Re: Exemption Request Pursuant To Section 333 of th e FAA Reform Act of 2012

Dear Sir or Madam,

Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Robert Barnes DBA Camerawork Video & Photography

, operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography for the media and advertising industries for pre

- planned, controlled area s , photographic and video services, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federa l Aviation Administration (FAA) as required by§333. Robe rt Barnes cu rrent operation of sUASs for commercial purposes has been halted to comply with recently enacte d federal aviation regu l ations pertaining to sUASs. As descr i bed more fu ll y below

, the requested exemption wou l d permit the operation of small,

unman ned and re l ative l y inexpensive multi

- rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on

- s ite safety personnel controlling access, and 4) wou l d provide increased safety and enhancements to clients' busines s operations. The name and address of the applican t is: Robert Barnes Address: 4610 Lake in the woods Drive, Spring Hill, Fl. 34607 Ph: + l

- (727)

- 272

- 2306 Emai l: bob@cvpus.com

I, Robert Barnes respectfully requests a grant of an exemption of the followin g sections of Title 14 of the Code of Federal Regulations:14 CFR 21; 14 CFR 91, et seq.; 14 CFR 45.23 (b);

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 • 14 CFR 61.113 (a) & (b); 14 CFR 407 (a)(l); 14 CFR 409 (a)(2); • 14C FR417(a)&(b). I, Robert Barnes also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.1 1 3 (a) & (b); 91.7 (a); 91.9(b)(2); 91.103(b) ; 91.109; • 91.119; • 91.12 1 ; • 91.151(a); • 91.203(a) & (b); • 91.405 (a); • 91.407 (a) (1); • 91.409 (a) (2); • 91.417 (a) & (b). T he Ex t e nt of Re l ie f Robert Barnes S e e k s a nd t h e Re ason I t Seeks Suc h Re li e f : Robert Barnes submits this application in accor dance with the R efo rm Act, 112 P.L. 95 §§331

- 334, seeking relief from any currently applicable federal aviation regulations PARs pertaining to UASs (unmanned aircraft systems) and operating to prevent Robert Barnes contemplated commercial photography, Phot ographic mapping, and other flight operations within the U.S. nationa l airspace system.The Reform Act in §332 provides for such integration of civil UASs into our national airspace system as it is in the public's interest to do so. Robert Barnes lightweig ht UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industri es, Robert Barnes light duty UASs are ideal recipients of exemption by the intent of the Reform Act. Considerations for relief include a combination of sUAS physical characte ri stics, safety features, and safe practices identified in §333:

• sUAS weight, • sUAS overall size, • sUAS speed over ground,

• sUAS flight zone characteristics,

- Non

- operation near airports (civilian or military),

- Tightly contro lled operation in populated areas,

the cl i ent. Spec i fic co n side r a ti on is outline below

. Re: Exemption R equest Pursuant To Section 333 of the FAA R eform Act of201 2

• Operat ion of the UAS by VLOS by

1 4 C.F.R. Par t 2 1

, Sub p ar t H : A i rwort hin ess Ce r ti fi ca t es 14 C.F. R . §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the pro cedural r e quirem e nt s for th e issuance of
airworthiness certificate s as requir ed by F AR §91.203 (a) (1 )

. Given the size and limit e d
ope r at in g area associated sU ASs, an exemption from Part 21 Su bpar t H m ee t s the requirem e nts of an e quival e nt l evel of safety under Part 11 and §333 of th e R efo rm A c t. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act bo th authorize the FAA to exempt aircraft from the requirement for an airworthiness c e rtificate, upon consideration of the size, w e i g ht, s peed, operational capability, and proximity to airports and populated areas of the particu l ar sU AS. In all cases, an ana l ysis of these criteria demonstrat es that th e UAS operated without an airworthiness cer tific ate , in the r es tricted environment and under the conditions proposed will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificat e without the restrictions a nd conditions proposed. The sUAS to be operated by Robert Barnes is l es s than 11k g. wit h maximal payload consisting of remote se n sing instrumentation, carr i es neither no per sons, carries no explosive or flammable mat e rial s including combustib l e fuels, and operates exclusively wi thin a secured

area. Unlike other civil airc ra ft

, operations under this exemption will be tightly controlled and monitored by both the pilot (P I C), 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety i ssues, and a technician, which assists in matters

r elated to maintaining the sUAS and also m onitors for sa fet y c oncern s and liaisons to the on

