October 27, 2015
U.S. Department ofTransportation Docket Management System Room Wl2-140 1200 New Jersey Ave. , SE Washington, DC 20590 Subject: Exemption request under Section 333 ofthe FAA Reform Act.
Dear Sir /Ma'am:
Pursuant to Section 33 3 ofthe FAA Modernization and Reform Act of2012 Kingdom Works Media, Inc, the operator ofsmall Unmanned Aircraft Systems (UAS) seeks an exemption from the Federal Aviation Regulations (FARs) 14 CFR §§ 61.23(a) and (c) , 61.10 1(e)(4) and (5) , 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121 , 91.151(a)(l), 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 Kingdom Works Media, Inc to operate a UAS to perform aerial data collection.

The requested exemption would permit Kingdom Works Media, Inc to commercially operate UAS for the following purposes:

• Airborne photography and videography
• Emergency services support • Search and rescue • Emergency Services training
• UAS operations training
• UAS capability demonstrations
Furthermore, Kingdom Works Media, Inc will research, develop, and commercial operate UAS to conduct:

• Agriculture and land surveying
• News gathering and reporting
• Railroad inspections
• Bridge inspections
• Infrastructure inspection
• Tall structure inspections (smokestacks, cell phone towers , windmills, and electrical transmission towers, etc.) The primary purpose ofKingdom Works Media, Inc is to assist other industries by providing safe and efficient UAS support. The uses ofUAS to perform airborne photography andvideography as well as aerial inspections and surveying have two major benefits. First, small UAS are considerably safer than using manned aircraft in the previously mentioned tasks, and also reduces the fall risk ofworkers. Second, UAS allows the completion ofmany tasks at a fraction ofthe cost using traditional means. Granting this exemption is in the public interest because it will dramatically enhance safety, lower-cost, and improve the efficiency ofmany industries. Kingdom Works Media, Inc will conduct the aforementioned tasks by using the following small sized UAS: DJI Phantom 3 professional These UAS are very small, all weighing less than 25 pounds, and have advanced navigation systems and automated control features that enhance safety.
All ofKingdom Works Media, Inc operations will strictly adhere to FAA regulations with safety being the number one priority. All operations will be conducted via unaided visual line of sight below 400 feet AGL and outside ofany controlled airspace unless the controlling agency g1ves express perm1ss1on. Kingdom Works Media, Inc respectfully submits a grant ofexemption is in the public interest because the use ofsmall UAS in lieu ofcomparatively more expensive and hazardous fixed and rotary wing aircraft or other conventional manned methods of inspection greatly enhances efficiency and achieves a level ofsafety that is significantly higher. Furthermore, Kingdom Works Media, Inc will assist other industries in the safe application ofUAS and promote the benefits ofsafe UAS operations. Approval ofthis exemption would enhance safety and fulfilled the Secretary ofTransportation's responsibility under the section 333(c) ofthe FAA Modernization and Reform Act of20 12 to "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system."
Name and address ofthe applicant:

David Woodall Kingdom Works Media, Inc Cell: (610) 883-6424 Email: mail @ kingdomworksmedia.com Address: P.O. Box 1974 West Chester, PA 19380JUSTIFICTION UNDER SECTION 333 According to the 

### F AA ' s Public Guidance for Petitionsfor**emption** 

### F' iled und er Section 333

" Section 333 grants the Secretary ofTransportation the authority to determine ifan unmanned aircraft system, as a result ofits size, weight, speed, operational capability, proximity to airports and populated areas , and operation within visual line ofsight does not create a hazard to users of the national airspace system or the public or pose a threat to national security". Kingdom Works Media, Inc submits that the small size and weight ofthe purposed UAS coupled with the fact that the operations will be conducted at low altitudes, slow airspeed, and within visual line ofsight ofthe operator; our operations pose no potential hazard to the national airspace system, general public, or present any threat to national security.



### Airworthiness ofthe UAS

The Federal Aviation Act (49 US.C§44701 

### (f)) and Section 333 ofthe Refonn Act both authorize the FAA to exempt aircraft from the requirement for an ai1worthiness certificate, upon consideration ofthe size, weight, speed, operational capability ofthe particular UAS. Kingdom Works Media, Inc purposes using DJI Phantom 3 professionaL The proposed systems have the inherent advantage ofbeing small in size and battery-operated therefore do not carry flammable fuel , this significantly reduces any potential damage in the event ofa mishap. Kingdom Works Media, Inc will operate the proposed UAS below 400 feet AGL, at speeds less than that recommended by the manufacturer, and at all times less than 50 knots. Operations will only be conducted in during daylight hours, in uncontrolled airspace, unless specific permission is granted by the controlling agency, and within visual line ofsight ofthe operator.



### Operation ofthe UAS Kingdom Works Media, Inc will ensure that the exemption does not adversely affect safety and will operate at a level ofsafety at least equal to existing rules by operating with the following limitations and conditions:

• All operations will strictly adhere to manufactures owners, operators and maintenance manual.

• All operations will occur in class G airspace, unless specifically authorized by the controlling authority.• All operations will be conducted during daylight hours.

• All operations will occur below 400 feet AGL.
• All operations will be conducted and visual meteorological conditions with visibility ofat least three nautical miles.
• All operations will be conducted with at least 500 feet below clouds and with a horizontal separation ofat least 2000 feet.
• At no time will the operator allow the aircraft within 500 feet ofnonparticipating person, structure, or vehicle.
• Preflight operations will be conducted in accordance with the manufacturer's recommendation and preflight checklist.
• All maintenance will be conducted in accordance with manufacturers recommendations and documented in the aircraft logbook


### PIC Requirements Kingdom Works Media, Inc respectfully submits that the operator requirements should take into account the advanced internal navigation and autopilot systems ofthe proposed UAS. The DJI systems have a high degree ofcontrol and are extremely stable even in high wind environments. DJI incorporate various built-in capabilities that limit the potential for operations outside ofthe aircraft capability. The pilot in charge (PIC) is solely responsible for the safe operation ofthe UAS. Kingdom Works Media, Inc will ensure that all PICs comply with manufacturer training requirements, and have been deemed safe and proficient by the chiefpilot.



