U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor s12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

William J Bender 

DBA PhotoRodz Mobile Photograpy 

P 0 Box 1184 

Sandpoint, ID 83864 

January 8, 2015 

,.,''' 

Amended Request Original Request Submitted December 6, 2015) 

Section 333 , Petition for Exemption 

Dear Administrator, 

PhotoRodz Mobile Photography respectfully requests an exemption from applicable 

provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of 

unmanned aerial vehicles 

Requested Relief 

A. use of small unmanned aerial vehicle (SUAV) over private and public gatherings 

where designated show venues are held and where specific aerial services have 

been requested I contracted by the vendor/show specific organizers. 

B. use of small unmanned aerial vehicle (SUAV) over public streets, where 

shows/events have been authorized, where no active vehicle traffic is allowed 

and where specific aerial services have been requested I contracted by the 

vendor/show specific organizers 

C. use of small unmanned aerial vehicle (SUAV) over non federal lands or bodies of 

water, at the specific request of property owners or at the request of vendor/show 

specific organizers of the events in question. · 

D. use of small unmanned aerial vehicle (SUAV) over National, State and/or Local 

Parks with full permission of the agencies representing the land/park/waterway 

and with compliance of any imposed restrictions placed on the aerial operation, 

either by the operators of the property or to be in full compliance with any and all 

FAA operational limitations. 

E. If applicable with this request, use of small unmanned Aircraft Vehicle (SUAV) for 

above stated reasons in the Province of British Columbia and Alberta, Canada. 

F. To accept financial compensation for work performed and/or products produced 

and sold as a result of such flight activities. 
Expected Limitation for Such Relief 

A. limited to use of one small unmanned aerial vehicle (SUAV) in the sky during a 

single event 

B. maximum altitude of small unmanned aerial vehicle (SUAV) to 300 feet AGL 

C. limited speed of small unmanned aerial vehicle (SUAV) to less than 15 mph 

D. limted horizontal distance from vehicle operator to be no greater than 1500 feet 

E. Maximum air time per flight limited to 75% of battery capacity, based on fully 

charged battery provided by or within specifications of the manufacturer 

F. Use of FAA approved two way air to ground radio with approved FCC license on 

the premise as needed to assure safe flight operations 

G. Proof of FAA Airmen Certification, to be presented upon request (AC 207 5659) 

H. Proof of Liability Insurance to cover both persons and property, to a maximum 

limit of $1,000.000.00 upon request. 

I. Full compliance of all FAA air space rules and regulations 

Operator: William J Bender (dba PhotoRodz Mobile Photography) 

Airman Certification # 207 5659 

**Small UAS Certificate Registration: FA3KLTAA4Y 

DOB 07.07.1948 

www.photorodz.com 

photorodz@gmail. com 

208.255.9779 

208.255.8074 

Benefit to the Public Interest*** 

A. Educational opportunities to the general public 

B. Offering educational training of safety, use and legal compliance 

C. Interaction with General Aviation Community to better understand and develop a 

proactive working relationship. 

D. Substantial documentation of all flight activities to develop a better understanding 

of reliability, needed pilot training and aircraft maintenance 

E. Open cooperation with FAA and other agencies to fully incorporate a safe flying 

culture and community. 

F. Opportunity to reinforce the safe and positive aspects of UAS flight. 

G. Direct support with Manufacturer to promote continued development of UAV 

Safety Benefits From Request for Waiver*** 

A. Detailed documentation of all flights which can contribute to future development 

of UAV's and serve as necessary supporting documentation for accident 

investigation 

B. Detailed documentation of all maintenance records to monitor and develop 

maintenance guidelines and support further vehicle development and safety 

standards 

C. Development and use of flight checklists to assure proper safety and operation 
D. Open dialogue with UAS manufacturer to identify areas of improvement for the 

operation and safety of vehicles, pilots and the general public. 

Current Experience and Training 

A. Licensed Private Pilot (1300 hours PIC) 

B. Flight Safety Instructor Training with Ultralight Aircraft (1984) 

C. 1700 flight hours in Ultralight Aircraft) 

D. Over 1,000 recorded flights with all small unmanned aerial vehicle (SUAV) type 

equipment 

E. Over 300 recorded flights with current small unmanned aerial vehicle (SUAV) in 

our inventory 

SUAV Inventory as of January 1, 2015 

One Yuneec 0500+ Typhoon small unmanned aerial vehicle (SUAV) 

Two Yuneec Flight Controllers, specified for above vehicle 

Six Yuneec Lithium ION batteries, specific to vehicle 

One Yuneec factory specified CG03 Camera with attached 3 axis gimbal 

One GoPRO Silver4 Camera with attached 3 axis gimbal 

Physical Dimensions and Flight Characteristics of SUAV 

• Height: 240mm (9.45 in) 

• Width: 420mm (16.54 in) 

• Diagonal Length W\0 Rotor Blades: 565mm (22.2 in) 

• Propeller/Main Rotor Diameter: 330mm (13.0 in) 

• Operational Weight: 60 oz I 1700 g 

• Power Supply: 5400mAh 3S 11.1V LiPo 

• Power Supply Safety Margin: All batteries are removed after 75% consumption or 

15 minutes of flight time, which ever comes first, to provide additional safety 

margins) 

• Flight Modes: Smart, Angle and Home Modes 

• Maximum Flying Height: Default 400 Feet 

• Maximum Rotational Velocity: 65°/S 

• Maxiillum Bank Angle: 35° 

• Maximum Climb Rate in Smart and Angle mode: 3m/s 

• Maximum Descent Rate in Smart and Angle mode: 2m/s 

• Radio Control Frequency Band: 2.4GHz 

ST1 0 Personal Ground Station Operating System 

• Number of Channels: 10 

Control Transmission Distance/Range FCC Compliance: 

• Up to 800m (2624.67 ft) 

• CE Compliance: 

• Up to 400m (1312.34 ft) 

• Radio Control Modulation: Yuneec Protocol 
• Video link Frequency Band: 5.8GHz 

• Video Transmission Distance/Range (Optimum Conditions) 

FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.252 ft) 

Should further documentation or additional information be needed by your agency to grant 

this exemption, I will be happy to provide at your request. Thank you for your time and 

attention to this request, I look forward to receiving this exemption at your earliest 

convenience. 

** amendment from original waiver request 

*** amendment from original waiver request 

Sincerely yours, 

w~~~~ 

William J Bender 

Chief Operations Officer 

PhotoRodz Mobile Photograpy 

**** amendment from original request for waiver