U.S. Department ofTransportation Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 Dec 28, 2015

SUBJECT: Petitionto Amend ExemptionNo.l3689, Pursuant to Section 333 ofthe FAA ReformAct and Part II ofthe Federal Aviation Regulations from: 14 CFR 61.1 13{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(l); 91.409 (a)(!) and {2}; 91.417{a) & (b).

Ref: ExemptionNo. 13689 Regulatory DocketNo. FAA-2015-3844

This petitionis being submitted onmy behalfofHigh Angle Images L. L. C.

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act), and 14 C.F.R. Part 11, Travis L. McKinney, a freelance photographer, hereby applies to amend granted exemption from the Federal AviationRegulations (FARs) listed belowto allow operation ofan Unmanned Aircraft System (UAS) commerciallyin airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permitTravis L. McKinney to pursue his commercial interests in providing services to clients using a UAS in the following areas: Real Estate, Marketing, Land Management/Surveying, Special Events, and Cinematography. Travis L. McKinney states that all UAS flights will occur overprivate orcontrolled access prope1ty and will do so withthe property owner's consent and knowledge and that only people who have consented orotherwise have agreed to be within the UAS'sradius during filming andphotography applications.

Travis L. McKinney has demonstrated the ability to safely and effectively fly the UAS DJI Phantom 3 and DJI Inspire which will be used for commercial and private purposes. He complies with local ordinances and laws regarding the operation ofUAS, and adheres to all weather and environmental restrictions or limitations inreferenceto the operations ofUAS. Additionally, he has completed training associated to the operation ofUASs. Courses include: Basic UAS Qualifications Level l, Meteorology, Navigation, and Airspace Design and Operating Requirements.

All flights will in accordance with any and all state or local laws regarding privacy.

1I, Travis L. McKinney am seeking to amend ExemptionNo 13689 because I have added a new UAS (DJI Inspire). I am committed to complying with all ofthe rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the UAS inthe manner that I have described, and for the purposes that I have described. I have been granted an exemption and I continue to safely and effectively run my business legally, and it is my intention to continue to comply with the FAA and all regulations.

The following contains my list ofregulations from which I am seeking an amendmentto my approved exemption, and a complete list ofresponsibilities I assume as operator; it also contains informationregarding the aircraft, public benefit and safety features, and similarpetitions requests granted.

Regulations from which exemption is requested:

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a) & (b), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b) (2), 14 C.F.R. 91.109, 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 C.F.R. 91.203(a) & (b), 14 C.F.R. 91.205(b), 14 C.F.R. 91.215, 14 C.F.R. 91.401-91.417



### I, THE OPERATOR,ASSUME THEFOLLOWING RESPONSIBILITIES I. Operations authorized by this grant ofexemption are limited to the DJI Phantom 3 and DJI Inspirewhen weighing lessthan55 pounds including payload. Proposed operations ofany other aircraft will require a newpetition or a petition to amend this exemption. 2. Operations for the purpose ofclosed-set motion picture and television filming are not pennitted. 3. TheUA maynot be operated at a speed exceeding 87 knots (I00 miles perhour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA mustbe operated at an altitude ofno more than400 feet above ground level (AGL). Altitude must be rep01ied in feet AGL. I the operator will stay below200 feel AGL. 5. TheUAmustbe operated within visual line ofsight (VLOS) ofthe PIC atall times. This requires the PICto be able to use human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airmanmedical certificate orU.S. driver's license. 6. All operations mustutilize a visual observer (VO). TheUA must be operated within the visual line ofsight (VLOS) ofthe PIC and VO at all times. TheVO may beused to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. TheVO and PIC must be able to communicate verbally at all times; electronic messaging or texting is notpetmitted during flight operations. The PIC must be designated before the flight and cannottransfer his orher

2designation for the duration ofthe flight. The PIC must ensure that the VO canperform the duties required ofthe VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance withthe conditions and limitations stated in this grant ofexemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administratorupon request. Ifa discrepancy exists between the conditions and 4 limitations in this exemption and the procedures outlined inthe operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update orrevise its operating documents. Itis the operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official uponrequest. The operator must also present updated and revised documents ifitpetitions for extension or amendment to this grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted this exemption, then the operatormust petition for an amendmentto its grant ofexemption. The FAA's 

### VAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates

orrevisions to the operating documents. 8. AnyUAS that has undergone maintenance oralterations that affectthe UAS operation or flight characteristics, e.g., replacement ofa flight critical component, must undergo a functional test flight priorto conducting further operations under this exemption. Functional test flights may only be conducted by a PIC withaVO and must remain at least 500 feet from otherpeople. The functional test flight must be conducted in such a manner so as to notpose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that itis in a condition for safe operation. 10. Priorto each flight, the PIC must conduct a pre-flightinspection and determine the UAS is in

a condition for safe flight. The pre-flight inspection must accountfor all potential discrepancies, e.g., inoperable components, items, orequipment. Ifthe inspectionreveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformedand the UAS is found to be in a condition for safe flight. 11. The operatormust follow theUAS manufacturer's maintenance; overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraftcomponents. 12. EachUAS operated underthis exemption must comply with all manufacturer safety bulletins. 13. Underthis grant ofexemption, a PIC must hold either an airline transport, commercial, private, recreational, or spottpilot certificate. ThePIC must also hold a current FAA airman medical certificate ora valid U.S. driver's license issued bya state, the District ofColumbia, Pue1to Rico, a teJTitory, a possession, orthe Federal government. The PIC must also meet the flight reviewrequirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his orherpilot ce1tificate. 5



