Thomas	Ryan	Drake

– Section	333	Exemption	Petition

January	20 ,	2015

U.S.	Department	of	Transportation,	Docket	Operations West	Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Ave.,	SE	Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation Regulations	f rom 14	C.F.R.	61.113(a)&(b); 91.7(a);	91.9(b)	(2); 91.109;119.121; 91.151(a);	91.405(a);	91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)

Dear Sir	or	Madam :

I,	Thomas	Ryan	Drake,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of 2012	and	the	pro cedures	contained	within	14	C.F.R.	11,	to	request	that	I,	Thomas	Ryan Drake,	an	owner	and	operator	of	small	unmanned	aircraft,	be	exempted	from	the Federal	Aviation	Regulations	(“FARs”)	listed	below	so	that	I, Thomas	Ryan	Drake ,	may operate	a	small	ultra	l ight	weight	unmanned	aircraft	system	(“UAS”)	commercially	in airspace	regulated	by	the	Federal	Aviation	Administration	(“FAA”) located	in	Southern California	(specifically	in	Los	Angeles	and	Ventura	Counties) in	accordance	with FAA	UAS Regulations	&	Polici es

.

This	exemption request is	made	based	on	information	outlined	in	this	petition,	as	well as	the	accompanying	DJI Phantom	Vision	2+	Operators	Manual 1 and	Personal	Protocols
and	Controls 2 .	The	DJI	Phantom Vision 2+	UAS	was	selected	because	it	has	a	proven capability	for	controlled	flight	as	well	as	a	gyro	stabilized	flight	mode,	GPS	aided navigation,	a	compass,	blinking	LED’s	on	the	bottom,	a	failsafe	mode	for	returning home,	and	prop	guards.	These	devices	are	offered	for	general	sale	around	the	world	and
have	often	been	used	as	Model	Aircraft	in	the	USA. In	addition, I, Thomas	Ryan	Drake

, have flown	UAS’s	in	a	recreational	capacity	since	2013	and	have adopted safety protocols	and	controls to	avoid	and	prevent	public	hazard,	as	well	as	manned	aircraft
hazar ds/catastrophe.	This	will	act	to	further	safety	protocols	exclusive	to	lightweight UAS's	specific	to	video	and	photography	usage	as	I, Thomas	Ryan	Drake

, record	flight data	and	other	information	gained	through	permitted	flight	operations	to share	with	the FAA	through	any	required	FAA	reports	to	assist	with	future	protocol	and safety regulation.

I.	Contact	Information

Thomas	Ryan	Drake DBA	six6one	Development
28388	Maitland	Ln.

1 Appendix	A

– DJI	Phantom	2	Vision+	Operator’s	Manual

2 Appendix	B

– Personal	Protocols	and	Controls 2 Appendix	B

– Personal	Protocols	and	ControlsThomas	Ryan	Drake

– Section	333	Exemption	Petition

Santa	Clarita,	CA Mobile:	(661)	313

- 5858 Email:	drake@six6one.com

II.	Informat ion	regarding	the	Phantom	2	Vision+	UAS

Specifically,	the	UAS	is:

A n	ultra	lightweight battery	operated	4

- motor	rotorcraft	in	the	form	of	a	quadcopter that	takes	off	and	lands	vertically,	manuf actured	by	DJI,	Model	Phantom	2 Vision + ,	with the	following equipment:

• An	on

- board	flight	computer	with	GPS	navigation	and	location	ability	that receives	signals	for	flight	controls	from	a	ground

- based	transmitter/controller;

• An	integrated	on

- board	camera	capable	of	capturing	imagery	in	the	form	of	full color,	h igh	definition	still	photos	and	video;

• An	on

- board	telemetry	system	that	delivers	flight	data	from	the	on

- board	flight computer	to	the	on

- board	radio	transmitter	including	altitude	AGL,	horizontal and	vertical	speed,	compass	direction	of	flight	and	direct ion	back	to	its	launch site;

• A	600mW,	5.8GHz	on

- board	radio	transmitter	that	transmits	live	video	from	the

on

- board	camera	plus	all	the	flight	data	from	the	telemetry	system	described above;

The	Ground	Station	Includes:

• A	Pilot	in	Command	(PIC)	in	oper ational	control	of	a	flight	operation	from beginning	to	end	and	who	controls	the	UAS	while	in	the	air;

• A	100mW,	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	control the	UAS	while	in	flight;

• A	radio	receiver	receiving	live	video	and	flight	d ata	from	the	on

- board	camera and	computer	projects	it	all	together	onto	a	screen	for	the	PIC	to	view	during flight;

• A	Visual	Observer	(VO)	is	a	person	who	provides	a	second	pair	of	eyes	to	visually track	the	UAS	while	in	flight.

