September 8, 2015 

Robert Michael Karman

5376 Ohio Street, Vermilion OH 44089

Cell 508-868-0881 Email: Rkarman950@gmail.com

 

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave SE Washington, DC 2059 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

 

Manuals Used For Operations:

1) DJI Inspire 1 User Manual v1.4

2) DJI Inspire 1 Maintenance Manual v1.0

3) DJI Inspire 1 Safety Guidelines v1.0

4) DJI Phantom 3 Professional User Manual v1.4

5) Intelligent Flight Battery Safety Guidelines v1.4

6) Yuneec Q500 User Manual V2

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 AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter of the petition 

of FLYING CAM INC 

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, I, Robert Michael Karman, referred to hereafter as 

the petitioner, request exemption from 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, mapping, crop surveying, 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 U.S. national 

airspace system as compared to a manned aircraft. Operations will be performed only at the request of 

and with the 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 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 operating under this exemption would be required 

to comply with any 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 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 “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 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 daytime, VFR conditions. The UAS provides battery

power remaining in percent to the PIC. 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 PIC will 

initiate a landing procedure when 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)(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 keeping, were sufficient to ensure that safety 

would not be adversely affected. 

The UAS 

The petitioner plans on utilizing separate, but similar airframes. The DJI Inspire 1, DJI Phantom 3 

Professional, and Blade Chroma Drone. These airframes are a "pro-sumer" grade small rotorcraft in 

the quadcopter configuration powered by electric motors each. 

DJI Inspire 1 – Weight 6.47lbs. Transmitter Frequency 2.4-2.83Ghz

DJI Phantom 3 Professional – Weight 2.82lbs. Transmitter Frequency 2.4-2.83Ghz

Yuneec Q500 – Weight 3.75lbs. Transmitter Frequency 2.4Ghz

These airframes utilize 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 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 PIC, camera imagery, and control 

camera angle. 

Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is limited 

and pre-programmed to not exceed 400ft AGL. Battery life limits flight times to approximately 20-25 

minutes for each airframe. 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 product manuals which are 

Attachments 1 through 6. 

 

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 to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine inspections before 

each flight, maintaining flight and maintenance logs to record time on failure-prone components.

If inspection reveals a condition that affects the safe operation of the UAS, it will be grounded 

immediately and prohibited from operating until maintenance is performed and the UAS is found to be 

airworthy. The petitioner also is a Company Check Airman for a 121 Air Carrier, holds a Class One 

Medical Certificate, and participate in an active drug testing program. As such I will maintain the 

highest safety standards, continue with constant hands on training in a controlled area away from the 

public, and utilize flight simulators. I will also maintain awareness of current airspace closures, 

Prohibited Areas and “NO DRONE ZONES” 

Public Interest 

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, 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 enhance 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 data regarding the use of UAS as part of this 

application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or 

other means as required.

 

Conclusion 

The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography,

videography, mapping, crop surveying, inspections and other flight operations”. The 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 pent up demand for these services currently exists 

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

Adding to the level of safety and experience in these operations, the petitioner has experience in the 

radio control model aircraft hobby, 19 years experience in general and commercial aviation and holds 

the following FAA Licenses and Ratings: 

Airline Transport Pilot Certificate (AMEL) Commercial Pilot License (ASEL)
Certified Flight Instructor - Single and Multi Engine Land, Instrument Airplane

Company Check Airman – ExpressJet Airlines 121 Carrier

 

Thank you in advance for your time and consideration. 

Kind Regards, 

Robert Michael Karman

INSPIRE 1

Weight 2935g (Battery Included)

Takeoff Weight 3400g

Hovering Accuracy 

(GPS mode) Vertical:0.5m;Horizontal:2.5m

Max Angular Velocity Pitch:300°/s;Yaw:150°/s

Max Tilt Angle 35°

Max Ascent/Descent Speed 5/4 m/s

Max Speed 22m/s(ATTI mode,no wind)

Max Flight Altitude 4500m

Max Wind Speed Resistance 10m/s

Operating Temperature Range -10°~40°C

Max Flight Time Approximately 18 minutes

Indoor Hovering Enabled by default

 Advanced Ready-to-Fly Design 

 Intelligent Power 

 Management System 

 Full-Featured App 

 Dedicated Controls 

 A Complete Ready-To-Fly System 

Remote Controller

 Operating Frequency

922.7 ~ 927.7 MHz (Japan Only) 
5.725 ~ 5.825 GHz 

2.400 ~ 2.483 GHz 

 Transmitting Distance (outdoor and unobstructed: 2 km 

EIRP

10dBm@900M 

13dBm@5.8G 

20dBm@2.4G 

 Output Power:9W 

 Battery: 6000 mAh LiPo 2S 

 Max Mobile Device Width:170mm 

DJI PHANTOM3 PROFESSIONAL

Battery 6000 mAh LiPo 2S

Phantom 3 Professional Weight 1280g (with battery & propellers)

Hover Accuracy (Ready to Fly)

Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 

m

Horizontal:1.5m

Max Ascent / Descent Speed Ascent: 5m/s

Descent: 3m/s

Max Flight Speed 16m/s((ATTI mode, no wind)

Diagonal Length 590mm

Controllable Range of Gimbal Pitch -90°to +30°

 Operating Frequency: 2.400 GHz-2.483 GHz 

 Max Distance: 2000m (outdoors and unobstructed) 

 Receiver Sensitivity (1%PER): -101 dBm ±2 dBm 

 Transmitter Power (EIRP): FCC: 20 dBm CE: 16 dBm 

 Working Voltage: 1.2 A @7.4 V 

Yuneec Q500

Flight Time up to 25 minutes

Weight with Battery and Payload60.0 oz (1700g)

Weight without Battery and 

Payload 40.0 oz (1130g)

Battery 5400mAh 3S 11.1V LiPo (included)

Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter 

(included)

Transmitter 10-channel 2.4GHz with 5.8GHz video downlink (included)

3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home

Maximum Flying Height Default 122m (400ft) above Ground Level (Adjustable via the 

Typhoon GUI)
Maximum Rotation Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature Range −5°C to 80°C

Radio Control Frequency Band 2.4GHz

Max. Descent Speed 2m/s

Max. Flight Speed 8m/s

Transmitter Type ST10+

Operating System AndroidTM

Number of Channels 10

Control Transmission 

Range (Optimum 

Conditions)

FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m 

(1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual 

Line of Sight of Aircraft at All Times

Robust Radio Control 

Modulation Yuneec Protocol

Video Link Frequency 

Band 5.8GHz

Video Transmission Range 

(Optimum Conditions)

FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m 

(984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual 

Line of Sight of Aircraft at All Times

Flight Systems Telemetry 

Data On Screen Display Yes

LED Backlit LCD Screen Capacitive Multi-touch 5.5′′

Tactile (Vibrating) and 

Audible Feedback Yes

Built-in LiPo Battery 

Voltage / Capacity 3.6V/5200mAh 18.72Wh

Screen Resolution 854 × 480px

Camera Settings White balance, light exposure, ISO, shutter speed, video resolution, FPS, 

record video, take pictures