Kane A Lauck 

1967 Trowbridge High St 

Carmel Indiana, 46032 

Cell (317) 400-2274 

Email: kane@kanelauck.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

January 24 2016 

u 

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

Attachments: These attachments are too large for submission via the submission portal. 

They are available at this website for viewing or download. 

http://www.dji.com/product/phantom-2-vision/download?www=v1 

1) Phantom 2 Vision User Manual (EN) v1.8 - 2015-01-30 

2) Phantom 2 Vision Quick Start Guide (EN) v1.0- 2013-10-30 

3) Phantom 2 Vision Pilot Training Guide vl.O- 2013-11-16 

References: 

1) FAA Exemption No. 11138, Hegula.tory Docket No. FAA20140481 in 

the matter of the petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in 

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355in 

the matter of the petition of FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for 

Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, I Kane Lauck 

referred to hereafter as the petitioner, request exemption from the following sections of 

Title 14, Code of Federal Regulations §§ 

61.113(a); 61.113(b); 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, that could be performed safely and more 

cost effectively with the use of small UAS at low altitude within the U.S. national 

airspace system as compared to a manned aircraft. Operations will be performed only 
at the request of and with the authorization and permission of clients or their authorized 

agents in order to facilitate 

commerce and raise awareness of the beneficial uses of small unmanned air systems. 

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 13. 

The FARs 

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

reasons; 

91.119(c) As discussed in Exemption 11138 (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 "congested areas" and "densely populated". The 

petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is 

inapplicable since the UAS does not have an altimeter and instead utilizes electronic 

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 the prescribed minimums, including Exemption Nos. 2689, 57 45, and 10650. In 

addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, 

and 10673 for daytime, VFR conditions. 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. Those documents contain a condition in which 

the PIC will initiate a landing procedure when 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)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in 

Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and 

ensure that the UAS is in a condition for safe flight in accordance with the operating 

documents. The FAA found that adherence to the petitioner's 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. 
The UAS 

The OJI Phantom 2 Vision 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 aloft a high definition camera. It has an 

advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of 

less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a 

distance between motors of less than 14 inches (350mm) It utilizes an internal inertial 

measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) 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 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 and external lighting cues before reaching a low battery state. An 

automatic termination of flight and landing will be initiated when the battery reaches a 

predetermined low state. It is anticipated that flights will usually last less than 10 

minutes. More information is available in attachment 1 or 

http://www .dji .com/product/phantom-2-vision?www=v1 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference's 13 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 will be developed and employed to ensure that the UA airworthiness 

will be verified before launch. Airworthiness will be maintained by performance of 

routine inspections before each flight, maintaining flight and maintenance logs to record 

time on failure prone components. The UAS will never be flown within 5 miles of an 

airport. 

Public interest 

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

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to 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 lead to increased commerce and 
enhance personal photography. Crop surveying applications 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 risks. The petitioner will provide 

clients with photographic data for these purposes on a /for hire' basis acting as an 

independent contractor. Liability insurance will be obtained commensurate with the 

granting of this request for exemption. Flight data including UA flight time, Control Unit 

operation time, incident, accident, and details concerning any deviations from normal 

operations will be available to FAA for use in collecting data regarding the use of UAS 

as part of this application. 

Conclusion 

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

photography, cinematography, and videography. The petitioner has refrained from 

engaging in commercial use of the UAS. The primary purpose of seeking this exemption 

is to obtain the capability to offer those services while remaining in compliance. The 

petitioner is a licensed Indiana Real Estate Agent, License number: RB14052327. 

/.·J··'' 

/ I 

Jespectfull: Submitted, 

Kane A Lauck