III. Proposed	Operations

I,	Thomas	Ryan	Drake,	intend to	use	UAS s in two areas.	First, I	seek an	exemption	to perform	video	filming	and	photographing	by	air	for	public	and	private	use

. Second, I will employ	UAS’s	to	inspect	land,	residential	commercial	and	indu strial	structures and
property.Thomas	Ryan	Drake

– Section	333	Exemption	Petition

Specifically, I will	use	UASs which	are	equipped	with	cameras	and	sensors,	in	order	to engage	in	the	following	commercial	activities in	Los	Angeles	and	Ventura	Counties :

(a)	Video	filming	by	air	and	photographing	for public	and private	pu rposes, including:	television,	cinematography, advertising	or promotio ns. Filming	and Photography	will	only	be	conducted	with	permission	and	under	contract	with registered	owners	or	with	any	local	government	author ity	and only when	safe	to
do	so.

(b)	Vide o	filming	by	air	and	photographing	to	support	professional	operations	in engineering,	land	surveying and	development ,	architecture,	real	estate	and other	related	professional	activities. Filming	and	Photography	will	only	be conducted	with	permission	and	un der	contract	with	registered	owners	or	with any	local	government	authority	and only when	safe	to	do	so.

(c)	Inspection by	air	of	infrastructure	such	as	bridges,	highways,	photovoltaic power	stations, and	pipelines .	These	inspections	will	only	be	done	unde r

contract and	permission with any	registered owners	or	with any	local government	authority	and only when	safe	to	do	so.

(d )	Inspection	by	air	of	land	and	residential,	commercial	and	industrial structures,	only	under	contract and	permission with any regis tered owners	or with any	local	government	authority	and only when	safe	to	do	so.

(e )	Support	provided	to	search	and	rescue	operations	and	reconnaissance	in cases	of	need,	emergency	or	natural	disasters	only	when	government	authorities have	reques ted	it	by contract	or	donation	and only when	safe	to	do	so.

IV. Relevant	Statutory	Authority

This	Petition	for	Exemption	is	submitted	pursuant	to	Section	333(a)	through	(c)	of	the FAA	Modernization	and	Reform	Act	of	2012	("Reform	Act").	Congress	has	directed	the FAA	"to	safely	accelerate	the	integration	of	civil	unmanned	aircraft	systems	into	the national	airspace	system."	Pursuant	to	Section	333	of	the	Reform	Act,	the	FAA Administrator	is	to	permit	unmanned	aircraft	systems	to	operate	in	the	National	Air Space	( "NAS")	where	it	is	safe	to	do	so	based	on	the	following	considerations:

• The	UAS’s	size,	weight,	speed	and	operational	capability;

• Operation	of	the	UAS	in	close	proximity	to	ai rports	and	populated	areas;	and

• Operation	of	the	UAS	within	the	visual	line	of sight	of	the	operator.

Additionally,	the	FAA	Administrator	has	general	authority	to	grant	exemptions	from	the agency's	safety	regulations	and	minimum	standards	when	the	Administrator	decides	a requested	exemption	is	in	the	public	interest.	See	49	U.S.C. §	106(f)	(defining	theThomas	Ryan	Drake

– Section	333	Exemption	Petition

authority	of	the	Administrator);	49	U.S.C.	§	44701(f)	(permitting	exemptions	from§§ 44701(a),	(b)	and§§	44702

- 44716,et	seq.).	A	party	requesting	an	exemption	must explain	the	reasons	why	the	exemption:	(1)	would	benefit	the	public	a s	a	whole,	and	(2) would	not	adversely	affect	safety	(or	how	it	would	provide	a	level	of	safety	at	least equal	to	the	existing	rules).	See	14	C.F.R.	§	1 1.81	(petitions	for	exemption).

