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-, LNWAVideoTours_j 2603RosewoodDr.Fayetteville,AR72703 June16,2015 DocketOperations,M-30 U.S.Department

ofTransportation 1200NewJerseyAve,SE RoomW12-140,WestGroundFloor Washington,DC20590-0001 Subject:PetitionforSection333Exemption I,MatthewKrauft,of2603RosewoodDriveinFayetteville,Arkansas72703,hereby petitiontheFAAforanexemptionfromvarioussectionsof49USCofFederalAviation Regulation.

IamassociatedwithNWAVideoToursof2603RosewoodDr.Fayetteville, AR72703,andwillbethePilotinChargeofallaerialphotography,followingapproval
of thisrequest. Pursuant
toSection333oftheFAAModernizationandReformActof2012,PublicLaw 112-95,

Irequestcertainexemptions

inordertoconductcommercialaerialphotography (henceforthmeaningstillphotoand/orvideo)operatingtheDJIS1000andDJIPhantom 2unmannedaircraftsystems. Sincerely, Matthew
C.Krauft 2603RosewoodDr. Fayetteville,AR72703 mckrauft@gmail.comOverview: I, Matthew Krauft, of 2603 Rosewood Dr. in Fayetteville, Arkansas 72703 hereby petition the FAA for an exemption from various sections of 49 USC of Federal Aviation Regulations.

I am associated with NWA Video Tours of 2603 Rosewood Dr. Fayetteville, AR 72703, and will be the Pilot in Charge of all aerial photography, following approval of this request. Pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95,

I request certain exemptions

in order to conduct commercial aerial photography using the DJI S1000 and DJI Phantom

2 unmanned aerial systems. The DJI S1000 consists of eight electric motors with rotors, powered by a Lithium battery and managed by an onboard flight control system (A2) that is remotely accessed by the Pilot in Charge using
a portable control unit. The DJI Phantom

2 consists of 4 electric motors with rotors, powered by a Lithium battery and managed by an onboard flight control system that is also remotely accessed by the Pilot in Charge using
a portable control unit. The DJI S1000 remote control unit is a wireless communication device using the 2.4GHz frequency band. The DJI Phantom

2 remote control unit uses the 5.8GHz frequency band. Both frequencies are approved by the FCC for limited-range communication purposes. The DJI S1000 has a maximum takeoff weight of 11kg or 24.25 pounds. Although not specified

in the user manual

,the DJI S1000 roughly has a top speed of 30-40 knots. For my purposes,

I would not exceed 15 knots. The DJI S1000
is managed by the DJI A2 onboard computer and has the following safety features: Intelligent Orientation Control (IOC), Intelligent Landing Gear Function, Auto Return-to-home, One-Key Go-Home, and One-Motor Fail Protection. The same system can set maximum altitude and distance (from home-point)
so that the UAS does not exceed preferred parameters.

In addition, the control system has a No Fly Zone feature that will prevent takeoff from within Controlled/Restricted Airspace and warn the Pilot in Charge of an impending intrusion when in flight. The manufacturer,
DJI

,regularly updates software and firmware. The DJI Phantom

2 has a maximum payload of less than three pounds including the camera (1350 grams or 2.97 pounds). The maximum forward speed
is 29.16 knots. For my purposes, top speed with not exceed 15 knots. The DJI Phantom

2 is managed by a sophisticated GPS control system that assures

a Return To Home (RTH) procedure

in the event of Loss Of Signal (LOS). The same system can set maximum altitude and distance (from home-point)
so that the UAS does not exceed preferred parameters.

In addition, the control system has a No Fly Zone feature that will prevent takeoff from within Controlled/Restricted Airspace and warn the Pilot in Charge of an impending intrusion when in flight. The manufacturer, DJI, regularly updates software and firmware

. I, Matthew Krauft, will use the UAS in daytime only to enhance real estate marketing for realtors
in the Arkansas counties of Washington and Benton.Pre-flight Checklist (51000 and Phantom 2): • If required, notify the appropriate FAA facility of our launch schedule and location. • Survey the property for hazards

- trees, utility poles and other elements that might compromise the flight, then make
a judgment as to whether to proceed. • Check the weather for wind speed, cloud cover, and any forecast changes that might adversely affect flight safety and performance. • Examine the aircraft

- looking at connections and searching for cracks and/or loose parts. • Determine that the electronic elements are performing correctly (receiving more than 6 GPS signals along with calibration
of the magnetic compass. • Determine that the barometric altimeter reflects approximately

