Submitted by: Robert Augustine 106 Valleyview Drive Bardstown, KY40004 502-507-0128 robertcraighaugustine@gmail.com Ms. Robeson: This is in response to a letter you sent me dated June 24, 2015 (copy enclosed). Please consider this an addendum to my previous petition. Feel free to contact me with any questions.

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# ... .Robert Augustine, Public Docket: FAA-2015-2126 Petition: I request an exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b) The Extent Of Relief Being Sought: 1. Extent of Reliefthat I'm seeking regarding Section 61 .113 (a) and (b) Private Pilot Privileges and Limitations Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command holding a current Private Pilots Certificate to operate the DJI Phantom Vision 2+. The pilot will maintain Visual Line ofSight with the UAV at all times. All operations conducted will be incidental to my business. This UAVis not able to carry passengers. 2. Extent of Relief I seek in regards to Section 91.7(a) Civil Aircraft Airworthiness Relieffrom Section 91.7(a) is requested to allow Robert Augustine to determine airworthiness ofthe Phantom Vision 2+.. As part ofthis determination the following will be adhered to: a. Prior to the UAVs flight the PIC will inspect the UAVto ensure it is in a condition that will be conducive for a safe flight. The ground control station will be included in the above inspection. b
. Iwill follow the DJI Phantom Vis ion 2+'s aircraft/component, maintenance, overhaul , replacement, inspection and life limit requirements. c. I will complywith all DJI manufacturer's Safety Bulletins. 3. Extent of Reliefthat Robert Augustine seeks in regards to Section 91.119 Minimum Safe Altitudes General relief from 91.119 is requested to allow me to operate the UAV at altitudes not to exceed 400' AGL over private property (with permission) or public property (when legal and permissible) at a distance at or greater than SNM from the nearest airport as depicted on current Aeronautical Charts. Robert Augustine also wishes to be granted exemption to operate at an altitude not greater than 50' AGL (below tree level) between 1NM and SNM from the nearest airport as depicted on current Aeronautical Charts. (a) 1 will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. (b) I am and will remain familiar with and able to manually institute the UAVs Return to Home (RTH) feature. This feature aborts a flight operation and automatically returns the UAS to a predetermined GPS safe point. (c)l will not operate over private property without first finding a suitable alternate landing spot on the property. (d) Iwill abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.'- 

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## ...4. Extent of Reliefthat I seek in regards to Section 91.121 .AJtimeter Settings Relieffrom 91.121 is requested because the Phantom Vision 2+ utilizes electronic GPS with a barometric sensor. In order to maintain an equal level ofsafety that 91.121 requires, the PIC of Robert Augustine's UAVwill abort the flight in the events that the UAVIoses communications with the GPS signal. 5. Extent of Reliefthat Robert Augustine see!<s in regards to Section 91.151 (b) Fuel Requirements for Flight in VFR Conditions Relief from 91.151 (b) is requested to the extent that allows me to operate the Phantom up to a point (considering wind and forecast weather conditions) that there is enough power to fly at normal cruising speed to the intended landing point and land the UAwith 25% battery power remaining. 6. Extent of Relief that I seek in regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) These are all associated a with Airworthiness certificate Relieffrom 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is requested to the extent that allows me to operate the Quad-Copter as necessary. These sections are all related to airworthiness certificates of aircraft. There is not currently an airworthiness certificate for small UAS's. Iwould comply in full to any conditions and limitations that the Administrator would place in order to receive an approved Grant of Exemption. Public Interest: Aerial videography for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, it's expense has been cost-prohibitive. Granting this exemption to me would allow me to provide this service at a much lower cost. 

### My UAV will pose no threat to the public given its small size and lack of combustible fuel when compared to manned aircraft. The operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in the Central KY area. Furthermore, the cost prohibitive nature of hiring traditional aircraft for be prohibitive for small budget film makers and local busineeses and Chamber's ofCommerce. Using "b-roil" shots from an aerial advantage will promote my community, its landmarks, attractions, and talent. Conclusion: As set forth herein, Robert Augustine seeks an exemption pursuant to 14 C.F.R. §11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 2 Vision+ Quadcopter commercially. The Administrator will be assisting small business by granting this petition. In accordance with the FAA. Modernization and Reform Act of2012, I respectfully request that the FAAAdministrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2) ; 91.417 (a) and (b) Robert Augustine, Public Docket: FAA-2015-2126•,U.S
.Deportment orTransportation FederalAviation Administration



### June 24,2015 Mr. Robert Augustine 1

06 Valleyview Bardstown, KY 40004 Dear 

### Mr. Augustine: 800 Independence Ave
.. S
.W
. Washington. DC
. 20591



### This letter is to inform you that we are unable to process yourrequest for an exemption from Title 14, Code ofFederal Regulations (14 CFR). It explains why we cannot process your request and what you should do in the next 30 days. 

### Why We Can 

### Not Process YourRequest We entered your June 5, exemptionrequest into the public docket (No. FAA-2015-2126), but we are unable to process your request any further. The information you sent does not comply with the requirements of§ 11.81 (copy enclosed). For us to consider the request any further, you must send us all ofthe following:
• The specific section or sections of 14 CFRfrom which you seek relief, the extent ofthe reliefyou seek, and the reason you seek relief. • The reasons why granting the request would be in the public interest; that is, how it would benefit the public as a whoie.
• Any additional information, views, or arguments available to support your request. 

### WhatYou Should Do Ifyou want us to process your request any further, you must send the information described earlierto reach us within 30 days. Please note that§ 11.63(d)requires you to send your petition for exemption at least 120 days before the proposed effective date ofthe exemption.

### If

### We 

### Do Not Hear From You Ifwe do not hear from you within 30days, we will close the docket without notifying you further. Ifyou have any questions orrequire additional time, you may call (202) 267-9677.

Brenda Robeson Program Analyst, Airmen and

Airspace Rules Division Enclosure 2

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### ELECTRONIC CODE OFFEDERALREGULATIONS e-CFR Data is current as of March 2, 2015 Title 14 --+- Chapter I --+- Subchapter B --+- Part 11 --+- Subpart A__. 

### §11.81 Title 14: Aeronautics and Space PART 11-GENERAL RULEMAKING PROCEDURES Subpart A- Rulemaking Procedures §11.81 What information must ! include in my petition for an exemption? You must include the following information in your petition for an exemption and submit it to FAA as soon as you know you need an exemption. (a) Your name and mailing address and, ifyou wish, other contact information such as a fax number, telephone number, or e-mail address;

# (b)The specific section or sections of 14 CFR from whichyou seek an exemption;

, (c) The extent of relief you seek, and the reason you seek the relief; "' (d) The reasons why granting your request would be in the public

**in~erest;** that is, how itwould benefit the public as

**~** whole; '(I. (e) Th e reasons why g ranting the exemption would not adversely affect safety, or howthe

exemption would provide a level of safety at least squai to that provided bythe rule from which you seek the exemption; (f) A summary we can publish in the FEDERAL REG ISTER, stating: (1) The rule from which you seek the exemption; and (2)A briefdescription of the nature ofthe exemption you seek; (g)Any additional inf ormation
. views orarguments available to support your request; and (h) Ifyou want to exercise the

**privile~es** Gf your exemption outside the United States, the reason why

**y~~** need to do so.


### ..... .. Forquestions or comments regarding e-CFR editorial content, !eatures,ordesign, email ecfr@nara.gov
. Forquestions concerning e-CFR programrring and delivery

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**,** email W'3bteam@gpo.gov.



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