Elevated Media Concepts, Inc.

May 6 th , 2015 4400 Huxley

Drive Ellicott City , MD 21043 Cell (443) 722

- 3335 Email: jhardway @yahoo.com U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) DJ I Inspire 1

- User Manual v1.2 2) DJ I Inspire 1

- (Quick Start Guide) 3 DJIMaintenance v1.0

References: 1) FAA Exemption No. 11138 , Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

–2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regul atory Docket No. FAA20140355 in the matter of the petition of FLYI NG CAM INC
Dear Sir or Madam, I, John A Hardway

president and head UAS Operator of Elevated Media Concepts , Inc. ( “ the Petitioner” ), 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 , hereb y request exemption from the following sections of Title 14, Code of Federal Regulations §§
**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 s ys tems (UAS) commercially in airspace regulated b y the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematograph y, videography , and other flight operations that could be perform ed safel y and more cost effectivel y with the use of small UAS at low altitude within the U.S. national airspace sy stem as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of client s or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air s ys tems. 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 b y 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 relief in order to facilitate the utilization of an experienced UAS operator with the a ddition of a trained observer. All pre

- flight inspection, maintenance and flight logs will be saved and made available to the FAA an d Secretary of Transportation ( SoT) for review ; with the purpose of safel y integrating civil UAS operation in the National Airspace Sy stem

. **91.119(c)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be op erated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The Petitioner requests modification, waiver or exemption and clarification concerning the terms “ congested areas ” and

“ densely populated” . T he Petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. The Petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be operat ed over designated properties with the owner’ s consent and while maintaining a safe distance from persons. The Petitioner will compile flight data from the logs. This data may assist the FAA in development of regulations for commercial operations in low

- ri sk, controlled environments. **91.121** As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. **91.151(a)** As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned 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 1 0673 for day time, VFR conditions. The UAS provides battery

power remaining in percent to the PI C. The UA batteries provide approximately 23 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC 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, T he FAA found that a reduced minimum power reserve for flight in day time 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 Petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the Petitioner’ s operating documents and the conditions and limitations specified, describing the requirements for maintenance , inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.**Other Relief**

The Petitioner further ask s for relief to permit Petitioner to operate and launch a UAS for photograph y/ filming/and data collecting from a boat in a marine environment at times when operating from a land base is not a viable option. The p urpose s for such launches include, but are not limited to, seashore/water erosion studies, wetland area survey s , natural disaster assistance

– such as se arch and rescue in a flood zone

– and sailing events where race operations take place off shore. In such situation s where launching from land is not feasibly possible , this relief could potentially

save lives

– if, for example, the UAS could search are as deemed high risk with human life aboard

– and could benefit the environment and wildlife

. The Petitioner will ensure, for all f lights that launc h from a boat or floating platform , that the UAS will remain in VLOS of the PI C and VO. Any movement performed by the vessel will only be for the purpose of improv ing visual safety and/ or landing and takeoff. The dy namic home point feature of the UAS further ensures that, in the event of brief communication disruption, the UAS will return to the point of flight origination, or to the GPS coordinates of the last ground station transmission, whichever is the most recent.

**The UAS** The DJ I Inspire 1 is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised Max Takeoff W eight: 6 lbs 10.5oz with T48 (5700 mah) Battery . It is designed primaril y to carry aloft a high definition camera. It has an advertis ed maximum speed of less than 45 knots (22 m/s) and a maximum climb rate of l ess than 1000 feet per minute (5 m/s). It is powered b y four electric motors with a distance between mo tors of less than 23 inches (580 mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning sy stem (GPS) to maintain it s geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry

information is transmitted back to a ground control station allowing the operator and/or PI C to monitor battery level, RC signal strength, GPS signal 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

18 minutes with a T47 batteries, and 22 minutes with a T48 b attery . The onboard flight controller will warn the pilot via telemetry and external light ing cues before reaching a low battery

state. An automatic termination of flight and landing will be initiated when the battery

reaches a predetermined low state . It is ant icipated in an y flight when the aircrafts batte ry

capacity reaches a 30% level, the Petitioner will terminate the and land the UAV.**Risk mitigation**

The Petitioner has reviewed FAA exemptions reference ’ s 1

- 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA S airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safety standards and regulations. The Petitioner will o nly operate the UAS over designated properties with the owner’ s consent. Flight plans will be predetermined to limit the UAS s flight time and limit safety concerns. The Petitioner will take into account distance from persons and potential flight obstacle s prior to operating the UAS. UAS operation will alway s be within VLOS of the PI C and the VO

. **Added Background Information** In addition to the above, my training as a private pilot will benefit Elevated Media C oncepts in performing safe and effective UAS operations in a commercial environment.
My FAA private pilot’ s certificate , first obtained in September 2006, includes the following disciplines : private pilot fixed wing (+300 hrs ) ; and private pilot rotorcraft

– helicopter (+50 hrs, and an instrume nt rating (+120 hrs) )

. Using the same pre

- flight and in

- flight techniques needed for manned aircraft is beneficial to m y safe and effective operation of UAS on multiple levels , including operational awareness, risk management , creati on of flight plans, und erstanding flight charts, communicating with ATC, and checking NOTAMS, METARS and other pertinent information

. This combination of experience and knowledge with manned aircraft, with over 300 hours of fl yi ng UAV ’ s, and with over four ye ars of building an d designing multirotor UAVs, puts me in the unique position of being able to identify and address safety i ssues at all stages of flight.

**Public interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally , use of the UAS i n order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography /photography . Aerial photography is a valuablemarketing tool that can lead to increased commerce and enhance personal photography . Aerial

surveying and inspections can increase work site e fficiency , 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. 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 submitte d to FAA via traditional means or other means as required.

**Conclusion** The Petitioner is requesting this exemption for the purposes of “ aerial photograph y, cinematograph y, videography , inspections and other flight operations ” . The reason for such a general and broad based request is that the Petitioner wishes to utilize a business strateg y of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associ ated with additional exemptions. The Petitioner 's business model is based on the id ea of offering ad hoc small UAS services to individuals or companies who wish to e mploy these services as a safe, effective, and legal option to enhance their business or h obby

. The primary purpose of seeking this exemption is to obtain the capability to offer th ose services while remaining in compliance

Respectfully

submitted

John A Hardway President & Head UAS Operator Elevated Media Concepts