0 feet AGL. • Following takeoff,

I will hover at an altitude of approximately

10 feet AGL to assure the Home Point is marked. • I will exercise all controls to confirm their functionality-

if one of the controls

is not functioning, the flight will be terminated immediately. • I will fly only with a Visual Observer (VO) at my side who will provide

a second set of eyes to assist in observing possible flight hazards and help assure the UAS remains
in Visual Line of Sight (VLOS) of PIC. Since purchase
of the Phantom

2 and S1 000, all training and skill improvement flights have been with the same VO. • I will not fly over or near dense automobile traffic or crowds. • I will give right-of-way

to any manned aircraft. • I will stay clear of FAA controlled airspace
at airports (generally

a five nautical mile radius) as well as restricted and prohibited zones. • I will fly no higher than 400' AGL and no further than
1 000' from the Home Point, recognizing that the primary responsibility

is to keep the aircraft safely within VLOS. • I will stay clear of clouds and fog (500' vertically and 2,000' horizontally). • I will perform

a post-flight check of the UAS to determine
its physical and electronic condition. Operating Procedures: • After receiving permission from the property owner/representative/business
owner,

I will notify all adjacent property owners/business owners of our intentions and anticipated time on site. • I will not fly over neighboring properties unless permission

is granted. • I will keep individuals not involved

in the flight at a safe distance (500' feet if practical). • I will post a sign stating: "Take Notice: Aerial Photography Under Way- Stay Clear". Altitude, distance from the PIC, airspeed, and battery state-of-charge
are data constantly viewable on the On-Screen-Display (OSD), which
is equivalent
to an aircraft's control panel.

I maintain that the above checklist and procedures will minimize risks to property and persons on the ground as well as other aircraft
in the National Airspace.As this writing,

I have practiced extensively

in the DJI Phantom

2 and DJI S1000, accumulating 12:35 hours of flight time operating the DJI Phantom

2 and 9:56 hours operating the DJI S1000.

I continue
to train on both systems. I have a private pilot license, Airplane Single Engine Land; Instrument Rating, #430479294, issued on November

2, 2003.

I am fully aware and have extensive knowledge
of VFR flight rules. The serial number of my Phantom

2 is: PH646C48171. The serial number on the S1000 is: 0200023057.

I will mark the aircraft with whatever 'N' number the FAA requires. Exemption Requests: 14CFR Part 21 Airworthiness Certification Subpart

H "prescribes the procedural requirements
for issuing and changing design approval, production approval, airworthiness certificates and airworthiness approval." (Summation from Exemption No. 11138, page 11) Response: "The Secretary
of Transportation has determined that this aircraft meets the conditions
of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, and any associated noise certification and testing requirements

of part 36, is not necessary." (Summation from Exemption No. 11138, page 11) Part 61 (a)(b) Parts, General Operating and Flight Rules (a) Prescribes the requirements
for issuing pilot licenses and the privileges and limitations associated with various ratings. (b) Aeronautical experience means pilot time, flight simulator
or flight training device for meeting the appropriate training and flight time requirements
for an airman certificate. Response: Organized
or commercially available FAA-approved flight training has yet to be achieved by the UAV industry. While

I have regularly used a flight simulator on my computer, those skills are generally not transferable

to quadcopter/octocopter operation. My sources of training are: the Flight Instruction Manuals from DJI; online videos from the manufacturer

as well as videos from users; and most importantly, personal training in a secure location

-an open area not subject to traffic and/or uninvolved individuals. Those training flights, which have averaged 10-15 minutes each, deal with setup, physical and electronic safety checks; lift off followed by hovering
at approximately

10 feet to confirm that the GPS system

is functioning properly and has registered
its Home Point;
a prescribed flight plan to familiarize and then master the fight controls and camera; returning
to the launch point and landing, either on a plastic pad for the S1000 or having my VO secure the Phantom/S1000

by hand.

I then conduct

a post-flight inspection for any problems, log the location and flight time and then view the video.There arenoFAA certified instructors
orFAA certified study guides available
atthis time asthe technology continues
to develop.

