September 23, 2015

Pro Presenters, LLC

Steve Patrick

PO Box 721320

Norman, OK 73070

Phone: (405) 364-5400

Fax: (405) 928-5990

Email: info@propresenters.com

US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request Section 333 the FAA Reform Act of 2012 

Attachments: 

1) Copy of Aircraft Registration Application

2) Drone Preflight Checklist

References: 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0418 in the matter of 

the petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0S08 in the matter of 

the petition of ADVANCED AVIATION SOLUTIONS, LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-03SS in the matter of 

the petition of FLYING CAM INC 
Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting Petition for Exemption under 

Section 333 of the FAA Modernization and Reform act of 2012, I Steve Patrick, owner and 

operator of Pro Presenters, LLC referred to hereafter as the petitioner, request exemption to 

the following sections of Title 14, Code of Federal Regulations: 

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 Administration (FAA) for the purposes of Aerial 

Photography, Cinematography, Videography, 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 US National Airspace System as compared to a manned aircraft. 

Operations will only be performed at the request of and with the authorization and consent 

of clients and their authorized agents in order to facilitate commerce and raise awareness of 

beneficial uses of small UAS. 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. 

Federal Acquisition Regulations

The petitioner seeks the exemption from the above mentioned FARs for the following 

reasons: 

91.119(c) As discussed in Exemption 11139 (Douglas Trudeau), operations conducted 

closer 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 modification, waiver or exemption and clarification concerning the terms 

of "congested areas" and "densely populated." The petitioner requests waiver for this 

condition to allow reasonable and responsible operations in areas of subdivisions and 

neighborhoods. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU), this is inapplicable since 

the UAS does not have an altimeter and instead utilizes 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 prescribed 

minimums including Exemption NO.s 2689, 5745, and 10650. In addition similar UAS 

specific relief has been granted an Exemption No.s 8811, 1080, and 10673 for daytime, 

VFR operations. The UAS provides battery power remaining in percent to the PIC. The UA 
batteries provide approximately 25 minutes of powered flight. Information provided in the 

operating documents discusses procedures regarding remaining battery power 

management. The documents contain a condition in which the PIC will initiate a landing 

procedure when the 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); 91.409(a) (1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 

(DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure the UAS is in a 

condition for safe flight in accordance with the operating documents. The FAA found that 

adherence to the petitioners operating documents and the conditions and limitations 

specified, describing the requirements for maintenance, inspection and record keeping, 

were sufficient to ensure that safety would not be adversely affected. 

Unmanned Aircraft System:

The DJ I Phantom 3 Advanced is a highly successful consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) 

designed primarily to carry a high definition camera aloft. They have an advertised 

maximum speed of less than 30 kts (15 rn/s) and a maximum climb rate of less than 1200 

fpm (6 m/s), The UAS is powered by 4 electric motors with a distance between the motors 

of less than 14 inches (350 mm). It utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor to augment with Global Positioning System (GPS) to maintain 

its geospatial orientation and position. It is controlled primarily through an FCC certified 

radio control (Re) unit. Real time video and telemetry information is transmitted back to a 

ground control station allowing the operator and/or PIC to monitor battery level, GPS signal 

strength, altitude (AGL), distance from the 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 will 

warn the pilot via telemetry data and external lighting cues before reaching a low battery 

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

predetermined low state. It is anticipated that flights will usually last less than 15 minutes. 

Risk Mitigation

The petitioner has reviewed FAA exemptions references 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 

has been created (see attachment 2) and a post flight checklist will be developed and 

implemented to ensure that UA airworthiness will be maintained for flight operations. Flight 

time and maintenance logs will be maintained to ensure tracking on failure prone 

components. 

The petitioner requests that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that: 
"The UAS may not operate in Class B, C or D airspace without written approval of the FAA. 

The UAS may not operate within five nautical miles of the geographic center of a nontowered airport as denoted on current FAA-published aeronautical chart unless 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 management must be made available to the Administrator upon request. "

Operations within 5 miles of an airport are not anticipated to be routine, but the petitioner is 

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption should the need arise. Operations within class B airspace are not requested due 

to the lack of a mode C transponder. 

Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce 

environmental impact compared to similar operations conducted with much larger fuel laden 

manned aircraft. Additionally, the use of UAS to facilitate commerce can help to encourage 

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 valuable marketing tool that can facilitate 

increased commerce and enhance personal photography. Crop surveying and inspections 

could lead to decreased use of pesticides and fertilizer and conservation of water as well as 

increased crop yields and decreased costs. Aerial surveying and inspections can increase 

work site efficiency, improve volumetric estimations and reduce risk. The petitioner will 

provide clients with the photographic data for these purposes in 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 the FAA for use in collecting data regarding the 

use of UAS as a part of this application. This data can be submitted to the FAA via reports 

as required by the FAA. 
Conclusion

The petitioner is requesting this exemption for the purposes of "aerial photography, 

cinematography, videography, mapping, inspections and other flight operations." The 

reason for such a general and broad based request is that the petitioner wishes to utilize a 

strategy that allows maximum flexibility to utilize the UA to its fullest potential within the 

constraints of this request, without the long turnaround time associated with additional 

exemptions. The petitioner plans to offer services to individuals or companies seeking to 

enhance their business in a safe and lawful way. The petitioner knows that there is 

extensive demand for lawful aerial photography and videography.

The petitioner owns UAS, DJI Phantom 3 Advanced which he has flown from his own 

property and various other locations with owner consent to develop flight and photography 

experience. He has executed many takeoffs and landings, and has demonstrated 

continuous proficiency. He has experience with the fail safe modes of the aircraft, having 

run himself through non-normal procedures as described in the DJI operating manual. The 

petitioner plans to utilize the UA below 400' AGL, within visual line of sight (VLOS), within 

500' laterally of the PIC, and with a visual observer at all times. 

Sincerely,

Steve Patrick

Pro Presenters, LLC