### US Department ofTransportation Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Sept 29, 2015 Kaniela Boyle 942 Delfino Place Lake Mary, Florida 32746
U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 1l**~** ;j• J



### 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Kaniela Boyle operatorof Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of designated UAS, provided such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. Thank you in advance foryour consideration.

### Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas:

1. Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photographyfor public and/or private use Including television, public events, cinematography and newsgathering. 3. Aerial inspection/photography of residential/commercial structures under contractwith the owners or local government authority. 4. Aerial inspection/photography ofresidential/commercial utility infrastructure including but not limitedto electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 6. Trainingto persons individually or belonging to both private and/or public organizations to increase awareness and improve safetyfor current and future UAS operations within the NAS. As described fully below, the requested exemption would permitthe operation ofdesignated UAS as set forth in this document under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) safe. Approval ofthis exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibilities to "
....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."

### The name and address ofthe applicant is: Kaniela Boyle Ph: (407)416-7727 Email: typeonetech@aol.com Address: 942 Delfino Place Lake Mary, Florida 32746 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 

### 14 CFR 61.113 (a) 

### & (b) 14 CFR 91.7 

### (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14CFR 91.121 14 CFR 91.151 (a) 14CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b) Kaniela Boyle will operate one or more ofthe 

### Following model UAS: DJI Phantom 3 Yuneec Typhoon 500 +

## DJI Phantom 3 Aircraft Weight (including battery and propellers)-1280 g Diagonal size (including propellers)-590 mm Max Ascent Speed-S m/s Max Descent Speed-3 m/s HoverAccuracy-

•Vertical:+/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m •Horizontal: +/- 1.5 m Max Speed-16 m/s {A Til mode, no wind) MaxAltitude Above Sea Level-6000 m OperatingTemperature-O"C to40"C GPS Mode-GPS/GLONASS 

## Camera Sensor-Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) Lens-FOV 94" 20 mm (35 mm format equivalent) f/2.8, focus at co ISO Range-100-3200 (video) 100-1600 (photo) Shutter Speed-8s -1/8000s Image Max Size-4000 x 3000 Still Photography Modes *Single Shot *Burst Shooting: 3/5/7 shots *Auto Exposure Bracketing (AEB): 3/5 *Bracketed Frames at0.7EV Bias *Time-lapse

## Video Recording Modes Phantom 3 Professional •UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 •FHD: 1920x1080p 24/25/30/48/50/f;,O •HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60
Supported SO Card Types- * Micro SO *Max capacity: 64GB. Class 10or UHS-1 rating required

Max Bitrate ofVideo Storage- **Phantom 3 Professional

60 Mbps **Phantom 3 Advanced

40 Mbps Supported File Formats- •FAT32/exFAT •Photo: JPEG, DNG •Video: MP4, MOV (MPEG-4 AVC/H.264) OperatingTemperature-ooc to 40°C

## Gimbal Controllable Range-Pitch -90° to +30° Stabilization-3-axis (pitch, roll, yaw)


## Vision Positioning MaxVelocity-Less than 8 m/s (when 2 m above ground) Altitude Range-30 cm-300 em Operating Range-30 cm-300 em Operating Environment-Surface with clear pattern and adequate lighting (Lux> 15)


## Remote Controller Operating Frequency-2.400 GHz-2.483 GHz Max Distance-2000m (outdoors and unobstructed) Video Output Port-USB OperatingTemperature-O.,C· 40°C Battery-6000 mAh LiPo 25 Mobile Device Holder-Fortablet or phone Receiver Sensitivity (1%PER)--101 dBm ±2 dBm Transmitter Power (EIRP) *FCC: 20dBm *CE: 16 dBm WorkingVoltage-1.2 A @7.4 V

## Battery ChargerVoltage-17.4 V Rated Power: Phantom 3 Professional 

### •lOOW Phantom 3 Advanced •57W



## Intelligent Flight Battery Capacity-4480 mAh Voltage-15.2 V BatteryType-LiPo 4S Energy-68 Wh Net Weight-365 g Max FlightTime-Approximately 23 minutes OperatingTemperature--10°Cto 40°C Max Charging Power-100 W

## YuneecSOO+ FlightTime Weightwith Batteryand Payload Weightwithout Battery and Payload Battery Charger
Transmitter
3 FlightModes
Maximum Flying Height
Maximum Rotation Rate
Maximum Roll Angle OperatingTemperature Range Radio Control Frequency Band up to25 minutes

