David C. Richardson

3848 West 226 th Street Apt. #120

Torrance CA. 90505 Home: (760) 400-9853 Cell: (310) 251-0155 Dave@rv-7.com

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, I David C. Richardson an employee of the California Department of Transportation , hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of a Small Unmanned Aircraft System (sUAS) on behalf of the Department in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit David C. Richardson to operate a sUAS for various California State Agencies and Departments using a small advanced sUAV in the following areas: Inspection, Land Management/Surveying, Special Events, Mapping, Emergency Response, Environmental Assessment, Bridge Inspection, Structure and Antenna inspection, Aerial Videography, Still Photography and Slope Stabilization inspection and assessment.

I, David C. Richardson have demonstrated the ability to sa fely and effectively fly the sUAS DJI Phantom 2 Vision + which will be used for all proposed use activities. As part of this exemption I, David C. Richardson will comply with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in compliance with an y state or local laws regarding privacy.

I, David C. Richardson, am seeking the exemption because I am committed to complying with all of the rules, guidelines, limitations, and future legislation set forth by th e FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have descri bed. Without the exemption request granted, I would be unable to safely and effectively provide these services fo r the benefit and safety of the citizens of the State of California without excessive and undue costs and potential risk to persons and property that would be borne by the taxpayers of the State of California. It is my intention to comply with all FAA regulations and procedures and obtain an exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of responsibilities I assume as operator; it also contains info rmation regarding the aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which ex emption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.10914 C.F.R. 91.119
14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b)

14 C.F.R. 91.215
14 C.F.R. 91.401 - 91.417

I, the Operator, Assume the Following Responsibilities

1. Operations authorized by this grant of exemption ar e limited to the DJI Phantom 2 Vision + when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purp ose of closed-set motion picture and te levision filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine comp liance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds great er than the maximum UA operating ai rspeed recommended by the aircraft
manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated w ithin visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued
airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). Th e UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be us ed to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exempti on, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS ope rations and made available to the Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limita tions herein take precedence and must be followed. Otherwise, the operator must follow th e procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s re sponsibility to track such revisions and present updated and revised documents to the Administrator or any law enforc ement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical co mponent, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights ma y only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test fli ght must be conducted in such a manner so as to not pose an undue hazard to persons and property.9. The operator is responsible for maintaining and inspec ting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre-fli ght inspection and determine the UAS is in a condition for safe flight. The pre-flight in spection must account for all potential discrepa ncies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessa ry maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s main tenance, overhaul, replacemen t, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commerci al, private, recreational, or sport pilot certificate. The PI C must also hold a current FAA airman me dical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.5 6 in an aircraft in which the PIC is rated on his or her pilot certificate. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be op erated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from n onparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not
authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denot ed with an ARP, the center of the airport symbol as denoted on the current FAA-publishe d aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon
request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications with the PIC, the UA must return to a pre-determined location within the private or controlled-access property. 19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five
minutes or with the reserv e power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Ce rtificate of Waiver or Authorization (COA). All operations shall be
conducted in accordance with an ATO- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 6 22. All aircraft operated in accordan ce with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These docu ments must be made available to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and
structures unless: a. Barriers or struct ures are present that sufficiently prot ect nonparticipating persons from the UA
and/or debris in the event of an accide nt. The operator must ensure that nonpa rticipating persons remain under such protection. If a situation aris es where nonparticipating persons leave such protection and are with in 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. Th e PIC, VO, operator trainees or e ssential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled-access property with pe rmission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight oper ation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relie f previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Conducting aerial acquisitions with the DJI Phantom 2 Vi sion+ UAS, instead of traditional manned aircraft, will benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ UAS produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, four to six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 15-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+ UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather th an an internal combustion engine. By using the DJI Phantom 2 Vision+ UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Asid e from the lack of flight crew members lo cated onboard the aircraft, the DJI Phantom 2 Vision + UAS (weighing approximately 2.9 pounds at maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical po tential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 1600 -3500 pounds with a wingspan of approximately 36 feet, a length of 26 feet, and a fuel capacity of 50 gallons).I David C. Richardson am petitioning for an exemption to operate a DJI Phantom 2 Vision + with a built-in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace in cluding a no-fly zone feature. The DJI Phantom 2 Vision+ also has a failsafe function that is triggered in the event communication is lo st between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeof f and land safety. If the connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Airc raft Operating Standards as set below:

 The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from pop ulated areas within the sterile area descri bed in the Flight Operations Procedures Manual. Such operations will ensure that the sUAS will "not create a hazard to users of the national airspace system or the public."

 When flying the sUAS within three (3) miles of an airp ort, airport operators will be notified and the operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. Maximum flight time for each operation
will be 30 minutes.

 Flights will be terminated when battery levels reach 20%, allowi ng sufficient reserve flight time to safely land the

sUAS.

 The sUAS will be programmed so it w ill not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platfo rm from which videography is planned.

 Minimum crew for each operation shall consist of: sUAS pilot and a visual sUAS observer.

 The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current
FAA medical certificate.

 The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 k nots, can hover, and can simultaneously move vertically and horizontally.

 Given the small size of the sUAS, the proposed uses and the restricted environment within which it will operate, the operations on behalf of California Department of Transportation will adhere to the Reform Act's safety requirements.



### Thank you

David C. Richardson