V. These Proposed	UAS	Operations	Meet	the	Requirements	of	Section	333	o f	the
Reform	Act

The proposed	operations	in	this	Petition	for	Exemption	qualify	for	expedited	approval pursuant	to	Section	333	of	the	Reform	Act	as	each	of	the	statutory	criteria	and	relevant
factors	are	satisfied.

VI. Approval	is	Warranted	Based	on	th e	UAS	Size,	Weight,	Speed,	and	Operational Capability

I,	Thomas,	Ryan	Drake, will	employ	the	DJI	Phantom Vision 2 +	quadcopter for	the operations	specified	in	this	Petition	for	exemption.

• The Phantom	2	Vision+ UASs	have	a	maximu m	take

- off	weight	of	less than	5 pounds

• F light	speed	will	not	exceed	15 miles	per	hour,	and	it	will	not	be	flown	in controlled	airspace	or	at	an altitude	that	exceeds	3 00	feet	AGL.

• All	flights	will	be	flown	in	such	a manner that	they	can	be	safely	terminated	with
a	reserve	batter y	power	of no	less	than 20 %	of	the	battery's	maximum	charge.

• The	DJI Phantom	2	Vision+ UAS	do es not	carry	any	flammable	propellant	or	fuel.

• The Phantom	2	Vision+ UAS	has	an	integrated	GPS	system	that	calculates	the UAS’s	position	and	height	and	relays	th at	information	via	a	secure	connection	to the	operator.

• T he	Phantom	2 Vision+ UAS	contain	a	failsafe	mode	if	its	connection	to	the remote	control	is	lost,	and	this	system	permits	the	UAS	to	return	to	a predetermined	location	and land	without	injury	or	dam age.

• For	additional	safety,	the Phantom	2	Vision+ will	be	retrofitted	with	prop	guards.

VII. Approval	is	Warranted	Based	on	the	Operational	Restrictions	Set	Forth	in	the Operations	Manual.

DJI's	operators	manual 3 and	the Personal	Protocols	and	Controls 4 contain	all	of	the procedures	and	limitations	necessary	to	successfully	perform	the	operations	specified	in this	Petition	for	Exemption.

3 Appendix	A

4 Appendix	BThomas	Ryan	Drake

– Section	333	Exemption	Petition

VIII.	Public	Interest

The	public	interest	will	be	served	by	granting Thomas	Ryan	Drake	a Petition	for Exemption in Los	Angeles	and	Ventura	Counties .	Congress	has	established	a	national policy	that	favors	early	integration	of	UASs	into	the	NAS	in	controlled,	safe	working environments	such	as	those	proposed	in	this	Petition.	In	addition,	the	public	also	has	an

interest in	reducing	the	hazards	associated	with	alternate	methods	of	conducting	similar operations.	Currently	operations	are	conducted	using	teams	that	physically	climb	onto structures	using	ladders,	using	low	flying	helicopters	or	aircraft, are	extremely	cost

pr o hibitive or are simply	not	available	by	traditional	means.	By	using	UAS,	exposure	to phy sical	hazards	will	be	reduced	by conducting	the	operation	while	remaining	safely	on the	ground.

Additionally, the intended	uses of	the Phantom	2	Vision+ UAS	as outlin ed	in	this
document have	identifiable	safety	benefits	that	include	reducing	the	danger	and

emissions	associ ated	with	full	size	helicopters. UAS	have	no	fuel	to ignite	or	explode,	no crew,	add a	greater	degree	of	flexibility, supplement the	current	capabili ties	offered	by manned	aircraft,	and	public	interest	for	a	ground	impact	of	a	small	lightweight	UAS	is further	minimized	from	an	ecological	and	safety	standpoint.

