### 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 Managem ent 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 D ocket 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 INCDear 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 , own er 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 operation s 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 FA A as required by section 333. The conditions identified and proposed by the petitioner are drawn from references 1

- 3

.

F ederal Acquisition Re gulations

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

reasons:

91.119(c) As discussed in Exem ption 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 mo dification, 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 a n Exemption No.s 8811, 1080, and 10673 for daytime, VFR operations. The UAS provides battery power remaining in percent to the PIC. The UAbatteries provide approximately 25 minutes of powered flight. Information provided in the

operating documents discusses procedures regarding remainin g 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 operation s, 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 a nd 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, i nspection 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) , T he 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 (A GL), 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 P IC.

Bat tery 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 L imitations 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 implem ented 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 m iles 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 non

towered airport as denoted on current FAA

- publish ed aeronautical chart unless 

### a letter of agreement with that airport's management 

### is obtained, and the operation is conducted in

accordance with 

### a NO TAM as required by the operator's C 

### OA

. The letter of agreement w ith the airport management must be made ava ilable 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 nee d 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 pe rsonal 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

t ime, 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 t his exemption for the purposes of "aerial photography, cinematography, videography, mapping, inspections and other flight operations." The reason for such a general and b road 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 fa il 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