360	Media,	INC 5161	E.	Arapahoe	Rd.	#405 Centennial,	CO	80122

U.	S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.	,	SE	Washington,	DC	20590

Federal	Aviation	Administration	Exemption Petition	for	Exemption	under	Section	333

FAA	Modernization	and	Reform	Act	of	2012

Public	112

- 95	Feb.	14,	2012,	Section	333 Submitted	by:	Light	and	Glass	Studio,	LLC.	(Roy	Adkins)

References: 1)	FAA	Exemption	No.	11138,	Regulatory	Docket	No.	FAA20140481	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	AVIATION	SOLUTIONS	LLC

Date:	3/10/2 016

Dear	Sir	or	Madam,

In	accordance	with	the	FAA's	Guidelines	for	Submitting	Petition	for	Exemption

under	Section	333	of	the	FAA	Modernization	and	Reform	act	of	2012

, 360	Media,

INC	and Anthony	Franklin	Diehl referred	to	hereafter	as	the	petitioner,	r equest exemption	to	the	following	sections	of	Title	14,	Code	of	Federal	Regulations:

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	small	unmanned	aircraft	systems (UAS)	commercially	in airspace	regulated	by	the Federal	Aviation	Administra tion	(FAA)	for	the	purposes	of aerial	p hotography,	cinematography,	videography,	inspections	and	other	flight operations	that	could	be	performed	safely	and	more	cost	effectively	with the	use	of small	UAS	at	low	altitude	within	the	US	National	Airspace	System	as	compared	to manned	aircraft.	Operations	will	only	be	performed	at	the	request	of	and	with	the authorization	and	consent	of	clients	and	their	authorized	agents	in	order	to	f acil itate

commerce	and	raise awareness	of	beneficial	uses	of	small	UAS.	So	long	as	such operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	as	maybe	established	by	the	FAA	as	required	by	section	333.The	conditions	identified	and

propos ed	by	the	petitioner	are	drawn	from	references	1

- 3.

Operators	Name	and	Address

Anthony	Frank	Diehl 783	Ridgemont	Cir HIghlands	Ranch,	CO 80126

The	FARs The	petitioner	seeks	the	exemption	from	the above mentioned	FARs	for	the following	reasons:

61.1 13(a)	&	(b): The	petitioner	requests	relief	in	order	to	facilitate	the	utilization of	an	FAA	licensed	Commercial	Pilot	( Anthony	Franklin	Diehl ,	Cert	# 2806237 )	with the	addition	of	a	visual	observer.	All	pre

- flight	inspection,	maintenance	and	flight logs will	be	saved	and	made	available	to	the	FAA	and	Secretary	of	Transportation (SoT)	for	review;	with	the	purpose	of	safely	integrating	civil	UAS	operation	in	the National	Airspace	System.

91.119(c) : As	discussed	in	Exemption	11139	(Douglas	Trudeau),	opera tions conducted	closer	than	500	feet	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	of	"congested	areas"	and	"densely populated."	The	petitioner	requests	waiver	for	this	condition	to	allow	reasonable and	responsible	operations	in	areas	of	subdivisions	and	neighborhoods.

91.121 : As	discussed	in	Exemptio n	11138	(DOUGLAS	TRUDEAU),	this	is inapplicable	since	the	UAS	does	not	have	an	altimeter	and	instead	utilizes	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 prescribed	minimums	including	Exemption	NO.s	2689,	5745,	and	10650.	In	addition similar	UAS	specific	relief	has	been	granted	in	Exemption	No.s	8811,	1080,	and 10673	for	daytime,	VFR	operations.	T he	UAS	provides	battery	power	remaining	in percent	to	the	PIC.	The	UA	batteries	provide	approximately 18 minutes	of	powered flight.	Information	provided	in	the	operating	documents	discusses	procedures regarding	remaining	battery	power	management.	The	docum ents	contain	a condition	in	which	the	PIC	will	initiate	a	landing	procedure when	the	battery remaining	reaches	a	specified	level.	Given	the	limitations	on	proposed	operationsand	the	location	of	those	proposed	operations,	the	FAA	found	that	a	reduced

minim um	power	reserve	for	flight	in	daytime	VFR	conditions	was	reasonable.