I X .	A Summary The	FAA	May	Publish	in	the	Federal	Register :

A.	14	C.F.R.	91:	Airworthiness Certificates,	Manuals	and	The	Like.

14	C.F.R.	91.7(a) I,	Thomas	Ryan	Drake,	will	ensure	the UAS is	in	airworthy condition	based	on	compliance	with	the Phantom	2	Vision+ operating documents	prior	to	each	flight.

14	C.F.R.	§	91.121 Relief	is	requested	cons idering	the	limited	altitude	of proposed	operations

.

B .	14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC.

Pursuant	to	14	C.F.R.	§ 61.113	(a), The	FAA	has	previously	declared	that additional	manned	airship	experience	of	a	commercially	cer tified	pilot	would	not
correlate	to	the airmanship skills	necessary	for	similarly	proposed	operations	in previously	issued	exemptions	to	this	regulation	through Exemption Nos.	11062
and	11138.

Pursuant	to	14	C.F.R.	§	61.113	(b), T he	stick	and	rudder	contr ols	of	the	typical
aircraft	one	would	be	trained	on	to achieve a	private	pilots	license	are completely	different	than	that	of	a	small	UAS .	Additionally

, the	FAA does	not require manned	ultra light	vehicle	PICs to	meet	any	aeronautical	knowledge,	age,

or	exp erience	requirements	or	to	have	airman	or	medical	cert ificates ( asThomas	Ryan	Drake

– Section	333	Exemption	Petition

outlined	in	14	C.F.R.	§	103)

. Ultralight	vehicles can weigh	more	than	500	pounds than	the	Phantom	2	Vision+, can carry up	to	5	gallons	of combustible	fuel,	and	fly at	speeds close	to double that ca pable	by	the	Phantom	2	Vision+. Due	to	these
facts

, and	in	the	absence	of	a	specific	UAS	Pilot	License

, I	submit	that prior	to any commercial operations	I,	Thomas	Ryan	Drake,	will obtain	a	Student	Pilot
Certificate	and complete a	basic	aviation	int roduction	course

, with 45 minutes	of logged	flight	time

, applied by	a	certified	flight	instructor

. I n	addition I	submit	32 plus	hours	of UAS	logged	flight	time	I	have	acquired	over	the	past	two	years 5

.

D.	14	C.F.R.	91.119 (c) :	Minimum	Safe	Altitudes.

14 C.F.R.	§	91.119 (c)	I,	Thomas	Ryan	Drake,	will	ensure	that	all	persons	and objects	not	essential	to	flight	operations	must	remain	500	feet	away	from operations.	In	addition	to	visual	monitoring	of	the	area,	a traffic cone	and warning sign 6 alerting	persons in	the	area	will	be	placed	at	the	operation	ground station.	To	protect	objects	and	personnel	essential	to	flight	operations	the Phantom	2	Vision+	will	be	fitted	with	propeller	guards	and	safety	wire 7 to minimize	potential	hazards.

E.	14	C.F.R.	91.151	(c) : Fuel	Requirements	for	Flight	in	VFR	Conditions

.

14	C.F.R.	91.151	(c), I,	Thomas	Ryan	Drake,	will	ensure	that	each	individual	flight will	not	begin	unless	there	is	enough	power	to	fly	to	the	first	point	of	intended landing	and	land	the	UA	with	30%	batter y	power	remaining.	In	addition,	each individual	flight	will	last	no	longer	than	20	minutes,	5	minutes	less	than	the manufacturer	stated	25	minutes	of	flight	time.

F .	14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections.

T he	above

- cited	Regulations	require,	amongst	other	things,	aircraft	owners	and operators	to	“have	[the]	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part
and shall	between	required	inspections,	except	as	provided	in	paragraph	(c)	of this	section, h ave	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter.
.	.	.”

These	Regulations	only	apply	to	aircraft	with	an	airworthiness	certificate.	They	will	not, therefore,	apply	to	my, Thomas	Ryan	Drake’s ,	UAS.	However,	as	a	safety	precaution	I

ins pect	my UAS per	operating	documents before	and	after	each	flight.

