	Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas •	Ope ration	of	the	UAS	within	the	visual	line	of	sight	of	the	operator. If	the	Secretary	determines	that	such	vehicles	“may	operate	safely	in	the	National Airspace	System,	the	Secretary	shall	establish	requirements	for	the	safe	operation	of

such	aircra ft in	the National	Airspace	System.”Additionally,	the	FAA	Administrator	has	general	authority	to	grant	exemptions	from its	safety	regulations	and	minimum	standards,	and	has	done	so	on	numerous occasions,	when	the Administrator	decides	a	requested	exemption	is	in	t he	public	interest.	A	party requesting	an	exemption	must	explain	the	reasons	why	the	exemption:	(1)	would benefit	the	public	as	a	whole,	and	(2)	would	not	adversely	affect	safety	(or	how	it would	provide	a	level	of	safety	at	least	equal	to	the	existing	rul es). The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue exemptions.	This	statutory	authority,	by	its	terms,	includes	exempting	civil	aircra ft

, as	the	term	is	defined	under	40101	of	the	Act,	from	the	requirement	that	all	civil

aircra ft must	have	a	current	airworthiness	certificate	and	those	regulations requiring	commercial	pilots	to	operate	aircra ft in	commercial	service: The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation prescribed	under	subsection	(a)	or	(b)	o f	this	section	or	any	of	sections.

III.	Qualifications	for	Approval	Under	Section	333	of	the	Reform	Act The	proposed	operations	in	this	petition	for	exemption	qualify	for	expedited approval	under	Section	333	of	the	Reform	Act.	Each	of	the	statutory	criter ia	and

other	relevant	factors	are	satisfied. The	proposed	operations	would	p ermit	Ryan	Roberts	Videography the	use	of	small

unmanned	aircra ft systems	under	controlled	conditions	in	airspace	that	is:	(1) predetermined;	(2)	access	controlled;	(3)	enhanced	wi th	an	increased	level	of	safety beyond	that	existing	when	fixed	or	rotor	wing	aircra ft are	used	to	accomplish	the

same	purpose. Ryan	Roberts Videography uses	a	UAS	(DJI	Phantom	3	Advanced)	that	is	multi

- rotor, weighing	less	than	55	pounds,	including	payloa d.	Under	normal	conditions,	it operates	at	speeds	less	than	50	mph	and	has	the	capability	to	fly,	hover,	and	move	in the	vertical	and	horizontal	p lane.	Ryan	Roberts	Videography’s UASs	will	operate	in line	of	sight,	during	daylight	hours,	and	will	only	oper ate	within	a	sterile area.	Ryan Roberts	Videography will	operate	at	or	below	400	feet	above	ground	and	will	file	a NOTAM	for	each	flight	operated	in	controlled	airspace.	All	required	permissions	and permits	would	be	obtained	from	territorial,	state,	county ,	or	city	jurisdictions, including	local	law	enforcement,	fire,	or	other	appropriate	governmental	agencies prior	to	operating	a	UAS.

Given	the	small	size	of	the	UAS’s	involved	and	the	restricted	sterile	environment within	which	they	will	ope rate,	Ryan	Robe rts	Videography ’s	exemption	falls	within the	zone	of	safety	and	demonstrates	an	equivalent	level	of	safety,	in	which	Congress desired	the	FAA	to	permit	commercial	UAS	operations	by	exemption	pending	the completion	of	formal	legislation.	Also,	due	to	the	si ze	of	the	UASs	and	the	confined area	in	which	they	will	operate,	approval	of	the	exemption	presents	no	hazard	in	the National	Airspace	System. Considering	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority

contained	in	the	Federal	Aviation Act,	as	amended,	the	equivalent	level	of	safety surrounding	the	proposed	operations,	and	the	significant	public	benefit,	the	grant	of the	requested	exemptions	is	also	in	the	public	interest.IV.	Description	of	Proposed	Operations

To	assist	the	FAA	in	its safety	assessment	of	Ryan	Roberts	Videography,	’s	proposed UAS	operations,	below	is	a	summary	of	operational	limitations	and	conditions	that will	ensure	an	equivalent	or	higher	level	of	safety	to	operations	conducted	under current	regulatory	guidelines:

1.	The UAS will weigh less than 55 pounds, 2.	Flights will be operated within line of sight of the PIC and observer.

3.	Maximum total flight time for	e ach operational flight will be limited to the amount
of time	the	UAS	can	be	flown	and	still	maintain	a	res erve	battery	power	of	no	less
than	25%. 4.	Flights will be operated at an altitude of no more than 400 feet above ground.

