Submitted by: 

Robert Augustine 

106 Valleyview Drive 

Bardstown, KY 40004 

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 Relief that 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 of Sight with the UAV at all times. All operations conducted will be incidental 

to my business. This UAV is not able to carry passengers. 

2. Extent of Relief I seek in regards to Section 91.7(a) Civil Aircraft Airworthiness Relief from 

Section 91. 7(a) is requested to allow Robert Augustine to determine airworthiness of the 

Phantom Vision 2+ .. As part of this determination the following will be adhered to: 

a. Prior to the UAVs flight the PIC will inspect the UAV to 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. I will follow the DJI Phantom Vision 2+'s aircraft/component, maintenance, overhaul, 

replacement, inspection and life limit requirements. 

c. I will comply with all DJI manufacturer's Safety Bulletins. 

3. Extent of Relief that 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 1 NM 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 of 25 hours of total 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) I will abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents. 
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4. Extent of Relief that I seek in regards to Section 91.121 .AJtimeter Settings Relief from 91.121 

is requested because the Phantom Vision 2+ utilizes electronic GPS with a barometric sensor. 

In order to maintain an equal level of safety 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 Relief that 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 UA with 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 Relief from 

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. I would 

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 of Commerce. 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 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the 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 of 2012, I respectfully request that the FAA Administrator 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 

or Transportation 

Federal Aviation 

Administration 

June 24,2015 

Mr. Robert Augustine 

1 06 Valleyview 

Bardstown, K Y 40004 

Dear Mr. Augustine: 

800 Independence Ave .. S.W. 

Washington. DC. 20591 

This letter is to inform you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days. 

Why We Can Not Process Your Request 

We entered your June 5, exemption request 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 of the following: 

• The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you 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. 

What You Should Do 

If you want us to process your request any further, you must send the information described 

earlier to 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 of the exemption. 

If We Do Not Hear From You 

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677. 

Brenda Robeson 

Program Analyst, Airmen and 

Airspace Rules Division 

Enclosure 

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Page 1 of 1 

ELECTRONIC CODE OF FEDERAL REGULATIONS 

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, if you 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 which you 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 it would 

benefit the public as ~ whole; 

'(I. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least squai to that provided by the rule from which you 

seek the exemption; 

(f) A summary we can publish in the FEDERAL REGISTER, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

(g) Any additional information. views or arguments available to support your request; and 

(h) If you want to exercise the privile~es Gf your exemption outside the United States, the reason 

why y~~ need to do so . 

..... .. 

For questions or comments regarding e-CFR editorial content, !eatures, or design, email ecfr@nara.gov. 

For questions concerning e-CFR programrring and delivery ~ssues, email W'3bteam@gpo.gov. 

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