60.0 oz (1700g}

40.0 oz (1130g)
5400mAh 35 11.1V LiPo (included)
3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)
10-channel 2.4GHz with 5.8GHz video downlink (included)

i smart (FollowMe and Watch Me), Angle and Home

Default 122m (400ft) above Ground Level (Adjustable via the Typhoon 

### GUI)

### Max. Descent Speed 2m/s
Max. Flight Speed 8m/s

Battery Charger
Transmitter
3 Flight Modes
Maximum Flying Height
Maximum Rotation Rate
Maximum Roll Angle Operating Temperature Range
Radio Control Frequency Band 5400mAh 3S 

### ll.lV LiPo (included}

3$ 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included}
10-channel 2.4GHz with 5.8GHz video downlink (included)
Smart (Follow Me and Watch Me), Angle and Home

Default 122m (400ft) above Ground Level (Adjustable via the Typhoon GUI)

35°



# -soc to

# sooc

2.4GHzMax. Descent Speed
Max. Flight Speed

Gimbal Camera 2m/s

8m/s

Type l CG03 Weight 6.9oz (195g) Focusing System Aerial Optimized Fixed Focus
Field ofView FCC Compliance: Up to 600m (1968.5 

### ft) Video Transmission Range CE Compliance: Up to 300m (984.252 ft)

Video Resolution

Photo Resolution Storage (memory)
Control Angle Accuracy with

# sno
UHD: 4K at 30FPS, 2.7K at 30FPS, 2.SK at 30FPS - FULL HD: 1080p at 24/25/30/48/50/60/120FPS
12 Megapixels
microSD Class 10"'4 to 128 GB


# ±o.orWhite Balance
Transmission Band Input/Operating Voltage Working Temperature Storage Temperature AngularVibration Range
Control Range Microphone
Camera Lens
Sensor

Type Automatic or manual settings
5.2GHz-5.8GHz

12V

Pitch: between -90° and

# oo Yaw: between 

# oo and 360° 

## Yes
0.6in (14mm)/f2.8 (1.4in/35mm).....,No distortion
1/2.3" CMOS



### STlO+Operating System
NumberofChannels
ControlTransmission Range (Optimum Conditions)
Robust Radio Control Modulation
Video Link Frequency Band
VideoTransmission Range (Optimum Conditions) Flight SystemsTelemetry Data On Screen Display
LED Backlit LCD Screen
Tactile (Vibrating) and Audible Feedback
Built-in liPo Battery Voltage

## I Capacity
Screen Resolution
Camera Settings ' Android'M
10 FCC Compliance: Up to 800m (2624.67 

### ft) CE Compliance: Up to 400m (1312.34 

### ft) Warning: You Must Follow Local Laws and Maintain Visual Line ofSight ofAircraft atAll Times
Yuneec Protocol

FCCCompliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual Line ofSight ofAircraft atAll Times
Yes Capacitive Multi-touch 5.5"
Yes

3.6V/S200mAh 18.72Wh

854 x480px
White balance, light exposure, ISO, shutter speed, video resolution, FPS, record video, take picturesGiven the small size ofthe UAS in scope and the controlled environment provided, the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including but not limitedto reduced emissions and noise, the grantofthe requested exemption is inthe public interest. Accordingly, the applicant graciously requests thatthe FAA grantthe requested exemption. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will furtherenhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agreesto adhere to when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The UAS will weigh significantly less than 55 lbs. Itweighs less than 4 pounds with battery and camera. 2. The UAS, depending on the model in operation, will have a maximum operating speed of no morethan 50mph. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flight time for each operational flight will be depending on the UAS model in operation, butwill not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or30 minutes offlight time whicheveroccurs first. 5. Flights will be operated at an altitude of no morethan 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crew for each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include athird, but separate, Camera Operator (CO).7. The UAS pilotwill be a designated Pilot in Command (PIC)
.The PIC will have logged a minimum of20 hours on the designated UAS. 8. A safety briefing will be performed priorto each day's flights consisting ofall the days' production activities. 9. All flight activities will be logged. 10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 11. The flights will occur in Class G airspace no closer than a Smile radius ofthe geographic center/ Airport Reference Point (ARP) ofatower controlled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius ofthe geographic center/Airport. 13. The operatorwill file FAA Form 77111, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 14. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department ofTransportation required underthe FOM. With the advanced permission ofthe FSDO, operations atcloser range may be approved. 

