1

Dec 28, 2015

U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591

SUBJECT: Petition to Amend Exemption No.13689, Pursuant to Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 

(a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 

91.417{a) & (b).

Ref: Exemption No. 13689

Regulatory Docket No. FAA–2015–3844

This petition is being submitted on my behalf of High Angle Images L. L. C.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), 

and 14 C.F.R. Part 11, Travis L. McKinney, a freelance photographer, hereby applies to amend 

granted exemption from the Federal Aviation Regulations (FARs) listed below to allow 

operation of an Unmanned Aircraft System (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) so long as such operations are conducted with and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Travis L. McKinney to pursue his commercial interests 

in providing services to clients using a UAS in the following areas: Real Estate, Marketing, 

Land Management/Surveying, Special Events, and Cinematography. Travis L. McKinney states 

that all UAS flights will occur over private or controlled access property and will do so with the 

property owner's consent and knowledge and that only people who have consented or otherwise 

have agreed to be within the UAS’s radius during filming and photography applications.

Travis L. McKinney has demonstrated the ability to safely and effectively fly the UAS DJI

Phantom 3 and DJI Inspire which will be used for commercial and private purposes. He

complies with local ordinances and laws regarding the operation of UAS, and adheres to all 

weather and environmental restrictions or limitations in reference to the operations of UAS.

Additionally, he has completed training associated to the operation of UASs. Courses include: 

Basic UAS Qualifications Level 1, Meteorology, Navigation, and Airspace Design and 

Operating Requirements.

All flights will in accordance with any and all state or local laws regarding privacy.
2

I, Travis L. McKinney am seeking to amend Exemption No 13689 because I have added a new 

UAS (DJI Inspire). I am committed to complying with all of the rules, guidelines, limitations, 

and future legislation set forth by the FAA. I agree to operate the UAS in the manner that I have 

described, and for the purposes that I have described. I have been granted an exemption and I

continue to safely and effectively run my business legally, and it is my intention to continue to 

comply with the FAA and all regulations.

The following contains my list of regulations from which I am seeking an amendment to my

approved exemption, and a complete list of responsibilities I assume as operator; it also contains

information regarding the aircraft, public benefit and safety features, and similar petitions 

requests granted.

Regulations from which exemption is requested: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a) & (b), 14 C.F.R. 91.7(a), 14 C.F.R. 

91.9(b) (2), 14 C.F.R. 91.109, 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 

C.F.R. 91.203(a) & (b), 14 C.F.R. 91.205(b), 14 C.F.R. 91.215, 14 C.F.R. 91.401 - 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 and DJI 

Inspire when weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than 

the maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. I the operator will stay below 200 feel AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 
3

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between 

the conditions and 4 limitations in this exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA granted this 

exemption, then the operator must petition for an amendment to its grant of exemption. The 

FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates 

or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights may

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance; overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate. 5 
4

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart, unless a letter of agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official upon 

request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption holder 

may apply for a new or amended COA if it intends to conduct operations that cannot be 

conducted under the terms of the attached COA. 6 

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 
5

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at 

all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety assessment of the 

risk of operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons 

under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System UASs are often seen as superior to helicopters as an aerial video 

gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced 

noise and as such, a much smaller environmental impact which promotes public safety. 

I am petitioning to Amend Exemption No 13689 to operate a DJI Phantom 3 and DJI Inspirer 

with a built-in stabilized HD camera and GPS safety features which limit its ability to limit the 

height it flies above ground level (AGL), to limit the radius of the distance it flies from the 

operator and to exclude it from operations within designated Class B, C and D airspace including 

a no-fly zone feature. 
6

The DJI Phantom 3 and DJI Inspire also have a failsafe function that is triggered in the event 

communication is lost between the UAS and the main controller transmitter. At that time, the 

UAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can 

regain control of flight and land manually. 

These specifications meet with the Model Aircraft Operating Standards as set below: 

 The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and will 

operate at sites that are `sufficient distance' from populated areas within the sterile area described 

in the FOPM. Such operations will ensure that the UAS will "not create a hazard to users of the 

national airspace system or the public." 

 When flying the UAS within three (3) miles of an airport, airport operators will be notified and 

the operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. 

Maximum flight time for each operation will be 30 minutes. 

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight 

time to safely land the UAS. 

 The UAS will be programmed so it will not be operated at an altitude that exceeds 400 feet 

AGL, and not more than 200 feet above an elevated platform from which videography is 

planned. 

 Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and 

the camera operator. 

 The UAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate 

and a current FAA medical certificate. 

 The UAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. 

camera, lens, and stabilized gimbal). 

 The UAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously

move vertically and horizontally. 

 Given the small size of the UAS and the restricted sterile environment within which it will 

operate, SkyVideoCT’s operations adhere to the Reform Act's safety requirements.

If you have questions or need additional information, please contact me at 

travismckinney2@yahoo.com or (517 755-7077.

 Sincerely

Travis L. McKinney

Gunner (CWO3) U. S. Marine Corps

High Angle Images L. L. C.
7