I respectfully requestan exemption from this rule. §91.103 (b)(2) (b)(2) This section deals the pilot's preparations for flight, in particular runway lengths, takeoff and landing distance information. Response: Since
a quadcopter/octocopter,

like a helicopter, takes off and lands vertically,

aPhantom/S1000 pilot would notneed toknow this information since there areno runwaysinvolved and the returnfrom flight is the takeoff point. The FAA has determined that "relief is not necessary." (Summation from Exemption No. 11138, page 20) §91.105 Summary: This section deals with flight crewmembers
atstations. Response: Since there areno passengers, pilots orcrew members,

I respectfully requestrelief from this regulation. §91.109 Summary: This sections deals with flight instruction, simulated instrument flight and certain flight tests. Response: None of these functions are applicable
toa quad-copter flight and, asstated earlier, there arenoFAA certified instructors
orFAA certified study guides available
at this time for quad-copter operation.

I respectfully requestan exemption from this rule. § 91.119 (a) (b) (c) Summary: This section deals with minimum safe altitude stating that if the powerfails anywhere,
anaircraft should have analtitude sufficient sothat an emergency landing canoccurwithout hazard to personsor property (91.119 a). It also setsminimum altitudes over congested areasand uncongested areasaswell ashas a paragraph
on helicopters (91.119 b). It also setsminimum distance (500 feet) from any person, vessel, vehicle, orstructure (91.119 c). Response: None of the altitude requirements

in this regulation should apply toaUAS since these aircraft are required to fly below those altitudes. Their weight, speed and GPS-controlled Return toHome feature mitigates against

a catastrophic accident.

A manned aircraft
is much heavier and larger than aPhantom/S1000.

If aPhantom/S1000 wereto crash,

it carries nohumans, no explosive fuel and since

it flies primarily overa single piece of private property, any damage would likely be minimal and confined
to that area.As to keeping 500' from any person, vessel, vehicle orstructure,the purpose of real estate quadcopter/octocopter photography

is to fly close tothe subject structures with the permission
of the owner/representative.

I maintain that my nearly 23 hours flying the Phantom 2/S1 000 have provided mewith sufficient skills to manage safely any approach under 500 feet.In addition, accesstothe property

is strictly controlled (Warning sign and the clearing of any persononthe propertynotinvolved

in the flight).

I respectfully requestan exemption from this rule. § 91.121 Summary: This section details altimeter settings required tomaintain the "cruising altitude or flight level of that aircraft."

It requires that the "elevation
of the departure airport" be setin the altimeter orthe "current reported altimeter setting of astation along the routeand within 100 miles of the aircraft". Response: An UAV cannot comply fully with this section's altitude requirements. The Phantom/51 000 is equipped with abarometric altimeter which automatically calculates the takeoff altitude
(0 AGL) when the aircraft

is warmed up-the launch point becomes the "elevation
of the departure" point. The altitude of the UAV is visible
in the control monitor
(a smart phone or 050) by the PIC before launch and is consistently updated asthe flight progresses.

I respectfully requestan exemption from this rule. § 91.151 Summary: This section deals with fuel requirements
for VFR flights stating, among other things, that "no person may begin
a flight in an airplane under VFR condition unless
...there is enough fuel to fly tothe first point of the intended landing and,

" ...fly after that for atleast 40 minutes (day) and 45 minutes (night)". Response: This regulation deals with 'reserve' fuel. This could include anycondition that increases flight time orfuel consumption. Weather would be onefactor including wind, turbulence and the necessity
todivert around threatening thunderstorms. Compliance with this regulation

is not possible because the 'fuel" onboard the Phantom/ 51000
is notaviation gasbut aDC battery with amaximum flight duration of 25/15 minutes respectfully. Fuel management

of anUAV requires constant monitoring
of the battery's state-of-charge and bringing

it home before

it reaches the manufacturers recommended 30% level. In our training flights, we've found that a flight of 10-15 (Phantom) and 8-12 (51000) minutes tobe safe, returning the UAVto its Home Point around the 40% level.

I respectfully requestan exemption from this rule. § 91.405 Summary: This section deals with aircraft maintenance including regular inspection, the keeping of appropriate maintenance records and replacement

of inoperable instruments Response: Maintenance
onthe Phantom/51000

is quite straight forward.

If, in landing, arotorblade ortwoare damaged, they are quickly replaced. The traditional instrument cluster
in anaircraft
is replaced by adata streamfrom the Phantom/51 000, visible
in the control monitor (smart phone or 050). Replacement

of minor partsare performed by the PIC and a major 'overhaul' that can't be easily resolved will goback tothe manufacturer
for repair. Currently, there areno required inspections
by 'authorized' maintenance personnel and there would be no space/room
onboard toinstall
a placard of inoperability

.I respectfully requestan exemption from this rule.§ 91.407 Summary/Response:
This section addresses requirements after maintenance has been performed. Again, approval of the maintenance before flight is essentially

in the hands of the PIC. Whatever maintenance

is performed will be entered
in the aircraft log, unless

a separate maintenance
log is required. Paragraph (b) refers tothe prohibition
of a pilot carrying passengers

orcrew members,

if the flight characteristics have been substantially affected, before

arated pilot performs an operational check of the maintenance. Again, this is aPIC's responsibility

to preflight the Phantom/S1000 and determine
its flyability. And, asmentioned earlier, there is no pilot, crewmembers or passengers
onboard the Phantom/51 000.