91.405(a);	91.407(a);	91.409(a)	(1)	&	(2);	91.417(a)	&	(b) : As	discussed	in Exemption	11138	(DOUGLAS	TRUDEAU),	the	petitioner	proposes	to	inspect	and ensure	the	UAS	is	in	a	condition	for	safe	flight	in	accordance	with	the	operating documents.	The	FAA	found	that	adherence	to	the	petitioners	operating

documents	and the	conditions	and	limitations	specified,	describing	the requirements	for	maintenance,	inspection	and	record	keeping,	was	sufficient	to ensure	that	safety	would	not	be	adversely	affected.

Risk	Mitigation The	petitioner	has	reviewed	FAA	exemptions	referenc es	1

- 3	Conditions	and Limitations	section	and	believes	that	the	procedures	specified	therein	are reasonable	and	will	be	utilized	in	order	to	manage	and	mitigate	risk	and	ensure public	safety.	A	preflight	and	post	flight	checklist	has	been	developed	and	emp loyed to	ensure	that	UA	airworthiness	will	be	maintained	for	flight	operations.	Flight	time and	maintenance	logs	have	been	and	will	be	maintained	to	ensure	tracking	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	of	the FAA.	The	UA	may	not	operate	within	five	nautical	miles	of	the	geographic	center	of	a

non	towered	ai rport	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	conducted	in	accordance	with	a	NOT	AM	as	required	by	the	operator's COA.	The	letter	of	agreement	wi th	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	should	the	need	arise.

Public	Interest Use	of	the	UAS	in	lieu	of	a	manned	aircraft	would	enhance	safety	and	reduce environmental	impact	compared	to	similar	operations	conducted	with	much	larger

fuel	laden	manned	aircraft.	Addit ionally,	the	use	of	UAS	in	comparison	to	rotorcraft or	even	fixed	wing aircraft will	save	petitioners	clients	money. Typically	those

clients	cannot	afford	the	cost	of	manned	aircraft	for	aerial videography/photography	so	the	general	aviation	industry	shoul d	not	see	a	decline

in	revenue	due	to	UAS. Operations	for	this	petition	will	enable	service	for	project managers,	public	information	officers		and	property	owners	or	their	designees seeking	an	enhanced	perspective	for	characteristics,	amenities,	and	benefi ts	of	their desired	photographic	subjects	that	cannot	be	displayed	through	ground	level videography/photography.	Aerial	photography	is	a	valuable	marketing	tool	that	can facilitate	increased	commerce	and	enhance	personal	photography.	Crop	surveying

and	ins pections	could	lead	to	decreased	use	of	pesticides	and	fertilizer	andconservation	of	water	as	well	as	increased	crop	yields	and	decreased	costs.	Aerial surveying	and	inspections	can	increase	work	site	efficiency,	improve	volumetric

estimations	and	reduce risk.	The	petitioner	will	provide	clients	with	the photographic	data	for	these	purposes	in	a	for	hire	basis	acting	as	an	independent contractor.	A	visual	observer	will	be	utilized.	Flight	data	including	UA	flight	time, Control	unit	operation	time,	incident

, accident,	and	details	concerning	any	deviations	from	normal	operations	will	be available	to	the	FAA	for	use	in	collecting	data	regarding	the	use	of	UAS	as	a	part	of this	application.	This	data	can	be	submitted	to	the	FAA	via	reports	as	required	by

the	FA A.