5.	Minimum crew for each operation wi ll	c onsist of the UAS Pilot in Command and a Visual Observer

. 6.	Prior to the operation s at a par ticular location, a site inspection will have been

conducted. 7.	All	UAS’s	will	be	maintained	in	accordance	with	inspe ction	programs	specified	in

the manufacturer’s	guidelines. 8.	The	PIC	and	VO	will	at	all	times	be	able	to	communicate	by	voice.

9.	The PIC ,VO, & any other operational personnel will have been fully trained prior to having any	operational	responsibilities. 10.	All	required	permissions	and	permits	would	be	obtained	from	territorial,	state,

county	or city	jurisdictions,	including	local	law	enfor cement,	fire	or other appropriate	governmental agencies. 11.	If	the	UAS	loses	communication	signal,	the	UAS	will	have	the	capability	to	return

to	a	pre

- determined	location	with	the	sterile	area	and	land. 12.	The	UAS	PIC	has	the	capability	to	abort	a	flight in	c ase	of	unpredicted	obstacles

or emergencies. 13.	Ryan	Roberts	Videography, by	following	FAA,	NTSB,	and	AFS

- 80	best	practices,

will	assure	no individuals’	privacy	is	violated.

14.	Procedures	have	been	establish ed	by	Ryan	Roberts	Videography to	contact ATC prior	to operating	in	airspace	other	than	G.

V.	Regul ations	from	which	Exemption	is	r equested : To	use	a	UAS	for	data	collec tion,	Ryan	Roberts	Videography requests	relief	from	the following	sections	of	Title	14	of	the	Code	of	Federal	Regulations: •	§6 1.101(e)(4)	and	(5)	and	§61.113(a)	Private	Pilot	Limitations:	Pilot	in	Command Sections	61.101(e)(4)	and	(5)	and	61.113(a)	limits	private	pilots	to	non

- commercial operations.	However,	because	the	aircra ft will	not	carry	pilots	or	passengers	and	is

limited in	the	type	of	operation	and	the	area	of	operation,	a	private	pilot	can	achieve the	equivalent	level	of	safety	for	the	proposed	operations	as	a	commercial	pilot. First,	unlike	conventional	manned	aircra ft ,	UASs	are	remotely	controlled	by	a ground	based	pil ot	operator	in	a	controlled	and	restricted	area.	Second,	the	aircra ft

is	much	smaller	than	a	manned	aircra ft that	the	level	of	risk	associated	with	its’ operation	is	diminished	from	the	level	of	risk	associated	with	commercial operations	contemplated	by	pa rt	61.	Therefore,	allowing	aircra ft use	by	a	privatepilot	as	the	PIC	meets	or	exceeds	the	present	level	of	safety	sought	by	14	CFR 61.101(e)(4)&(5)	and	61.113(a). •	§61.315(a)	Sport	Pilot	Limitations Section	61.315(a)	limits	sport	pilots	to	non

- commercial operations.	However,

because	the	aircra ft will	not	carry	pilots	or	passengers	and	is	limited	in	the	type	of operation	and	the	area	of	operation,	a	private	pilot	can	achieve	the	equivalent	level of	safety	for	the	proposed	operations	as	a	commercial	pilot. First,	unlike

conventional	manned	aircra ft ,	UASs	are	remotely	controlled	by	a	ground	based	pilot operator	in	a	controlled	and	restricted	area.	Second,	the	aircra ft is	much	smaller

