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:	3/10/2016

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,	request	

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	Administration	(FAA)	for	the	purposes	of	

aerial	photography,	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	facilitate	

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	may	
be	established	by	the	FAA	as	required	by	section	333.The	conditions	identified	and	

proposed	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:

61.113(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),	operations	

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	Exemption	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.	The	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	documents	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	operations	
and	the	location	of	those	proposed	operations,	the	FAA	found	that	a	reduced	

minimum	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	references	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	employed	

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	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	conducted	in	accordance	with	a	NOT	AM	as	required	by	the	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	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.	Additionally,	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	should	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	benefits	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	inspections	could	lead	to	decreased	use	of	pesticides	and	fertilizer	and	
conservation	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	FAA.

UAS	Make	and	Model

The	DJI	s900 is	a highly	successful	consumer	grade	small	rotorcraft in	the	hexacopter configuration	with	an	advertised	take	off	weight (with	camera) of	less	than	

289 Ounces	(8.2	kg)	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	an	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.	Real	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	flight	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	flights will	usually	last	less	than	12

minutes.	More	information	is	available	in	attachment	3	or	at

http://www.dji.com/product/spreading-wings-s900/spec

Proposed	Operation

Petitioner	is	seeking	exemption	to	accomplish	the	following:

Aerial	videography	and	photography	of	transit	construction	including	highway	and	

railway,	transit	operations	specifically	light	rail,	commuter	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.

Conclusion
The	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	request,	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.	Petitioner	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	with	the	fail-safe	modes	of the	aircraft,	

having	run	himself through	non-normal	procedures	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	Diehl

360	Media,	INC