W. DAN PETERS 

October 5, 2015 

2819 144th Street Court East 

Tacoma, Wa 98445 

(cell) 206-310-5808 

(home) (253) 538-6888 

Email: wdanpeters@jcloud.com 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington DC, 20590 

.E.xerpp_tion Request Sectiqn 33.3 of the Reform Act of 2012 - .. . -

., j 

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in 

the matter of the petition of DOUGLAS TRUDEAU 

Dear Sir of Madam, 

2) FAA Exemption No.11136, Regulatory Docket No. FAA-2014-0508 in 

the matter of the petition of ADVANCED AVIATION SOLUTIONS, LLC 

3) FAA Exemption No.11080 Regulatory Docket No. FAA2014-0355 in 

the matter of the petition of FLYING CAM INC 

In accordance with the FAAs Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I, W. DAN PETERS, referred to 

hearafter as the petitioner, requests exemption from the following sections of litle 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 purpose of aerial photography, 

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cinematography, videography, mapping, crop surveying, inspection and other flight operations 

that could be performed safely and more cost effectively with the use of small UAS at low 

altitude within U.S. national airspace system as compared to manned aircraft. Operations will 

be performed only at the request of and with authorization and permission of clients or their 

authorized agents in order to facilitate commerce and raise awareness of the beneficial uses 

of small unmanned air systems. 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. 

The EARs 

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 operating under this exemption 

would be required to comply with any condition as set forth and in a similar fashion to the 

previously granted .exemption~ .. 

91.119(c) As discussed in Exemption 11138 (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, waver or exemption and clarification concerning the terms 

"congested areas" and "densely 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 11136 (ADVANCED AVIATIONS 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-specfic relief has 

been granted in Exemption Nos. 8811, 10808 and 10673 for daytime, VFR conditions. The UAS 

provides battery power remaining in percent to the PIC. The UAS batteries provide 

approximately 25 minutes of powered flight. Information provided in the operating documents 

discusses procedures regarding remaining battery power management. These documents 

contain a condition in which the PIC will initiate a landing procedure when battery remaining 

reaches a specific level. Given the limitations on proposed operations and the location of those 

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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)(1); 91409(a)A(2); 91A17(a)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 operation documents and the conditions and 

limitations specified, describing the requirements for maintenance, inspection, and record 

keeping, were sufficient to ensure that safety would not be adversely affected. 

TbeUAS 

· Yuneec QSOO Typhoon (N820BH pending) is a consumer grade small rotocraft in the 

quadcopter configuration with a advertised weight of 1.3kg designed primarily to carry a 4K high 

definition camera. It has advertised maximum speed of less than 30 knots and a maximum 

climb rate of 600 feet per minute (3 m/s). It is powered by four electric motors with a distance 

between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit 

(IMU) with integrated barometric sensor 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 information is transmitted back to a ground 

control station allowing the operator and/or PIC camera imagery and control camera angle. It · 

has fail safe 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 time to approximately 15 minutes. The onboard flight controller will warn the PIC 

via external light and audio cues before reaching a low battery state. An automatic termination 

of flight and landing will be initiated when battery reaches a predetermined low state. 

DJi Phantom Two Vision (N819BH pending) is a consumer grade small rotocraft in the 

quadcopter configuration with a advertised weight of 1.1 kg designed primarily to carry a high 

definition camera. It has advertised maximum speed of less than 30 knots and a maximum 

climb rate of 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance 

between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit 

(IMU) with integrated barometric sensor 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 information is transmitted back to a ground 

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control station allowing the operator and/or PIC camera imagery and control camera angle. It 

has fail safe 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 time to approximately 15 minutes. The onboard flight controller will warn the PIC 

via external light and audio cues before reaching a low battery state. An automatic termination 

of flight and landing will be initiated when battery reaches a predetermined low state. 

Risk Mitigation 

The petitioner has reviewed FAA exemptions reference's 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 checklist will be 

developed and employed to ensure that the UA airworthiness will be verified 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 conducted in accordance with a NOT AM as 

required by the operator's COA. The letter of agreement with the airport 

management must be 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 a mode C transponder. 

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Public lntrest 

Use of the UAS in lieu of manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to 

facilitate commerce could lead to economic growth. Operations for this petition will enable 

service for 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 lead to increased commerce and enhanced personal photography. Crop 

surveying applications 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 risks. The 

petitioner will provide clients with photographic data for these purposes on a ''for hire" basis 

acting as an independent contractor. A visual observer will be utilized. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. Flight data 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 date regarding 

the uses of UAS as part of this application. This data may be submitted to the FAA via 

traditional means, e.g. COA Monthly Reports, or other means as required. 

Conclusion 

The petitioner is requesting this exemption for the purpose of "aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations". 

The reason for such a general and broad based request is that the petitioner wishes to utilize a 

business strategy of horizontal integration and maximize economies of scope in order to 

capitalize on opportunities as they may arise in the future without long turnaround time 

associated with additional exemptions. This petitioner's business model is based on the idea of 

offering ad hoc small UAS services to individuals or companies who wish to employ these 

services as a safe, effective, and legal option to enhance their business or hobby. The 

petitioner's own market research shows that pent up demand for these services currently exists 

in the real estate market and other markets are just beginning to emerge. 

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A quick internet search will show that many are currently operating similar UAS in exactly 

this fashion without, it is assumed, FAA authorization. The petitioner has refrained from 

engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to 

obtain the capability to offer those services while remaining in compliance, The petitioner has 

25 years of experience in the hobby of radio controlled aircraft. 

Respectfully submitted, 

W. Dan Peters 

?~/06~ --........... .... ~ 

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