than	a	manned	aircra ft that	the	level	of	risk	associated	with	its’	operation is diminished	from	the	level	of	risk	associated	with	commercial	operations contemplated	by	part	61.	Therefore,	allowing	aircra ft use	by	a	private	pilot	as	the PIC	meets	or	exceeds	the	present	level	of	safety	sought	by	14	CFR	61.315(a). •	§91.7(a)	Civil	Ai rcra ft Worthiness Section	91.7(a)	requires	a	civil	aircra ft to	be	in	an	airworthy	condition	for	operation, which	accordingly	includes	an	airworthiness	certificate	in	accordance	with	14	CFR part	21,	Subpart	H.	To	maintain	an	equivalent	level	of	safety,	the PIC	will	ensure	that

the	aircra ft is	in	compliance	with	the	Operating	Manual	and	the	FOPM	prior	to	each flight.	Additionally,	the	Pilot	will	still	comply	with	91.7(b)	and	ensure	that	the

aircra ft is	in	condition	for	a	safe	flight. •	§91.119(c)	Minimum	Safe Altitudes Section	91.119(c)	establishes	safe	altitudes	for	operation	of	civil	aircra ft over	other than	congested	a reas.	Ryan	Roberts	Videography requests	authority	to	operate	up

to	400	AGL	over	uncontested	areas.	The	aircra ft will	operate	in	a	limited	are a	within

pre

- defined	boundaries	with	the	consent	of	the	landowner/controller	and	require

that	all	non

- essential	persons	remain	clear	of	the	flight	area	during	operations.	The PIC	will	make	a	safety	assessment	of	the	risk	of	operating	the	aircra ft and	ensur e	no undue	hazard	is	present	for	persons	or	property.	Considering	the	size,	weight	and speed	of	the	aircra ft ,	these	protections	will	ensure	the	equivalent	level	of	safety	of minimum	safe	altitudes.	Compared	to	flight	operations	for	manned	aircra ft and	the lack	of	flammable	fuel,	any	risk	associated	with	the	proposed	aircra ft operations	is

far	less	than	conventional	aircra ft operating	at	or	below	500 ft

. AGL.	In	addition,	the

low

- altitude	operations	of	the	aircra ft will	ensure	separation	with	conventional

ai rcra ft

. •	§91.121	Altimeter	Settings Section	91.121	requires	each	person	operating	an	aircra ft to	maintain	cruising altitude	by	reference	to	an	altimeter	that	is	set	“to	the	elevation	of	the	departure airport	or	an	appropriate	altimeter	setting	available	b efore	departure. ”	The	DJI

Phantom	3	Advanced does	not	have	a	barometric	altimeter,	but	instead	uses	GPS

altitude data.	Ryan	Roberts	Videography establishes	an	equivalent	level	of	safety	by requiring	the	pilot	to	confirm	that	the	GPS	altitude	is	set	to	zero before	every	flight. •	§91.151(a)(1)	Fuel	Requirements	for	Flight	in	VFR	Conditions Section	91.151(a)(1)	requires	all	day	VFR	flights	to	operate	with	enough	fuel	to	fly to	first	point	of	intended	landing	and	then	for	at	least	an	additional	thirty	minutes.

The	batteries	that power	Ryan	Roberts	Videography	unmanned	aircra ft systems provide	approximately	23	minutes	of	power ed	flight	time	and	therefore unable	tomeet	this	requirement.	However ,	the	DJI	Phantom	3	Advanced has	a	low	battery alarm	along	with	a	cri tical	battery	limit	that	automatically	sends	the	aircra ft back	to its	departure	point.	Also,	because	the	aircra ft will	be	flying	in	a	confined	area without	the	presence	of	non

- essential	persons	and	with	landowner/controller permissions,	an	equivalent	level of	safety	can	be	achieved	by	flight	planning	all flights	to	return	to	intended	landing	site	with	a	minimum	of	25%	reserve	power	in

accordance	with	the	FOPM. •	§91.405(a),	§91.407(a)(1),	§91.409(a)(1)	and	(2),	§91.417(a)	and	(b)	Maintenance Inspections