- s it e safety officials. These enhancements to current safety practices and regulations, which already apply to civ il aircraft, provide a greater degree of safety t o the public and property owners than conventional aircraft opera tion s conducte d with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H . Lastly, application of these same crite ria demonstrates that there is no intrin s i c cre dibl e threat t o national secu r ity po se d by the UAS, due to its size, s peed of operation, lo cat ion of operation, l ack of intrinsic exp l osive materials or flammable liquid fuels, and inability to carry a substantial exte rn a l load. 1 4 C.F.R. §45.23 ( b ). Marking of th e Air c raft The regulation r e quir es: When marks include only th e Roman capit a l l e tt e r "N" and the registration number is displayed on limit e d

, re strict e d or light

- sport category aircraft or ex p er im e ntal or provisiona ll y certificat e d aircraft, the operator must a l so display on that aircraft n ear eac h e ntr a n ce to th e cabi n , cockpit, or pilot station, in l ette r s n ot l ess than 2 in c h es nor more than 6 inch es high, the words " limit ed ; ' "restricted;' "light

- sport;' "expe rim enta l ;' or "provisional;' as applicable. Even though the sUAS will have no airworthiness certificate, an exe mpti on may be n ee ded as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word"Exper im enta l " can be placed. G i ven the size of the sUAS, two

- inch lettering will be impossible. The wo rd "Expe rim ental" will be placed on the frame in compliance wi th §45.29 (f) at a size suitable for the available space. The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 ( f) where the pilot, observer and other s working with the sUAV will see the identification of the UAS as "Expe ri mental." The FAA has issued the following exe mpti ons to this regulation to Exem ptions Nos. 10700, 8738, 101 67 and 101 67A. Further m arkings includ e the use of flashing green LED illumination on the underside of the sUAS frame which s tand s at co ntra st against a blue or white sky.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012
14 C.P. R. §6 1.11 3 (a) & (b): Private Pilot Pri v i l eges and Limitations: Pilot in
Command. §61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, th e proposed ope rations can achieve the eq uivalent lev el of safety of current operations by requiring a ground crew member to have a private pilot's license rather than a comme rcial pilot's lic ense to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with
no persons on board. The area of operation is contro lled and restricted, and all flights are planned and coordinated in advance

. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allow ing operations as requested with a private pilot in the ground crew
exceeds the present l evel of safety achieved by 14 C.P.R. §61.1 1 3 (a) & (b). 1 4 C.P.R. §91.7(a): C ivil aircraft airworthiness. The regulation requires that no person may operate a civil a ircraft unl ess it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and th e requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 14 C.F.R. §91.9 (b) (2): C i v il Airc raft Flight Manual in th e Aircraft. §91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft F light Manual is not required by §21.5 of this chapter, unles s th e r e is available in the aircraft a current approved airp l ane or Rotorcraft F li ght Manual, approved manual material, markings, and p l acards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a physical flight manual on the aircraft. The equival ent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738, 9299, 9299A, 9565,95658, 10167, 10167A, 10602,32827, and 10700. 14 C.F.R. §9 1.10 3: Preflight action This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not b e provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and airc r aft performance data before initiation of flight. Further, we have propr ietary manuals

c r eated with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered
to. 14 C.P.R. §91.1 09: Flight in s truction §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless thataircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do not have fully functional dual contr ols. Flight control is accomp l ished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual contro ls for a number of aircraft and for flight
instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and

Re: Exemption R equest Pursuant To Section 333 of the FAA Ref o rm Act of2012 speed of the aircraft. Enhanci ng this safety is the t echnology inh ere nt in the remote controls utilizing digital com muni cati on s wh i ch is paired to the sUAS m aking i t n early impossib le to unintentionally or intentionally h ave the con tr ol commun i cations interrupted. 1 4 C.F.R. §9 1.119 : M in imum safe alt itudes §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimu m s prescribed, provided the person operating the h e li co pt er complies with any route or alt i tudes prescribed for helicopters by the FAA. As this exe mpti o n is for a sUAS that closely mimic s the behavior of a h elicopter, and the exemption reque sts authority t o operate at altitudes up to 400 AG L, an exempt ion may be needed to allow such operations. As se t forth herein, th e UAS will never operate at higher than 400 AGL or b eyo nd unaided visual line of sight, whichever i s closer. It will however be operated in a r es trict e d area with sec urity officials tasked with ensuring pub l i c sa f e ty

