Page **1** of **5** A Pulitzer Prize

- Winning Newspaper Owned locally by Sonoma Media Investments, LLC

December 28 , 2015 Chad Surmick Sonoma Media Investments LLC The Press Democrat 427 Mendocino Ave Santa Rosa, Ca. 95401 Cell 707

- 291

- 5486 Email: Chad.Surmick@pressdemocrat.com U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave SE Washington, DC 2059 RE: Exemption Request Section 333 of the FAA Reform Act of 2012
**Attachments:** 1) DJIPhantom 3 Professional User Manual v1.2

- Link HERE (Fi le to o large to upload)
**References:** 1) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

–2014

– 0508 in the matter of the petition of ADVANCED A VI ATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

- 0355 in the matter of the petition of FLYING CAM I NC Dear Sir or Madam, In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, Sonoma Media Investments LLC, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Cod e of Federal Regulations :Page **2** of **5**

61.113(a); 61.113(b); 91.119(c); 91.121; 91. 151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b); In order to operate a small unmanned aircraft s ys tem (UAS) commerciall y in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of news gathering , aerial photograph y, cinematography, videograph y, mapping, agricultural surveying, and inspecti ons which could be performed safel y and more cost effectivel y with the use of small UAS at low altitude within the U.S. national airspace s ys tem as compared to a manned aircraft. Operations will be performed onl y with the authori zation and permission of the public or authorized agents in order to facilitate news gathering , commerce and raise awareness of the beneficial uses of small unmanned air s ys tems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333. The conditions identified and proposed b y the petitioner are drawn from references 1

- 3.

**The FARs** The petitioner seeks exemption from the above mentioned FARs for the following reasons; 61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots oper ating under this exemption would be required to comply with an y conditions as set forth and in a similar fashion to the previously

granted exemptions.
91. 119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 fee t to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densel y populated”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU ) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for day time, VFR conditions. The UAS provides battery

power remaining in percent to the PI C. The UA batteries provide approximately

25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PI C will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposedPage **3** of **5**

operations, the FAA found that a reduced minimum po wer reserve for flight in day time VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and record kee ping, were sufficient to ensure that safet y would not be adversely affected.

**The UAS** The petitioner plans on ut ilizing the DJ I Phantom 3 Pr ofessional. This airframe is a "pro

- sumer" grade small rotorcraft in the quadcopter configuration powe red b y electric motors . Individual Specifications for the airframe are located in the table below. The DJ I Phantom 3 Professional airframe utilize an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global posit ioning sy stem (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the o perator and/or pilot in command ( PI C ) to monitor battery level, GPS signal strength, altitude (AGL), distance from PI C, camera imagery , and control camera angle. Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Alti tude is limited and pre

- programmed to not exceed 400ft AGL. Battery life limits flight times to approximately 20

- 25 minutes . The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually

last less than 10 minutes. More information is available in the product manual which is attac hed as a link

. UAS Airframe Specifications DJIPhantom 3 Weight (Pounds) 2.82 Dimensions (inches) 23.23 (Diagonal) Max Speed (Knots) 30 Temp Range (°C) 0° to 40°Page **4** of **5**

**Risk Mitigation** The petitioner has reviewed FAA exemptions reference’s 1

- 3 Conditions and L imitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safet y. A preflight checklist has been develop ed and employ ed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained b y performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure

- prone components. The petitioner requests that in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided that; “The UA may

not operate in Class B, C, or D airspace without written approval from the FAA. The UA may

not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducte d in accordance with a NOTAM as required b y t he operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.” Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within Class B airspace are not requested due to the lack of Mode C transponder.
**Public Inter est**  Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carr yi ng a crew and flammable fuel. An exemption allowing the use of a DJIPhantom 3 Professional UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. Operations for th is petition will enable news gathering journalists to serve the public good in enhancing accurate dissemination of ne wsworthy and relevant information with timely aerial visual coverage. Aerial photograph y is a valuable information and marketing tool that can lead to increase d commerce. Agricultural surveying applications could lead to decreased use of pesticides and f ertilizer and conservation of water as well as increased crop y ields and decreased costs. Aerial surveying and inspections can increase work site efficiency , improve volumetric estimations and reduce risks.Page **5** of **5**

A visual observer will be utilized . Flight dat a including UA flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data m ay

be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as required.
**Conclusion** The petitioner seeks an exemption, pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and title 14 Code of Federal Regulations part 1 1, which will permit the petitioner to safel y operate a DJ I Phantom 3 Professional UAS in the National Airspace S ys tem for the purposes of “ n ews gathering, aerial photograph y, cinematogr aph y, videograph y, mapping, agricultural sur veying, and inspecti ons .” The petitioner has identified public a gencies that could benefit from the operatio n requested in this application to ai d in search and rescue by

contract or donation. Chad Surmick , of Sonoma Media Investments , is the Director of Photography for the Santa Rosa Press Democrat, a media outlet that consists of a 60,000 circulation daily newspap er, 25,000 circulation magazine and news website. As part of the news media we work closely with publi c agencies and first responders and tak e safety very seriousl y. Adding to the level of safety and experience in these o perations, the petitioner has 12 ye ars of experience in the radio control model aircraft hobby , 15 ye ars of experience in general aviation and holds the following FAA Airmen l icenses , c ertificates and endors ements : Private Pilot Li cense

– Single Engine Land Rating Current Third Class Medical Current Biannual Flight Review
Thank y ou in advance for y our time and consideration.

Sincerel y,

Chad Surmick Director of Photography The Press Democrat Sonoma Media Investments LLC