Sec tions	§91.405(a),	§91.407(a)(1),	§91.409(a)(1)	and	(2),	§91.417(a)	and	(b) require	that	an	aircra ft operator	or	owner	shall	“have	that	aircra ft inspected	as prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections,	except as	provided	in paragraph	(c)	of	this	section,	have	discrepancies	repaired	as prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or	maintain	the

aircra ft in	compliance	with	Part	43. Given	that	these	sections	and	Part	43	apply	only	to	aircra ft with	an	airw orthiness certificate,	these	sections	will	not	app ly	to	Ryan	Roberts	Videography operations. Ryan	Roberts	Videography	will	accomplish	maintenance in	accordance	with	the operations	manual	and	FOPM.	The	Pilot	in	Command	will	ensure	that	the	aircra ft is

in	wo rking	order	prior	to	flight	and	will	perform	some	maintenance	and	inspection

of	the	aircra ft and	“be	authorized	to	approve	the	aircra ft for	return	to	service.” Additionally,	the	Pilot	in	Command	will	conduct	detailed	inspections	of	the	aircra ft every	10	ho urs	of	flight.	Maintenance	performed	by	the	PIC	is	limited	to	repairing small	cracks	replacing	propelle rs,	and	updating	so ft ware	and	firmware. The manufacturer	will	perform	all	other	maintenance

. Ryan	Roberts	Videography will keep	a	log	of	maintenance	perf ormed.	More over,	Ryan	Roberts	Videography and	the

PIC	are	most	familiar	with	the	aircra ft and	best	suited	to	maintain	it	in	an	airworthy

condition. An	equivalent	level	of	safety	will	be	achieved	because	the	DJI	Phantom	3 Professional	is	limited	in	size,	wi ll	carry	a	small	payload	and	operate	only	in restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	arise,	the	aircra ft can	land	immediately	and	will	be	operating	no	higher	than	400	feet	AGL.

VI.	Privacy There	is	little	concern	that	the	propos ed	flights	will	cause	invasions	of	privacy because	flights	will	occur	over	private	or	controlled	access	property	with	the

landowner ’s	prior	consent	and	knowledge.

VII.	Public	Interest

Use	o f	the	DJI	Phantom	3	Advanced drone	is	in	the	public	interest	b ecause	it	is	safer for	people	and	structures	than	conventional	manned	aircra ft .	First,	risk	to	the	flight crew	is	virtually	eliminated	by	using	an	unmanned	aircra ft .	Second,	by	flying	a	smallaircra ft weighing	less	than	55	pounds	and	carrying	no	fuel,	risk to	persons	and structures	on	the	ground	is greatly	reduced.	Finally,	use	o f	the	DJI	Phantom	3

Advanced benefits	the	public	because	it	is	better	for	the	environment	through reduction	in	noise	and	environmental	pollution.

VIII.	Federal	Registry	Summary Rya n	Roberts	Videography seeks	an	exemption	from	the	following	sections	of	Title 14	of	the	Code	of	Federal	Regulation:	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	commercially	operate	an	unmanned	aircra ft system	for commercial	purposes	including	but	not	limited	to:	aerial	photography,	aerial videography,	land	surveying,	and	industrial	inspections. As	established	by	the	UAS	exemptions	already	grante d	by	the	FAA,	allowing commercial	operations	of	UASs	for	aerial	photography	and	videography	will enhance	safety	by	reducing	risk.	Conventional	aerial	photography,	aerial videography,	aerial	surveying,	and	aerial	inspections	using	manned	aircra ft present

av oidable	risks	to	flight	crew	and	persons	and	structures	on	the	ground	because	the

aircra ft is	flying	at	low	altitudes	with	large	amounts	of	fuel.	In	contrast,	a	UAS weighing	less	than	55	pounds	and	powered	by	batteries	eliminates	virtually	all	of

that	risk given	the	small	size	and	lack	of	combustible	fuel. Using	an	aircra ft that	does

not	have	emissions	also	eliminates	environmental	risks .	Therefore,	by	using	an	UAS for	the	purposes	outlin ed	by	Ryan	Roberts	Videography, the	risk	to	persons	and

structures	wil l	be	significantly	reduced.

IX.	Conclusion Ryan	Roberts	Videography requests	an	exemption	from	the	aforementioned sections	of	14	CFR.	The	exemption	is	in	the	public	interest	because	it	will	increase safety	for	persons	and	structure s	and	Ryan	Roberts	Video graphy will	provide	an equivalent	or	greater	level	of	safety	as	provided	for	in	the	applicable	14	CFR

sections.