, and where buildings and people will not be exposed to operations without their pre

- o btained consent and training. The eq uival e nt l e vel of safety w ill be achieved given th e size, weight, speed of th e UAS as well as the location wh e r e it i s o p erated . No flight operation will be tak e n without t h e permission of th e property owner in the case of private pr ope rty o r loc a l officials i the case of public pr ope rty or private property with public inter ests. B eca u se of th e a d va nc e notice to the property owner and participants in the remote sensing activ ity, all affected individu a l s will be aware of the planned flight operations. Compared t o flight operations with air craft o r rotorcraft weighting far m ore than the maximum 11kg of Robert Barnes sUASs proposed herein and the lack of flammable fuel, any risk associate d with these operations i s far l ess than those presently
pre se nt ed with conventiona l ai r craft operating at or below 500 AGL. I n addition, the low

altit ud e operations of the sUAS will e n sure separation between these s mall

- UAS operations and the o pera tio ns of conventiona l aircraft that must comply with §91.119. 14 C.F. R

. § 91. 1 21 Altime t er Settings §91.121 requires eac h person opera ting an aircraft to maint ain cruis in g a ltitud e by r efe rence to an alt i meter that is set " ...to the e l eva ti on of the de parture airport or an appropr i ate a ltim ete r setting available befor e d eparture." A s th e sUAS
may not have a barometric altimeter, but instead a GPS altitude read out, an exemption m a y be

ne e d e d

. An equiva lent lev e l of safety wi ll b e achieved by th e operato r, confirming the altitud e of th e launch s ite s h own on the GPS altitude indicator b efo r e flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accura t e dete c tion of height. 14 C.F.R. §9 1.15l (a): Fue l Req uirements for Flig ht in VFR Conditions §9 1.1 5 1 (a) prohibits

an individual from beginning "a flight in an airp l a n e und er VFR conditions unl ess (considering wind an d fo r ecast weather conditions) there i s enough fuel to fly to the first point of int e nd ed lan ding, and, assuming normal cruising speed

- (1) During the d ay, to fly after that for at least 30 minut es; or (2) At night, to fly after that for at l east 45 minutes:' The bat t ery powering the sUAS provides approximately15 minutes of powered flight i n hover mode with out payload. Robert Barnes sUAS will not be able to meet the 30 minute r eserve r equirement in 14 CPR §9 1.15 1. Operating the small UAS, in a tightly controlled area where on l y people and propertyowners or official representatives who have s i gned wa i vers will be allowe d , with less than 30 minutes of r eserve powe r , does not enge nd e r the type of risks that Sectio n 9l.l51(a) was intended t o alleviate give n the size and speed of the s mall UAS. Robert Barnes believes that an equivalent level of safety can be achieved by limiting flights to » 10 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS toils planned landing zone from anywhere in its limit ed o p e ra ti n g ar ea

. Similar

exe mption s h a ve been granted to other operation s, includin g E x em ptions 2689F, 5745, 10673

, and 10808.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012
1 4 C.P. R . §9 1. 2 0 3 (a) & (b): Carry in g C i v il A ir craft Cert i fica ti on a nd Reg i str a t ion The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

. .. (b) No person may operate a civi l aircraft unless the airworthiness certificate required by paragraph (a) of this 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. The sUAS fully loaded weighs no more than llkg and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS

. An equivalent level of safety wi ll be achieved by k eeping these documents

at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions
to this regulation. A representative sample of othe r exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 1 4 C.P. R. §9 1. 405 (a); 4 0 7 (a) ( 1 ); 4 0 9 (a) (2); 4 1 7(a) & ( b ): Mai nt e n a n ce I ns p ect i o n s These regulations require that an aircraft operator or owner "shall have that aircraft 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 o r m aintain the aircraft in compliance with Part 43

. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level of safety will be achieved because these

sma ll UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land im mediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to in i tiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equiva l ent level of safety. An exemption granted to Robert Barnes wou l d permit its operation of lightweight, unmanned, remotely contro lled, sUASs in a tightly controlled environment with limited airspace. Robert Barnes utilizes local business' safety officers in specifically determ i ned areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goa l s. Te chnical enhancements to current safety controls will allow Robert Barnes to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being imp l emented by the FAA and Department of Transportation. Further, Robert Barnes DBA Came rawork Video & Photography conducts its operations in compliance with protocols described here i n or as otherwise established by the FAA.