### 314. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistentwith 14 CFR 

### § 61.51(b). Flights for the purposes oftraining the operator's PICs and VOs (training, proficiency, and experience-building) and determining the PIC's abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permittedunder the terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance Jl'om nonparticipants in accordance with 14 CFR 

### § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR 

### § 1.1. All operations must be conducted undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. TheUAmaynot operate within 5 nautical miles ofan airportreference point (ARP) as denoted inthe current FAA Airport/Facility Directory (AFD) orfor airports not denoted with an ARP, the center ofthe airport symbol as denoted onthe current FAA-published aeronautical chart, unless a letter ofagreementwith that airport's management is obtained or otherwise permittedby a COAissued to the exemptionholder. The letter ofagreement with the airport management mustbe made available to the Administrator or anylaw enforcement official upon request. 17. The UAmay not be operated less than 500 feet beloworless than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 

### 18. Ifthe UAS loses communications orloses its GPS signal, the UAmustreturn to a predetermined location withinthe private orcontrolled-access prope1ty. 19. The PIC must abort the flight inthe event ofunpredicted obstacles oremergencies. 20. The PIC isprohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available powerfor the UA to conduct the intended operation and to operate afterthat for at least five minutes or with the reserve powerrecommended by the manufacturer ifgreater. 21. AirTraffic Organization (ATO) Certificate ofWaiver orAuthorization (COA). All operations shall be conducted in accordance with anATO-issued CO 

### A. The exemptionholder may apply for a new or amended COA ifitintends to conduct operations that cannotbe conducted underthe tetms ofthe attached COA. 6 22. All aircraft operated in accordance with this exemptionmust be identified by serial number, Tegistered inaccordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings mustbe as large as practicable. 23. Documentsused by the operator to ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR 

### §§ 91.9 and 91.203 mustbe available to the PIC atthe



### 4Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 24. TheUAmust remain clear and give way to all manned aviation operations and activities at all times. 25. TheUAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipatingpersons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/ordebris in the event ofan accident. The operator must ensure that nonparticipating persons remainunder such protection. Ifa situation arises where nonparticipatingpersons leave suchprotection and are within 500 feet ofthe UA, flight operations must ceaseimmediately in a manner ensuring the safety ofnonparticipating persons; and b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does notpresent anundue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted overprivate orcontrolled-access prope1ty withpermission from the property owner/controller orauthorized representative. Permission from property owner/controller or authorized representative will be obtained for eachflight to be conducted. 28. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must bereported to the National Transportation Safety Board (NTSB) perinstructions contained on the NTSB Web site: www.ntsb.gov.

SIMILAREXEMPTIONS

They are similar in all/or many material respects to reliefpreviously requested in Grant of ExemptionNos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmam1ed Aircraft System UASs are often seen as superiorto helicopters as an aerial video gatheringplatform due to the smaller devices cheaper equipmentand personnel cost, reduced noise and as such, a much smallerenvironmental impact which promotes public safety. I ampetitioning to Amend Exemption No 13689 to operate a DJI Phantom 3 and DJI Inspirer with a built-in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius ofthe distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including

a no-fly zone feature.



### 5The DJI Phantom 3 and DJI Inspire also have a failsafe function that is triggered in the event communication is lost between the UAS and the main controllertransmitter. At that time, the UAS will return to its point oftakeoffand land safety. Ifthe connection is restored, the PIC can regain control offlight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set below:

• Thepetitioner will only operate its UAS in line-of-sight ofa pilot and/or observer and will operate at sites that are 'sufficient distance' from populated areaswithin the sterile area described in the FOPM. Such operations will ensure thatthe UAS will "notcreate a hazard to users ofthe national airspace system orthe public."

• Whenflying the UAS within three (3) miles ofan airpott, airpott operators will be notified and the operator will give the right-of-way to avoid flying in the proximity offull-scale aircraft. Maximumflight time for each operation will be 30 minutes.

• Flights will be terminated when battery levels reach 25%, allowing sufficientreserve flight time to safely land the UAS.

• The UAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned.

• Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

• The UAS PIC will be an FAA licensed airman holding a minimum ofa Private Pilot certificate and a current FAAmedical certificate.

• The UAS operated by the petitionerweighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

• The UAS will operate at speeds ofno more than 50 knots, can hover, and can simultaneously

move vertically and horizontally.

• Given the small size ofthe UAS and the restricted sterile environmentwithin which it will operate, SkyVideoCT's operations adhere to the Reform Act's safety requirements.



### Ifyou have questions orneed additional information, please contact me at travismckinney2@yahoo.com or (517 755-7077.

Sinc·e·.rely 

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Travis 

### L. McKinney Gunner (CW03) U. S. Marine Corps High Angle Images 

### L. L. C.

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