Light	and	Glass	Studio,	LLC	(Roy	Adkins)

775	Pinehurst	Place

Jackson,	MS	39202

U.	S.		Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.	,	SE	Washington,	DC	20590	

Federal	Aviation	Administration	Exemption

Petition	for	Exemption	under	Section	333

FAA	Modernization	and	Reform	Act	of	2012

Public	112-95	Feb.		14,	2012,	Section	333

Submitted	by:	Light	and	Glass	Studio,	LLC.		(Roy	Adkins)

References:	

1) FAA	Exemption	No.		11138,	Regulatory	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.		FAA20140355	in	the	matter	of	the	petition	of	

FLYING	CAM	INC	

Date:	9/11/2015

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,	Light	and	Glass	Studio,	LLC	(Roy	Adkins)	,	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,	and	other	flight	operations	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	1-3.		

The	FARs

The	petitioner	seeks	exemption	from	the	above-mentioned	FARs	for	the	following	reasons;	
61.	113(a)	&	(b);

The	petitioner	requests	relief	in	order	to	facilitate	the	utilization	of	an	FAA	licensed	Private	Pilot	(Roy	Allan	

Adkins,	Cert	#	2763846	)	with	the	addition	of	a	visual	observer.			All	pre-flight	inspection,	maintenance	and	

flight	logs	will	be	saved	and	made	available	to	the	FAA	and	Secretary	of	Transportation	(SoT)	for	review;	

with	the	purpose	of	safely	integrating	civil	UAS	operation	in	the	National	Airspace	System.		

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.		

The	petitioner	will	primarily	operate	the	UAS between	ground	level	and	200	feet.		The	UAS	will	be	operated	

over	designated	properties	with	the	owner’s	consent	and	while	maintaining	a	safe	distance	from	persons.		

The	petitioner	will	compile	flight	data	from	the	logs.		This	data	may	assist	the	FAA	in	development	of	

regulations	for	commercial	operations	in	low-risk,	controlled	environments.		

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,	

5745,	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	recordkeeping,	were	sufficient	to	ensure	that	

safety	would	not	be	adversely	affected.		

The	UAS

The	DJI	Phantom	2	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	controlled	automatic	landing	will	be	initiated	when	the	battery	reaches	a	predetermined	low	

state.		It	is	anticipated	that	flights	will	usually	last	less	than	12	minutes.		More	information	is	available	via	

the	link	to	the	DJI	Phantom	2	UAS	Manual	("Manual"),	which	outlines	the	operating	requirements,	

limitations,	and	technical	specifications	for	the	DJI	Phantom	2	system.		

http://www.dji.com/product/phantom-2/download

Risk	mitigation

The	petitioner	has	reviewed	FAA	exemptions	reference’s	1-3	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.		These	documents	will	be	made	available	to	the	FAA	and	SoT	to	assist	in	future	

implementation	of	safety	standards	and	regulations.		The	petitioner	will	only	operate	the	UAS	over	

designated	properties	with	the	owner’s	consent.		Flight	plans	will	be	predetermined	to	limit	the	UASs	flight	

time	and	limit	safety	concerns.		The	petitioner	will	take	into	account	distance	from	persons	and	potential	

flight	obstacles	prior	to	operating	the	UAS.		UAS	operation	will	always	be	within	VLOS	of	the	PIC	and	the	

observer.		

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.		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.		A	visual	observer	will	be	utilized.		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.		This	data	may	

be	submitted	to	FAA	via	traditional	means	or	other	means	as	required.	

Conclusion

The	petitioner	is	requesting	this	exemption	for	the	purposes	of	“aerial	photography,	cinematography,	

videography,	inspections	and	other	flight	operations”.		The	reason	for	such	a	general	and	broad	based	

request	is	that	the	petitioner	wishes	to	utilize	a	business	strategy	of	horizontal	integration	and	maximize	
economies	of	scope	in	order	to	capitalize	on	opportunities	as	they	may	arise	in	the	future	without	the	long	

turnaround	time	associated	with	additional	exemptions.		The	petitioner's	business	model	is	based	on	the	

idea	of	offering	ad	hoc	small	UAS	services	to	individuals	or	companies	who	wish	to	employ	these	services	as	

a	safe,	effective,	and	legal	option	to	enhance	their	business	or	hobby.		The	primary	purpose	of	seeking	this	

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

Sincerely,

Roy	Adkins

Light	and	Glass	Studio,	LLC