II. C o m me rci a l and Publi c Benefit sI Robert Barnes believe that granting this exemption request furthers the public in terest by providing safe (by way of an unmanned system) and efficient means to meet technical problems so lvable by elevated data collection instruments. Robert Barnes client base are typically small to medium sized business' looking to increase their aware ness of structures or landscape on their respective properties through data collection other Public Interest
aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption to the petitioner would allow him to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economic growth by providing information to compan ies looking to relocate or build in the North Tampa area.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 by photographic, videography. By moving these functions onto sU A S base d a ir craft, the potential for l oss of life or pro p e rty i s diminished due to the g r eater con tr o l in a smaller and safe r aircraft that holds no persons. Second, th ere are n o r eac tiv e or combustible mat e rial s on board the sU AS and thus the pot e nti a l for fire or explosions i s greatly diminished. Third

, the

s mall size and extreme man e uverability of Robert Barnes UASs allow the PIC to avo i d hazards. Acco r dingly, Robert Barnes UASs have operated and will contin ue to operate at and above current safety levels. A

. The c os t s and b enefits of you r propo s ed a ct i on t o socie t y i n general and s p eci fi c gr o up s wi th i n s ociety
A s d escr ibed above, Robert Barnes DBA Camerawork Video & Photography past customers have been small to medium business seeking Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or lux ury homeowners can afford to absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic rash that the various communities have

ex perienced in the past with military aircraft and medical helicopter crashes within a even cities. Each resulting in loss of life, each with combustible fuel that exploded and burned on impact. My, Robert Barnes

, UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting

m y, Robert Barnes

, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the NW Florida area. My ultra light weight UAS is battery powered and creates no emissions that can harm the envir onment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.Utilizing s UASs minimizes the re quirement for c on ventiona l airc raft. Th i s eliminates the need for an onboa rd pilot, time consumin g adherence to regulations s urroundin g bookkeeping a nd

s ubmi ss ion of fli g ht path s to l ocal civilian or milit a ry airports, and detrim e ntal effec ts to the enviro nment caused b y operating a co mbustib l e fuel bas e d, l arge sca le aircraft, with

r es tri ct i ons on the proximity to the targ e t for remote sensing.

The impact to society, financial and otherwise, would be extr emely minimal. In d eed, it's bee n demonstrated th a t sUASs ha ve the abi lit y t o drastically increase the inf o rmation available to policymakers at a frac ti on of the cos t of measurin g th i s d ata by terrestrial m ea n s. One s uch impact would be inconvenience to directly proximal and non

- esse nt i a l p e r s onne l that w ou l d b e displaced from public or busin ess owned p r operty if it is d ee med to be unsafe. In this case we relay our needs for a f1ight zone with the r e quir e m en t that i t be safe from casual in trusions and allow the business time to sh ift operations in order to m i nimize potential safety issues. This is best perform ed with the aid of safety p erso n ne l that actively steer n o n

- essent i al persons around

t h e flight zone

.

F l i g h t Capabi l it i e s a n d Ch ara c t eris ti c s of Robert Barnes UAS s Pursuan t to 112 P.L. 95 §333 (a), c oncerns for public safety are mitigated by the overall capabilities and char acter istics of the sUAS. Robert Barnes UAS s utili zes four (4) counter