### The regulations from which the exemption is requested are as follows:
14 C.F.R. Part 21 ; 14 C.F.R. 45.23(b) ; 14 C.F.R. 6l.l13(a) & (b) ; 14 C.F.R. 6l.l33(a) ; 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2) ; 14 C.F.R. 91.1 09(a) ; 14 C.F.R. 91.119 ; 14 C.F.R. 91.121 ; 14 C.F.R. 91.151(a) ; 14 C.F.R. 9l.203(a) & (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(l) ; 14 C.F.R. 91.409(a)(2) ; 14 C.F.R. 91.417(a) & (b).

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 

### 91.203(a)(1) Subpart H, Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (I). Given the size and limited operating area associated with the aircraft to be utilized by Kingdom Works Media, Inc, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part II and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§4470 I (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. Our small UAS's will be operated at low speed in a controlled environment, away from airports. An analysis ofthese criteria demonstrates that the UAS's operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated is less than 25 lbs. fully loaded, carries neither a pilot nor passenger, carries no flammable liquid fuels , and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the PIC. Ifrequired, the FAA and general public will have advance notice ofall operations

. These safety enhancements, which already apply to civil aircraft operated in connection with private property, industrial sites, railroad yards and the like provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F

.R. Part 21 , Subpart H. Lastly, application ofthese
same criteria demonstrates that there is no credible threat to national security and the NAS posed by the UAS , due to its size, speed ofoperation, location ofoperation, lack flammable liquid fuels , and limited ability to carry an external load.


### 14 C.F.R. § 

### 45.23(b}: Marking ofthe Aircraft
This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station.
Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS , two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).
The equivalent level of safety will be provided by having the UAS marked on its fuselage
as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A.

### 14 C.F.R. § 

### 61.113(a) & 

### (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.

Part 61.113 (a) states that no person who holds a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or property for compensation or hire ; nor may that person, for compensation or hire, act as pilot in command or an aircraft. Part 61.113 (b)
states that a private pilot may, for compensation or hire, act as pilot in command ofan aircraft in connection with any business or employment if: ( 1) The flight is only incidental to that business
or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command ofan aircraft for compensation or hire.
Since there are currently no means available for the pilot ofa UAS to gain the experience in an equivalent category and class in order to apply for a commercial UAS pilot's license, and given the unique nature ofcommercial UAS operations we do not believe that it rises to the level ofrequiring a commercial pilot to operate the aircraft under§ 61.133(a).



### 14 C.F.R. § 

### 91.7(a): Civil aircraft airworthiness.
This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation ofthe UAS without an airworthiness certificate, no standard will exist for airworthiness ofthe UAS. Given the size ofthe aircraft and the requirements published by the manufacture for maintenance and the use ofsafety checklists prior to each flight, an equivalent level ofsafety will be provided.


### 14 C.F.R. § 

### 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.
The UAS , given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.
The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.



### 14 C.F.R. 91.103: Preflight Action
This regulation requires each pilot in command take certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements , checking takeoff and landing distances, and all other actions in the manufactures preflight checklist. These actions will provide an equivalent level ofsafety.

### 14 C.F.R. § 

### 91.109(a) & 

### 91.319(a)(1): Flight Instruction
These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, UASs and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use ofa control station that communicates with the aircraft via radio c01mnunications. The FAA has previously approved exemptions for aircraft without fully functional dual controls. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via radio signals from the controller, and by the size and speed ofthe aircraft.


### 14 CFR § 

### 91.119: Minimum Safe Altitudes
Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
The equivalent level of safety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner. Compared to flight operations with aircraft weighting far more than the maximum 55 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will
ensure separation between these UAS operations and the operations ofconventional aircraft

. 

### 14 C.F.R § 

### 91.121 Altimeter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS does not have a barometric altimeter, but instead a GPS altitude read out, an exemption is needed. An equivalent level ofsafety will be achieved by the operator confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.


### 14 C.F.R. § 

### 91.151(a): Fuel Requirements for Flight in VFR Conditions
This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (I) During the day, to fly after that for at least 30 minutes."An equivalent level ofsafety can be achieved by limiting flights to what the manufacturer recommends, or enough battery reserve to ensure that the UAS lands at the ground station with at least 25% ofbattery power (as determined by the onboard monitoring system and the pilot) , whichever happens first This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.



### 14 C.F.R. § 

### 91.203 (a) & 

### (b): Carrying Civil Aircraft Certification and Registration
This regulation requires: "no person may operate a civil aircraft unless it has [

...] an appropriate and current airworthiness certificate"

. "(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew".
An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation.



### 14 C.F.R. § 

### 91.405(a); 407(a)(l); 409(a)(2); 417(a) & 

### (b): Maintenance Inspections
Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this chapter

...." Section 91.407 similarly makes reference to requirements in Part 43 ; Section 91.409(a)(2) requires an annual inspection for the issuance ofan air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43 , or licensed pilots and records ofapproval ofthe aircraft for return to service.
Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Kingdom Works Media, Inc UAS. An equivalent level ofsafety, given the small size and unique characteristics ofthe aircraft, will be maintained by the operator accomplishing and documenting all required maintenance specified by the manufacturer.