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.comPetition 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 aDJI 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 (seeRegarding 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 ofclouds 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 developmentiii. 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.