UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DigitalRoamer Media LLC

FOR AN EXEMPTION SEEKING RELIEF FROM

THE REQUIREMENTS OF THE FAA REFORM ACT AND

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on November 3, 2015

Michael M Worley

642 Johnston Street, Unit #6, Half Moon Bay, 94019

DigitalRoamer Media LLC

642 Johnston Street, Unit #6

Half Moon Bay, CA 94019

www.digitalroamer.com

Info@digitalroamer.com
Petition for Exemption to Operate Unmanned Aircraft in the National Airspace

System Under Section 333 of the FAA Modernization and Reform Act of 2012

Petitionor:

Michael M Worley, Manager, sUAS Operator

DigitalRoamer Media LLC

642 Johnston Street, Unit #6

Half Moon Bay, CA 94019

mworley17@gmail.com

650.276.0265

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11, DigitalRoamer Media, LLC, (“{Company}”) Operator of Small

Unmanned Aircraft Systems (“sUASs”) equipped to offer on-demand commercial UAS

operations for a host of industries and applications and to perform the purposes listed below,

hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow

commercial operation of its sUAV’s/UAS, so long as such operations are conducted within and

under the conditions outlined herein or as may be established by the FAA in an exemption

granted under either Section 333 or Section 49 U.S.C. §44701(f)

As described more fully below, the requested exemption would permit the operation of a UAS

under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide

safety enhancements in the fields in which it will operate, which now depend upon conventional

aircraft or humans climbing high on dangerous structures, walking in insect laden swamps, and

working adjacent to treacherous infrastructure. Approval of this exemption would thereby

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s)

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the

national airspace system.” Section 333(c) of the Reform Act.1

SUMMARY

Regarding the Unmanned Aircraft System

I. How the proposed UAS operation will be safely conducted to minimize risk to the

NAS or to persons and property on the ground.

We intend to use a DJI Quadcopter Inspire 1. Includes the Aircraft,

Gimbal, Camera, Remote Control, Battery

1

{Company} relies upon the following exemptions where specific reference to an exemption is

not provided: Exemptions 11062 thru 11067, 11080, 11109 through 11112, 11114, 11213, 11062

and as recent as 11857.
a. Summary of Design and Operational Characteristics

i. Size: 438x451x301 mm

ii. Weight: 2935 g

iii. Speed:

1. Max Ascent Speed: 5 m/s

2. Max Descent Speed: 4 m/s

3. Max Speed: 22 m/s no wind

iv. Operating Area: Limited to Visual Line of Sight in ecological

survey areas (see Regarding the Operation of Unmanned

Aircraft)

b. DJI Inspire Aircraft Specs

i. Model: T600

ii. Weight (battery included): 2935 g

iii. Hovering Accuracy: Vertical 0.5 m, Horizontal 2.5 m

iv. Max Angular Velocity: Pitch 300 deg./s, Yaw 150 deg./sec

v. Max Tilt Angle: 35 deg

vi. Max Ascent Speed: 5 m/s

vii. Max Descent Speed: 4 m/s

viii. Max Speed: 22 m/s no wind

ix. Max Flight Altitude: 4500 m

x. Max Wind Speed Resistance: 10 m/s

xi. Max Flight Time: Approx. 18 minutes

xii. Motor Model: DJI 3510

xiii. Propeller Model: DJI 1345

xiv. Operating Temperature Range: -10 to 40 deg. C

xv. Diagonal Distance: 559 to 581 mm

xvi. Dimensions 438x451x301 mm

2. Procedures to be implemented to ensure the UAS is in a condition for safe flight

a. Operating Procedures

i. The PIC will be thoroughly familiar with the aircraft and interface

ii. The PIC will use pre-flight checklists to ensure the UAS is

airworthy and does not pose a threat to persons or property on

the ground or in the air

iii. The PIC will ensure the UAS is maintained, and repaired if

necessary, to ensure the aircraft is in a condition for safe flight

iv. The PIC will ensure instruments read correctly (ie altimeter).

v. The PIC will continually assess terrain and avoid potential

obstacles/hazards in the area of operation

vi. The PIC will assess weather to ensure the UAS is airborne only

with minimums of 3 SM visibility while remaining clear of
clouds in Class G Airspace (or required minimum clearances in

other Airspace classes)

vii. The PIC will immediately avoid and give right of way to any

manned aircraft

viii. The PIC will keep the UAS at no greater altitude than 200 feet

AGL and always within line of sight.