5 Appendi x	C

– Drake	UAS Flight	Logs

6 Appendix	D

– Warning	Sign

7 Appendix	E

– Phantom	2	Prop	Guard	Attachment	InstructionsThomas	Ryan	Drake

– Section	333	Exemption	Petition

X. Conclusion

This Petition	for	Exemption	satisfies	the	criteria	articulated	in	Section 333	of	the	Reform	Act	of	2012	including	weight,	speed,	operat ing	capabilities,	proximity

to airp orts	and	populated	areas,	operation	within	visual	line	of	sight	and	national security.	Additionally,	the	Petition	provides	more	than	adequate	justification	for	the grant	of	the	requested	exemptions	to	permit Thomas	Ryan	Drake	to	operate	a	Phantom

Vision	2+ Plus	UAS in	Los	Angeles	and	Ventura	Counties for	the	operations	specified
herein.

Granting	the	exemption	will	benefit	the	public	interest	as	a	whole	in	several	ways, including	(1)	significantly	improving	safety	and	reducing	risk	by	alleviating	human

exp osure	to	danger,	and	(2)	improving	the	quality	of	services	and	decreasing	operating costs	compared	with	conventional	flight	operations.

Very	Respectfully, Thomas	Ryan	Drake
28388	Maitland	Ln. Santa	Clarita,	CA	91350 drake@six6one.comThomas	Ryan	Drake

– Section	333	Exemption	Petition



# Appendix	A

DJI	Phantom Vision	2+	Manual

Sepa rate attachment
Also	available	at http://www.dji.com/product/phantom

- 2

- vision

- plus/downloadThomas	Ryan	Drake

– Section	333	Exemption	Petition



# Appendix	B

Protocols	and Co ntrols

### Protocols	and	Controls Safety	protocols	and	controls	for	UAS	flights

T ho m a s Ryan	Drake

– six6 one	Develpoment Page 1 of	2 Safety	for	public	on	the	ground	as	well	as	manned	aircraft	above	is	an	essential	and

utmost consideration	for	aerial	videos	and	photography.	As	such, these safety protocols	and	controls	must	be implemented	through	pre

- flight	preparation	and during	flight.

Pre

- Flight	Protocol:

• Check	batteries	with	voltage	meter	to	insure	fully	charged	and	ready	for	use.

• Inspect	batteries	for	damage	or	leakage	that	may	affect	proper	operation.

• Inspect	propellers	fo r	cracks,	chips	or	damage	that	may	cause	sudden	loss	of propulsion	or unmanageable/uncontrolled	flight.

• Check	weather	forecasts	for	wind	advisory	or	other	conditions	that	my impact	flight.

• Consult	five	(5)	mile	radius	map	for	airport	vicinity.

o Contact	re spective	airport	to	advise	of	estimated	flight time,	estimated flight	duration, estimated	elevation	of	flight,	and	any	other	pertinent information.

• Inspect	flight	area	for :

o vicinity	of	public	safety	helipads/heliports

o vicinity	of	medical	helipads/helipo rts

o vicinity	of	light	poles

o vicinity	or	utility	wires

o vicinity	of	trees

o flocks	of	birds	that	may	cause	interference	and	potential	flight	impact

o vicinity	of	any	elevated	obstructions	that	may	pose	potential	flight
hazard

o vicinity	of	roadways	wit h	moderate	to	heavy	traffic	that	can	be
distracted

o public	gatherings	that	may	attract	viewers

o optional	point	of	control	for	best	visual	site	of	UAS	while	in	flight

• Takeoff	and	landing

o i nspect	area	for	best	and	safest	point	of	takeoff	and	landing

o locate	a	secondary	landing	area	in	case	of	emergency

o if in	a	subdivision	or	area	that	is	within	150	feet	of	a	residential	street, post	warning

o sign(s)/stand(s)	" Caution

- Aerial	Photography	In	Progress

– Keep Back	150	Feet	"

### Protocols	and	Controls Safety	protocols	and	controls	for	UAS	flights

T ho m a s Ryan	Drake

– six6 one	Develpoment Page 2 of	2 Flight	Protocol:

• T akeoff	and	land	from	same	location

• R emain	alert	to	birds,	sound	or	aircraft,	curious	public,	and	approaching
vehicles

• D o	not	allow	anyone	to	engage	in	conversation	or	distract	the	remote	control pilot