- rotating 9 inch propellers paired oppositely to each other for balance, control and stability. The total s pan of the sUAS i s less than ""'1.2 m a ll owing for stab l e flight or l anding even with the sudden onset of d etrim e ntal

e nv i ronmenta l conditions. The sUAS's hav e a maxima l un i t+ payload ma ss of 11kg, including cinematic/photographic or other surveyi ng e quipment. Robert Barnes sUAS is designed to prim arily hover in place to cap tur e photographic data a nd then operate a t l ess than a 35 knot maximum s p eed to th e n n ext point of interest. They are capable of vert i cal and horizontal operations but, in practice, is opera ted only w i thin unaided VLOS of the PIC. In addition to the PIC, Robert Barnes has been actively producing aerial photographs and video for over 20 years
via conventional helicopter or fixed wing aircraft and a 20ft Helium Blimp (tethered) with an
i mpeccab le safety record.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In the

event of loss of visua l of the UAS, the PIC can change flight co ntrols from cartesian (X,Y,Z) based controls to radial (r, a ,h) based controls which a ll ows the PIC to utilize one controller axis to recall the VAS to the PIC's position without concern to the curr ent heading of the sUAS. In the event of loss of sight of the sUAS into an area co nt a ining hazards or possible hazards, the spotter ha s a heads

- up

- display containing a live video feed which can be used to locate the UAS wh il e it maintains it's position in hover mode. The sUAS has demonstrated
it's ability to main tain it's position by GPS coordinates in hover mode in 25 kts or greater wind gusts at rvr less than 25 feet representing an extreme environmental condition beyond the range of cond i tions within the scope for sUAS operation.

All of Robert Barnes sUASs ut ilize LiPo (lithium polyme r ) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight

areas per phase. The maximum flight time without payload is 22 minut es, however practicalsafe operation limits this to ( 10 ) minutes to give amp le time to control the sUAS to a safe landin g zone. Robert Barnes further restricts flight time by not operating it s s UASs with less than twenty five percent battery capacity

. Further safety management systems in place include a GPS mode that allows Robert Barnes sUASs to hover in place if communication with the PIC is lost and optionally follow a set of waypoints at a se t speed and height to a 'home base' predesignated safe l anding zone. In the event of unforeseen motor(s) failure, the system will
enter into a controlled descent while allowing full use of all UAS flight controls by the PIC. All commands sent via remote co ntroller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's realtime 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity. This assures that i f one system is compensate d a safe and successful landing can still occur.

I V. Reasons Why an Exempt i on to Robert Barnes Wi ll Not Adversely Affect Safety Standards Robert Barnes contends that operation of it's sUASs will not "create a hazard to users of t he national airspace system or t h e public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of Robert Barnes sUASs, combined with their operation in cordoned off and well

- controlled areas, Robert Barnes sUASs falls within Co ngr ess's contemplated safety zone. Robert Barnes sUASs have an established safety record bolstered by multi

- point preflight check li st, awareness of their surroundi ngs and intim ate knowledge of the behavior of the sUAS platform in many weather conditions. Th is safe ty record and impl emented operational pra ctices demonstrate an awareness of public safety. Robert Barnes operations routinely provide a level of safety at least equal to existing rules, and in nearly every instance, exceeds existing rules. Robert Barnes has worked very close l y with the regional vendors and support for this unit to create a tightly integrated and highly tolerant platform that has been tested thoroughly by a vendor with a proven record for safety and solid designs. Robert Barnes also contin ues to work closely with organizatio n to identify and mitigate sUAS platform risk due to their expertise in several industries closely related to th e aviation and transportation. Robert Barnes does not operate its UASs on or near airports and generally has only operated its fleet on private grounds with co r doned off areas or

areas under the control of the property owner I client with assistance by sa fety officials employed by the business. Robert Barnes determines the areas needed to fulfill the clients ' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby groups and recently codified by relevant FARs.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform A ct of20 12 Robert Barnes standardized on the foll owing practices to ensure safe operation of it's UASs:

• Work wi th on

- site pers onnel to plan the flight goa l s, • Work with on

- site personnel to restrict
access to non

- esse ntial persons,

• Operation by unaided VLOS operation only,

• Operation in phases 10 minutes in length,

• Operation to minimal 25% battery power,

• Operation of d ev i ce t o GPS aided readout to 200ft at maximum,

• Num e rous pre

- programmed fail

- safes that ensure specific b e havior per i ss u e,

• Three m a in roles s upplemented by on

- s it e safety p e rsonn e l

,

• E mpl oy contro ll ed life cycle management of compon en t s to g uard against multipl e failures,• Preform a site check day(s) before flight t o identify pot en ti al issues,