### 15. The PIC and VO will have been trained in operation of UAS and receive uptodate information forthe particular UAS to be operated. 16. The PIC and VO will be able to communicate byvoice and/or radio at all times. 17. Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including lawenforcement, fire or otherappropriate governmental agencies as appropriate toflight operations. 18. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS

### will have the capability to return to a predetermined location within adesignated location and land autonomously. 19. The UAS will have the capability to abort aflight in case of emergencies with an automated "Return Home and Land" function. 20. The UAS will have the capabilityto abort aflight in case ofunpredicted obstacles, weather, oremergencies such as low battery. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 

### and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate in the restricted environment and under the conditions proposed will be at least as safe, orsafer, than aconventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide agreaterdegree ofsafetytothe public and property owners than conventional operations conducted with airworthiness

### certificates issued under 14C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking oftheAircraftThe regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words "limited," "restricted/ "lightsport," "experimental,11 

### or "provisional," as applicable 14 C.F.R. 

### § 45.23 (b). Marking ofthe AircraftThe regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental or provisionally certificated aircraft, the operator mustalso display onthat aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words ''limited," "restricted," "light sport," "experimental," or "provisional,11 

### as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance tothe cabin, cockpit or pilot station on which the word 1

### 'Experimental" can be placed. Given the size ofthe UAS, two inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 

### (f). US Department ofTransportation February 20, 2015 The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) wherethe pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. 

### § 61.113 (a) and (b):Private Pilot Privileges and Limitations: Pilot in Command. Pursuantto 14CFR 61.113 (a) 

### & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or propertyfor compensation or hire. The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do notcarry any pilots or passengers nor property. The risks attendanttothe operation of UAS is far less than the risk levels inherent inthe commercial activities outlined in 14CFR 61. The PIC ofthe UAS will be, or be underthe directsupervision of, a FAA Certificated Private Pilotwith currentThird Class or higher medical certificate. It is believed thatthe operation and limitationssetforth inthe FOM will equate tothe safe operation ofthe UAS. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety checklists priorto each flight, an equivalent level ofsafety will be provided. 14 C.F.R. 

### § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft
... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircrafta current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no piloton board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it.

### restricted area with security perimeter, where buildings and people will not be exposed tooperations withouttheir pre obtained consent. The equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owneror local officials. Because of the advance noticeto the property ownerand participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far morethan the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated withthese operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL In addition, the low altitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "
...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant tothe safety check listand live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14C.F.R. 

### § 91.1Sl(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind andforecast weather conditions) there is enough fuel to flyto the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2} At night,tofly afterthatfor at least45 minutes." The applicant believes that an exemption from 14CFR §91.15l(a) falls within the scope of prior exemptions.Operating the UAS in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does notengender thetype of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level ofsafety can 

### be achieved by limiting flights to 30 minutes or 25% of battery power - whichever happens first. This restriction would be morethan adequate to return the UAS to its planned landingzone from anywhere in its limitedoperating area. 14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthefollowing: (1) An appropriate and current airworthiness certificate
.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well underthe proposed SSib limit and is operatedwithout an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them onthe UAS. An equivalent level of safety will be achieved by keeping these documents atthe ground control pointwherethe pilotflyingthe UAS will have immediate access tothem, tothe extentthey are applicable to the UAS. 14C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### & (b): Maintenance Inspections. These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter
.../' and others shall inspect or maintainthe aircraft in compliance with Part 43. Given thatthese sections and Part43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applyto the applicant. Maintenance will be accomplished bytheoperator pursuanttothe flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraftand best suitedto maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided inthe FOM, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight and perform required maintenance needed. Additional Information. The applicant, Kaniela Boyle, believesthis exemption request and associated safetyconsiderations adequately satisfy criteria provided in Section 333 ofthe Reform Act of 2012, providing sufficientjustification forthe granting ofcommercial operations ofthe applicant's UAS. The applicant, Kaniela Boyle respects your respective approval ofthis Section 333 exemption petition request. Thankyou for your attention inthis matter. Please contact Kaniela Boyle ofyour actions, and or approvals. Thank You foryour interest in this request.

# ;~rs~ Kaniela Boyle 942 Delfino Place Lake Mary, Florida 32746