Kane A Lauck 1967 Trowbridge High St Carmel Indiana, 46032 Cell (317) 400-2274 Email: kane@kanelauck.com

U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 January24 2016



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RE: Exemption Request Section 333 ofthe FAA Reform Act of2012

Attachments: These attachments are too large for submission via the submission portal. They are available atthis website forviewing 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 2Vision PilotTraining Guide vl.O- 2013-11-16

References: 1) FAA Exemption No. 11138,Hegula.toryDocketNo. FAA20140481in the matter ofthe petition of DOUGLASTRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter ofthe petition ofADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355in the matterofthe petition of FLYING CAM INC

Dear Siror Madam,

In accordancewith the FAA's Guidelines forSubmitting a Petition for Exemption undersection 333 ofthe FAA Modernization andReform Actof2012, 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) 

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In orderto operate small unmanned aircraftsystems (UAS) commercially in airspace regulated bythe Federal Aviation Administration (FAA)forthe purposes ofaerial photography, cinematography, videography, that could be performed safely and more cost effectivelywith the use ofsmall UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed onlyatthe request ofand with the authorization and permission ofclients ortheir authorized agents in orderto facilitate

commerce and raise awareness ofthe beneficial uses ofsmall unmanned air systems. So long as such operations are conducted within and underthe conditions outlined herein oras 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 feetto the ground may require that the UA be operated closerthan 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver orexemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests waiverforthis condition to allow reasonable and responsible operations in areas ofsubdivisions 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 sensorfor altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraftto 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 10673for 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 ofthose 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 FAAfound that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficientto 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 quadcopterconfiguration with an advertised weight ofless than 44 Ounces (1242g) designed primarilyto carry aloft a high definition camera. It has an advertised maximum speed of lessthan 30 knots (15m/s) and a maximum climb rate of lessthan 1200feet per minute (6 m/s). It is powered byfour electric motorswith a distance between motors oflessthan 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 primarilythrough an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operatorand/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distancefrom PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC orGPS signal. Altitude can be limited by the onboard flight controllerand maximum altitude can be preprogrammed by the PIC. Battery life limits flighttimes to approximately 25 minutes. The onboard flight controllerwill warn the pilotvia telemetry and external lighting cues before reaching a low battery state. An automatictermination offlight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated thatflights will usually last less than 10 minutes. More information is available in attachment 1or http://www.dji.com/product/phantom-2-vision?www=v1

Riskmitigation

The petitioner has reviewed FAA exemptions reference's 13 Conditions and Limitationssection and believes thatthe procedures specified therein are reasonable and will be utilized in orderto manage and mitigate risk and ensure public safety. A preflight checklistwill be developed and employed to ensure thatthe UA airworthiness will be verified before launch. Airworthinesswill be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logsto record time on failure prone components. The UAS will never be flown within 5 miles ofan airport.

Public interest

Use ofthe UAS in lieu ofa manned aircraftwould enhance safety and reduce the environmental impact as compared to similaroperations conducted with manned aircraft ofgreater proportions, carrying a crew and flammable fuel. Additionally, use ofthe UAS in orderto facilitate commerce could lead to economic growth. Operationsforthis petition will enable service for property owners ortheir designees seeking an enhanced perspective forcharacteristics, amenities, and benefits oftheir desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is avaluable marketing tool that can lead to increased commerce andenhance personal photography. Crop surveying applications could lead to decreased

use ofpesticides and fertilizer and conservation ofwater 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 petitionerwill provide clients with photographic data forthese purposes on a /for hire' basis acting as an independent contractor. Liability insurance will be obtained commensurate with the granting ofthis requestfor exemption. Flight data including UAflighttime, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAAfor use in collecting data regarding the use of UAS

as part ofthis 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 ofthe UAS. The primary purpose ofseeking this exemption is to obtain the capability to offerthose services while remaining in compliance. The petitioner is a licensed Indiana Real Estate Agent, License number: RB14052327.

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Jespectfull:Submitted, Kane A Lauck