• Subscribe to relevant local wea ther and safety a l erts,

• Expertly choose data collection in stru m ents and accessories to minimize flight requirements or expe r tise,

• Robert Bar nes has exper i ence in sim ilar fields and has a d apted this experience in it's use of UASs to increase safety. In co mbination to th e ever expanding knowledge

r eposito ri es from hobbyist s and experts alike, Robert Barnes i s constant ly evo l ving it 's practice s w hen th e r e is a clear benefit to ope ration s or increas ed safety e l ement. **A. Summary** Pursuant t o 14 C.F. R. Part 11

, the following summary i s provid e d for publication in the Federal Register, sho uld it b e d eter min ed that publication is needed: Robert Barnes { applican t ) see k s an exemption from the fo llowin g rul es : 1 4 C.P.R. §2 1, s ubpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to operate commercially a small unmanned ve hicle (11kg or less) in elevated photographic and r e mo te sensing ope r at i ons. Approval of exemptions allow in g commercial operat ion s of sUASs in the media indu stry will

e nha n ce safety by reducing r isk associated wit h conventional aircraft ope r ations and othe r

means of elevated r e m ote sensing involving persons. The public benefit se r ved by approval of this petition i s increased aware n ess o f character i stics of difficult imaging targets. A sUAS

we i ghing fewer than 1lkg and powered by sealed batteries eliminates virtually all associate d risk inherent in operating conven tion al aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they woul d be able t o collect needed d a t a. The operation of sma ll UASs, we ighting less than 55lbs., co ndu cted in the str i c t conditions outlined above, will provide an eq uival e nt l e vel of safety supporting the grant of the exemptions requested herein, including exem pting the app li ca nt from the requirements of Part 21 and a llowing c omm erc ial operations. Robert Barnes 4610 Lake in the woods Drive, Spring Hill, Florida 34607 PIC VLOS Best,

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

As identified and described herein, Robert Barnes DBA Camerawork Video & Photography , is an experienced, recognized media services p r ofessional in the various photographic industries. Mr. Barnes and his companies have been producing and delivering media and t ec h nical solutions for the media service in du stry for twenty (20 ) years wit h a spot l ess safety record. The FAA has b een given the author i ty t o i ss u e the exemption to Robert Barnes purs u ant to the Federa l Aviation Act, 85 P.L. 726 (1958), and as such, we hu mbly seek your consideration and approval of this petition. encl: Supplement A: Physica l characteristics of UAS encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in Robert Barnes regional base

VI. Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM) • All regular and i rregular ope r ations are noted w i th t i mestamps, relevant UAS metr i cs andco rrective action procedures (CAP) that are performed.

- Note: All irreg u l ar behavior have root cause analysis performed before UAS operation is resumed. Emergency Pr oce du r es • Loss of Remote Signal

- The flight package features an optional enhanced fail

- safe which returns the UAS to the h ome base waypo i nt via the same path taken to point of lost signal.

- The UAS will then prefo r m a hover over this waypoint and then a co n tro ll ed landing. • Loss of GPS signal

- The system will operate in GPS assisted mode with three (3) satell i tes.

- At l oss of three (3) GPS satellites, manual mode can be activated or the flight package can be programmed to preform a controlled landing to the home base waypoint.

- Ground based height ranging is prefo r med by a separate system and so l oss of GPS w i ll not impact controlled landing in a safe manner. • Loss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the system will enter into controlled spin where all controls a r e trans l ated based on current

o rientation and will behave as normal operation to the PIC to ensure a safe l anding,

- I n the event of multiple rotor or motor failures the flight package can be configured to preform a safe l and i ng or attempt operat i on to home base waypoint.

- Note : Behavior of the landing location is highly dependent on the position and number of rotors/motors that are affected.

• Loss of Ground Control Software

- This w ill not affect operation of the flight. The unit will be piloted to a safe l anding area and then l anded so that examination of the link can be made.

**DJI Phantom Information**

http://www.dji.com/product/phantom-2-vision-plus/spec

Phantom 2 Quick Start Guide

Smart Flight Battery Safety Guidelines

Phantom 2 Vision+ User Manual (EN) v1.8

Phantom 2 Vision Plus Pilot Training Guide v1.1

NAZA M Quick Start Guide v1.26