I respectfully requestan exemption from this rule. § 91.409 Inspections: This section deals with the necessity
of annual and 1 00-hour inspections or "progressive inspections" and approval by authorized personswhich will lead tothe "issuance
of anairworthiness certificate." Response: As stated earlier, there is noFAA approved inspection protocols nor authorized inspection personnel. The PIC handles those issues each time the Phantom/ S1 000 is prepared for flight. The pre-flight check list enumerated earlier will be followed todetermine
its mechanical and electronic integrity.

I respectfully requestan exemption from this rule. § 91.417 Maintenance Records: This section requires

amaintenance record be kept on repair, replacement and condition of vital parts (rotors, engines
& airframe). Certain records mustbe retained for one yearwhile other record mustbe kept with the aircraft even when sold toanother part. Response: The details of this section would be impractical with aPhantom 2/51000, but repair issues canbe entered into the aircraft log.

I respectfully requestan exemption from this rule. The above requestsfor exemptions follow the guidance published by the FAA. Safety: The Phantom 2/S1 000 areUAS with multiple safety features toassure

asafe and efficient flight, minimizing personal injury and property damage and integrating with minimal risk into the NAS. They include: •A GPS flight systemthat allows for stable remotecontrol of the aircraft. •The ability tohover in place by simply taking hands off the controls.•A Return toHome function

if reception between the Remote Control and the aircraft
is lost. If the aircraft begins toshow unstable flight,

I will land it immediately. •The ability tolimit height (<400') and distance (<1 000') from the PIC through the control software. •Use of the 'radar' mode which instantly allows the PIC to pinpoint the UAV. •The No Fly Zone control software will prevent takeoffs within
aS-mile radius of a major airport aswell as provide warning
in the eventthat the aircraft inadvertently approaches the zonewhile in flight. This warning will provide sufficient time for the PIC toreversecourse. •Readout of the battery's stateof charge sothat there is sufficient powerto bring the UAV home. •The weight, size, speed and limited flight which focuses oninanimate objects (homes) reduces the likelihood
of significant personal or property damage. Flight of the UAV risks noonboard lives, asin helicopter
or plane photography. The safety features associated with the Phantom/51 000 aswell as my pre-flight checklist and procedures will assurethat public safety
is not adversely affected. Airports and Prohibited Areas: Since

I intend toconduct flights above properties

in northwest Arkansas, there are several airports that require precautions.

I amfamiliar with these airports.

I will follow all FAA regulations. •Northwest Arkansas Regionai(KXNA)- FAA Control Tower (127.1) •Bentonville Municipal (KVBT)- CTAF/UNICOM (122.8) • Rogers Municipal (KROG)- Rogers Tower/CTAF (119.375) • Springdale Municipal (KASG)- Springdale Tower/CTAF (118.2) •Drake Field (KFYV)- Drake Tower (121.8) •Smith Field (KSLG)- CTAF/UNICOM (122.8) Community Benefit: First and foremost

is the level of safety offered by the useof asmall UAS in comparison toamanned fixed wing orrotorcraft. Weighing less than 25 pounds with camera,the UAV described

in this application are incapable
of causing the level of damage or injury caused by afull-size, manned aircraft. Additionally, the ecologic and noise impact
is negligible as compared
totraditional manned aircraft. Lastly, asreal estate
is a large partof our community economy,the useof asmall UAV aerial filming platform

is acosteffective and visually impactful meansto promote available properties, therefore becoming aneconomic driver in the community.I respectfully request exemptions from the above listed regulations

in order toconduct aerial photography

of residential and commercial properties

in order toassist realtors, home owners, developers, business owners
in their marketing efforts. Matthew Chester Krauft Attachments: 1.DJl Phantom

2 User Manual 2. DJl S1 000 User Manual 3. Private Pilot License #4304 79294 and Arkansas Driver's License 4.Area of operation VFR Sectional Map (Washington and Benton County Arkansas onKansas City Sectional) 5. DJl Phantom

2 Battery Safety Guidelines