3. Radio Frequency Spectrum (Remote Controller only transmitting equipment)

a. Operating Frequency of Remote Controller: 5.725-5.825 GHz, 2.400-

2.483 GHz

b. Complies with the Federal Communications Commission requirements

Regarding the Unmanned Aircraft PIC

1. Qualifications of PIC

a. All UAS operations will be conducted by Michael M. Worley

i. Gold Seal UAV Ground School

ii. Trained in the use of UAS with RealFlight 7 flight simulator,

CopterShop Kelby One Inspire 1 training course,

Vidmuse Multi Rotor Tutorial Series for Filmmakers , 51 hours

Flight Simulator, 22 hours Ground School & 63 hours DJI

Inspire 1 multirotor aerial flight time.

iii. Naval Aviation Aircrew Candidate School graduate.

2. Medical standards and certification of PIC: not required under FAA

Ground School written certification

Regarding the Operation of the Unmanned Aircraft

1. Description of UAS Operations

a. We propose to use UAS for image/video electronic field productions, highresolution georeferenced, orthomosaic mapping & surveying of property

and worksites. Services that we will provide include:

i. Fly fishing industry - i.e. aerial filming of single-handed

fly rod, switch rod and two-handed Spey rod fishing &

casting techniques and fishing for DVD/ Blu-ray Disc

& On-Demand streaming media website distribution.

ii. Coastal Property Assessment & Survey - habitat stream

restoration for Coho salmon & steelhead, trailway development
iii. Private Forest Property Assessment & Survey - private forests

owned by non-industrial forest landowners & large timber

companies

iv. Agricultural - orthomosaic & digital terrain survey

mapping (crop scouting, actionable data acquisition)

v. Construction Site Inspection - digital elevation models

and 3D models of sites & structures

vi. Special Event Coverage - low population density informal events

b. Safety

i. Many of the above actions are currently conducted using

traditional aerial surveying in fixed wing aircraft. This is

inherently hazardous as it often entails flying close to terrain or

over water at low altitudes (i.e. surveying stream habitat). We

propose to increase safety by providing aerial imagery and so

dispense with the necessity of placing pilots and staff in

dangerous conditions.

ii. There will be very low risk to people or property as operations

will be conducted in un- or sparsely populated areas such as

marshes, protected wildlands, Coastal trailways or agricultural

lands. The PIC will ensure that the UAS cannot come in contact

with bystanders in the event of a malfunction.

2. Proposed Operating Conditions

a. Maximum Operating Speeds:

1. Max Ascent Speed: 5 m/s

2. Max Descent Speed: 4 m/s

3. Max Speed: 22 m/s no wind

b. Maximum Altitude: 200 feet AGL

c. Minimum Flight Visibility and Distance of Clouds proposed as the same

VFR rules as under the PIC sport pilot's license. LOS visibility

maintained in all situations. Clear of clouds in Class G Airspace (and in

the unlikely event of operating in Class B Airspace). In C, D & E

Airspace, will be at least 500 feet below and 2000 feet horizontal (vertical

distance above clouds

does not apply since UAS will go no higher than 200 feet over

the ground).

c. Potential Hazards: We do not anticipate significant hazards to the

operator or bystanders, but some hazards to the UAS and property may be

present. The likeliest of these are collisions with powerlines and trees. The PIC

will thoroughly assess an area of operation to identify obstacles. Since the UAS

will be kept within VLOS, visual scanning should be sufficient.
3. Characteristics of the Area of Intended Operations

a. The proposed areas of operations will be conducted in unpopulated or

sparsely populated areas. Some man made obstacles will be present such

as powerlines and towers of various kinds.

4. Proximity to Airports: We do not intend to operate in close proximity to any

airport.

5. VLOS: The PIC will be ground-based and will not allow the UAS to fly out of

sight at any time.

6. Procedures for preflight:

a. Weather conditions suitable

b. No bystanders or property at risk in area of operation

c. Operations free to perform in Airspace (contact tower if necessary)

d. No TFRs

e. Frame and all screws are tight.

f Propellers not damaged and tightly fixed.

g. Battery fully charged and securely mounted.

h. Transmitter battery charged and the antennas are free.

i. Channel of the transmitter is not busy.

j. Check RC operation range on the ground

k. Ensure there is nothing in the danger zone of the propellers.

1. Ensure enough space for launch and flight.

m. Ensure the GPS module has GPS fix. Ensure sensors are calibrated

and that the right setting is loaded. FSDOs - We do not intend to

conduct operations with existing requirements necessitating contacting

a Flight Standards District Office

7. COA — We will comply with the requirement to obtain a Certificate of Waiver or

Authorization from the FAA Air Traffic Organization prior to conduction

operations in the NAS.