UAS	Make	and	Model The	DJI s900 is	a highly	successful	consumer	grade	small	rotorcraft in	the hexa

copter configuration	with	an	advertised take	off weight (with	camera) of	less	than

289 Ounces	( 8.2	k g)	designed primarily	to	carry	a	high	definition camera	aloft.	They have	an	advertised	maximum	speed	of	less	than 30	kts	(15	m/s)	and	a	maximum climb	rate	of	less	than	1200	fpm	(6	m/s).	They	are	powered	by 6 electric

motors	with	a	distance	between	the	motors	of	less	than 14	inches	(350	mm). It

utilizes	a n	internal inertial	measuring	unit	(IMU)	with	integrated	barometric	sensor to	augmented	with	Global	Positioning System	(GPS)	to	maintain	its	geospatial orientation	and	position.	It	is	controlled	primarily	through	an FCC	certified	radio control	(RC)	unit.	R eal	time	video	and	telemetry	information	is	transmitted	back	to	a ground	control	station	allowing	the	operator	and/or	PIC	to	monitor	battery	level, GPS	signal	strength, altitude	(AGL),	distance	from	the	PIC,	camera	imagery,	and control	camera	angle.	It	has failsafe	modes of	operation	for	either	loss	of	RC	or	GPS signal.	Altitude	can	be	limited	by	the	onboard	flight	controller and	maximum altitude	can	be	preprogrammed	by	the	PIC.	Battery	life	limits	flight	times	to approximately 18 minutes.	The	onboard	fligh t	controller	will	warn	the	pilot	via telemetry	data	and external	lighting	cues	before	reaching	a	low	battery	state.	An automatic	termination	of	flight	and landing	will	be	initiated	when	battery	reaches	a predetermined	low	state.	It	is	anticipated	that	flig hts will	usually	last	less	than	1 2

minutes.	More	information	is	available	in	attachment	3	or	at http://www.dji.com/product/spreading

- wings

- s900/spec

Proposed	Operation

Petitioner	is	se eking	exemption	to	accomplish	the	following: Aerial	videography	and	photography	of	transit	construction	including	highway	and railway,	transit	operations	specifically	light	rail,	comm uter	rail	and	heavy	rail, real estate	construction	and	marketing and	crop surveillance .		Operations	would proceed only	with	prior	approval	of property	owner	and	or construction	contractor.

ConclusionThe	petitioner	is	requesting	this	exemption	for	the	purposes	of	"aerial	photography, cinematography, videography,	mapping, inspections	and	other	flight	operations." The	reason	for	such	a	general	and broad	based	request	is	that	the	petitioner	wishes to	utilize	a	strategy	that	allows	maximum	flexibility	to utilize	the	UA	to	its	fullest potential	within	the	constraints	of	this	re quest,	without	the	long	turnaround time	associated	with	additional	exemptions.	The	petitioner	plans	to	offer	services	to

individuals	or companies	seeking	to	enhance	their	business	in	a	safe	and	lawful	way. The	petitioner	is a construction	videographer	and photographer and	knows	that there	is	extensive	demand	for	lawful	aerial	photography	and	videography. The	petitioner	has 20 years fixed

- wing flying	experience	which	includes	over 1400

hours in	general	aviation	aircraft as	pilot	in	command	and	CFI. Petition er	also	has	a

current second class	medical	certificate. The	petitioner	has experience	flying	several UAS,	the	DJI f

- 450,	DJI	s1000	and	the	DJI

s1000 ,	which he has flown	for	over	100	hours	from private property	and	various

other	locations	with	owner	consent to develop	flight	experience. He has	executed hundreds	of	takeoffs	and	landings,	and	has demonstrated	continuous	proficiency

over	the	last 3	years

. He has	experience	w ith	the	fail

- safe	modes	of the	aircraft, having	run himself through	non

- normal	procedure s	as	described	in	the	DJI operating manual. The	petitioner	plans	to	utilize	the	UA	below	400'	AGL,	within	visual	line	of	sight {VLOS),	within	500' laterally	of	the	PIC,	and	with	a	visual	observer	at	all	times.

Respectfully	submitted,

Anthony	Frank	Die hl 360	Media,	INC