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 Refo rm 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 Sy stem ( UAS) commerciall y in airspace regulated b y 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 pr oviding 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 propert y and will do so with the propert y owner's consent and knowledge and that only people who have consented or otherwise have agre ed to be within the UAS’s radius during filming and photograph y applications. Travis L. McKinney has demonstrated the ability to safe ly and effectivel y fly the UAS DJI Phantom 3 and **DJI Inspire** which will be used for co mmercial and private purposes. He complies with local ordinances and laws regarding the operation of UAS , and adheres to all weather and environmental restrictions or lim itations in reference to the operations of UAS. Ad ditionally , he has completed training associated to the operation of UASs. Course s include: Basic UAS Qualifications L evel 1, Meteorology , Navigation, and Airspace Design and Operating Requirements.
All flights will in accordance with an y and all state or local laws regarding privacy

.2

I, Travis L. McKinney am seeking to amend E xemption No 13689 because I have added a new UAS ( **DJI Inspire** )

. I am committed to complying with all of the rules, guidelines , l imitations, 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 safel y and effectivel y run m y 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 amendm ent to my approved exemption, and a complete list of responsibilities Iassume as operator; it also contains information regarding the aircraft, public benefit and safet y 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 RE SP**  **ONSIBILITIES** 1. Operations authorized by this grant of exemption are limited to the DJ I Phantom 3 and **DJI Inspire**  when weighing less than 55 pounds including payload. Proposed operations of an y 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 o r 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 alt itude 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 PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’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 PI C and VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PI C alway s ma intains VLOS capability . The VO and PI C 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 her3

designation fo r the duration of the flight. The PI C 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 limi tations 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 ope rator 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. I f the operator determines that an y 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 ope ration 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 b y 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 propert y. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation. 10. Prior to each flight, the PI C 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 c omponents, 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 saf e 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 manufactur er safet y bulletins. 13. Under this grant of exemption, a PI C must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PI C must also hold a current FAA airman medical certificate or a valid U.S. driver’s li cense 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 PI C is rated on his or her p ilot certificate. 54

14. The operator may

not permit any

PIC to operate unless the PI C demonstrates the abilit y to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuve rs and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C 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 PI C’s ability

to safel y 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, trainin g 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 PI C must operate the UA with appro priate 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 th e airport sy mbol 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 an y 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 fr om the PI C. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property

. 19. The PI C must abort the flight in the event of unpredicted obstacles or emergenc ies. 20. The PI C 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 r eserve 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 b y the operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CF R §§ 91.9 and 91.203 must be available to the PI C at the5

Ground Control Station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or an y 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 b y 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 nonparticipati ng 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 immediatel y in a manner ensuring the safet y of nonparticipating persons; and b. The owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C 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 PI C, 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 propert y 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 b y 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 Safet y 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 Sy stem UAS s 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 **A mend**  **E xemption**  **No 13689** to operate a DJ I Phantom 3 and DJ I 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 C lass B, C and D airspace including a no - fl y zone feature.6

The DJ I Phantom 3 and DJIInspire 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 pe titioner will only operat e 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 o perations will ensure that the UAS will "not create a hazard to users o f the national airspace s ys tem 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 videograph y is planned.

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

 The UAS PI C will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current FAA medical certificate.

 The UAS operated b y the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

 The UAS will operate at s peeds of no more than 50 knots, can hover, and can simultaneously move verticall y and horizontally

.  Given the small size of th e UAS and the restricted sterile environment within which it will operate, SkyVideoCT’s operations adhere to the Reform Act's s afet y requirements.
If you have questions or need additional information, please contact me at travismckinney2@y ahoo.com or (517 755

- 7077

.

Sincerely Travis L. McKinney Gunner (CWO3) U. S. Marine Corps High Angle Images L. L. C.7