January 12, 201 6

Jim Honaker

– President Kentucky Technical Solutions, Inc. 149 Dan Johnson Cemetery Rd. Morgantown, KY 42261 270

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- 2382 JHonaker@KyTechnical.com U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washin gton, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: These attachments are too large for submission via the submission portal. They are available at this website for viewing or download. http://www.dji.com/prod uct/phantom

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- adv/info#downloads 1) Phantom 3 Advanced User Manual (EN) v1. 6 2015

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-03 2) Phantom 3 Advanced Quick Start Guide (EN) v1. 2 2015

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- 14 3) Phantom 3 Safety Guidelines and Disclaimer

References : 1. FAA Exemption No. 12253 Regulatory Docket No. FAA

- 2015

- 2055 in the matter of the petition of GERSHWIN THOMAS STEPHEN 2. FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU 3. FAA Exemption No. 11136, Regulatory Docket No. FAA

- 2014

- 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 4. FAA Exemption No. 11080 Regulatory Docket No. FAA

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- 0355 in the matter of the petition of FLYING CAM INCDear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I , Jim Honaker, President of Kentucky Technical Solutions, Inc. , referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Re gulations §§ **61.113(a) ; 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1);**  **91.409(a)(2) ; 91.417(a) & (b);**  In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Admi nistration (FAA) for the purposes of aerial photography, videography, mapping, inspections and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace syst em as compared to a manned aircraft. Operations will be p erformed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unm anned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1 3. **The FARs** The petitioner seeks exemption from the above mentioned FARs for the following reasons; **61.113(a) & (b) ;**  The petitioner requests re lief in order to facilitate the utilizatio n of pilots, who hold a PRI VATE PILOT ( or greater ) certificate. Any pilots operating under this exempt ion would be required to comply with any conditions as set forth and in a si milar fashion to the previously granted exemptions. **91.119(c)** As discussed in Exe mption 11138 (DOUGLAS TRUDEAU) , operations conducted clo ser than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modifi cation, waiver or exemption and clarification concerning the terms “congested areas “and “densely populated”. The petitioner requests waiver for this co ndition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.
**91.121** As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronics with a barometric sensor for al titude information.**91.151(a)** As discussed in Exe mption 11136 (ADVANCED AVIATIONSOLUTIONS LLC)

prior relief has been granted for man ned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition , similar UAS specific relief has been granted in Exemption Nos. 8811, 10808,and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to th e PIC. The UA batteries provide approximately 25 minu tes of powered flight . Information provided in the operating documents discusses procedures regarding remaining battery power manage ment. Those documents contain a condition in which the PI C will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. **91.405(a) ;**  **91.407(a)(1) ;**  **91.409 (a)(1) & ( 2)** **; 91**  **.417(a) & (b)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The pet itioner proposes to inspect and ensure that the UAS is in a condition for s afe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the condit ions and limitations specified, describing th e requirements for maintenance, inspection , and re cordkeeping, were sufficient to ensure that safety would not be adversely affected.

**The UAS**  The DJI Phantom 3 Advanced is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of 46 Ou nces (1280g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less t han 32 knots (16 m/s) an d a maximum climb rate of less than 1000 feet per minute (5 m/s). It is powered by four electric motors with an advertised diagonal size (including propellers) of less than 24 inches (590mm). It utilizes an internal inertial measuring unit (IMU) wi th inte grated barometric sensor augmented with global positioning system s (GPS) utilizing both GPS and GLONASS to maintain its geospat ial orientation and position. In addition to GPS, the DJI Phantom 3 Advanced also utilizes DJI’s Vision Position Sensing syste m t o maintain vertical and horizontal stability in the event of GPS signal loss. It is controlled primaril y through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a grou nd control station allowing th e operator and/or PIC to monitor battery level, GPS s ignal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller wi ll warn the pilot via telemetry and external lighting cue s before reaching a low battery state. An automatic termination of flight and landing wil l be initiated when the battery reaches a predetermined lo w state. More information is available in attachment 1 or http://www.dji.com/product/phantom

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- adv/info#downloads**Risk mitigation**

The petiti oner has reviewed FAA exemptions refe rence’s 13 Conditions and Limitations section and believe s that the procedures specified therein are reasonable and will be utilized in order to manage and mi tigate risk and ensure public safety. A Preflight checkl ist w ill be developed and employe d to e nsure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, mainta ining flight and maintenance logs to record time on failure p rone components. The petitioner does request that in a manner similar t o reference 3, he be allowed to operate within 5 miles of an airport provided that; “The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non towered airport as denoted on a current FAA published aeronautical chart un less a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport managemen t must be made available to the Administrator upon request.” Operations within 5 miles of an airport are not antic ipated to be routine but the petiti oner is requesting a mechanism to facilitate such activiti es without requesting a new and separate exemption(s) should the need arise. Operati ons within class B airspace are not requested due to the lack of mode C transp onder. **Public interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to si milar operations conducted with manned aircraft of greater proportions, carry ing a crew and flammable fuel. Addit ionally, use of the UAS in order to fa cilitate commerce could lead to econo mic growth. Operations for this petition will enable service for property owners or thei r designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects tha t cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photograph y. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yi elds and decreased costs. Aerial survey ing and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. L iability insurance is will be obtained commensurate with the granting ofthis req uest for exemption. Flight data including UA flight time, Control Unit operation time,

incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via trad itional means, e.g. COA Monthly Reports, or other means as required. **Conclusion** The petitioner is requesting this exemptio n for the purposes of “aerial photography, videog raphy, mapping, inspections and other flight operations for real est ate sales and services.” The reason for such this petition is that the petitioner wishes to utilize a business strategy in order to capitalize on opportunities as they may arise

. Aerial photographs currently exists in the real estate market and other industries and is an emerging trend. Although mapping and inspections are included in this request, these will be on a n as needed basis as the primary objective will be aerial photography of houses, buildings and land that may be offe red on the R eal Estate Market. The petitioner has refrained from engaging in commerc ial use of the UAS. The primary purpose of seeking t his exemption is to obtain the capability to offer th ose services while remaining in complianc e. The petitioner has been a Private P ilot since February 25, 2007 (Certificate Number: 3214588) and has been issued a valid d rivers license in the state of Kentucky

. Respectfully submitted, Jim Honaker

– President Kentucky Technical Solutions, Inc.