• R estrict	flight	to	minimal	elevation	sufficient	to	acquire	desired	results

• R emain prepar ed	for	emergency	landing	at	all	times

• P ay	attention	to	flight	time

o I f	possible	set	a	timer	as	a	safety	alert

• L and	UAS	and	shut	down	propulsion	immediately	following	landing

Post	flight:

a) D isconnect	battery	to	prevent	accidental	activation	of	propulsion	system b) S ecure	UAS	in	a	safe	location c) R emove	all	warning	signs	from	public	access	areas

Emergency	or	Suspected	Haza rd:

• Immediate	land	UAS	at	safest	and	closet	ground	location	in	the	event :

o manned	aircraft	is	heard	or	seen	in	vicinity	of	flight

o there	is	a	public	gathering	within	established	safety	boundary wanting	to	observe	flight

o pilot	is	being	distracted	from	fo cusing	on	flight	and	safety

o sudden	change	in	weather	( e.g

. wind	bursts)

o sudden	increase	in	vehicular	traffic	in	vicinity	of	flight

o birds	enter	into	proximity	of	flight

o any	sudden	unsafe	event	that	can	cause	collision,	distraction	or interruption	of	cont rolThomas	Ryan	Drake

– Section	333	Exemption	Petition



# Appendix	C

Drake	UAS	F l ight LogsThomas	Ryan	Drake

– Section	333	Exemption	Petition



# Appendix	D

Warning	Sign

# A E R I A L F I L M I N G I N P R O G R E S S 

# S T A Y B A C K 1 5 0 F T

.Thomas	Ryan	Drake

– Section	333	Exemption	Petition



# Appendix	E

Phantom 2 Prop	Guard
Attachment	Instruct ions	V1.00©20 13

- 2014 DJI Innovations. All Rights Reserved. | 

## PHANTOM 2 Prop Guard Attachment Instruction s V1.0 0



### PHANTOM 2 桨 保护 器 安装说明 V1.0 0

Please follow the below instructions to attach your Phantom 2 Prop Guard s

. 请按照下面步骤安装桨保护 器

。

1. Gather together the Phantom 2, P rop G uards (4), M3 x12 s crews (8), thread and an Allen key

. 准 备 PHANTOM 2 飞行器

, 桨保护 器 ( 4 个 )

, M3 x12 螺丝 ( 8 颗 )

, 保护线

, 内六角螺丝刀。

2. R emov e the M3 x8 screws under each of the four motors ( Fig.1 )

. 按照图 1 所示, 使用螺丝刀卸下 原 PHANTOM 2 四个电机上 的 M3 x8 螺丝。

3. Place the P rop G uards and attach them with the M3 x12 screws ( Fig. 2 ) . Tighten as required. Do this for all fou r

P rop G uards. Do not use thread lock.

按照图 2 所示,适当用力拧紧 M3 x12 螺丝, 装好四个 P HANTOM 2 桨保护器。 不可以 使用螺丝胶。

4. Improve protection further by attach ing a thread through the Prop Guard s. This thread should go under the

Prop Guard s ( Fig. 3 )

. 按照图 3 所示, 为起到更好的保护作用, 将保护线 连到桨保护 器 上 ,注意穿线时 将线绕在桨保护器底部。

IMPORTANT : M3 x12 s crew is only for Prop Guard assembly

. W ithout a Prop Guard, use M3 x8 s crew to avoid

damaging the motor. 注意 : 此处安装桨保护器,使用型号为 M3 x12 的螺丝;如果没有安装桨保护器,只能使用型号为 M3 x8 螺

丝。否则,过长的螺丝会损坏电机。

Fig. 1 Removing Screws / 图 1 卸下原 螺丝 Fig. 2 Prop Guard Attachment / 图 2 安装 桨 保护 器

Fig. 3 C omplete / 图 3 正确安装示意图 Specifications/ 参数

Weight ( Single ) / 重量 (单个) : 21 g
Angle/ 角度 : 15 0 .0 o

Radius/ 半径 : 1 28

. 25 mm

Whole Size w ith Four P rop Guard s / 安装后

最大外形尺寸 : 613 mm