,.**·~** Travis Knoop Travis Knoop Photography, LLC

4200 W. Eaglerock Dr. Wenatchee, WA 98801
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_. -. ,__•'.... ·-•-**~::·** i. • "\ September 26, 2015**-~** Cell: 509.860.4321Email: travisknoop@gmail.com U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

.,"'.- -..**~**....**~. ~**  1.•,.0 L**.~;**J . _.::ti'!-..: RE: Exemption Request Section 333 ofthe FAA Reform Act of 2012 Dear Siror Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Actof 2012 (the Reform Act}, Travis Knoop Photography, LLC, and owner Travis Knoop hereby apply foran exemption from Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of small unmanned aerial systems for the primary purpose of aerial photography and video. Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 9.1.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14CFR91.12114 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(2) 14 CFR 91.417 (a) and (b) Extent of reliefIseek and reasoning behind the request:

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I14 CFR Part 21 subpart H The UAS's tobe operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircrafts tobe utilized, I request exception. Inthe restricted environment and under the conditions proposed operation will beat least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without

said restrictions.

14 CFR 45.23 (b) Due tothe size of these UAS's they do not have a cockpit, cabin, or pilot station on which to market certain words or phrases. Lettering would be very difficult to place on such a

small aircraft and dimensions would need tobe smaller than required minimum. 14 CFR 91.7 (al As there will beno airworthiness certificate for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircrafts for maintenance and use of safety check list prior to each flight an equivalent level of safety will be provided. 14 CFR 91.9 (b)(2) Given the size and configuration, the UAS's have no ability to carry a flight manual onthe aircraft. There isno room, capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will be maintained by keeping the flight manual at ground control point where the pilot will have immediate access toit. 14 CFR 91.103 As FAA approved flight manuals will notbe provided for the aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along willallof those found in attachment "OJIPilot Training". An equivalent level of safety will be provided by preflight protocol to properly match the machine. 14 CFR 91.109 UAS's and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the useofa control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried inthe aircraft, and bythe speed and size ofthe aircraft.14 CFR 91.113 (a) and (b)

Travis Knoop Photography, LLC can achieve an equivalent level of safety as achieved by current regulations because my UAS's do not carry pilot nor passenger. While helpful, a pilot's license will not ensure remote control piloting skills.14CFR91.121The UAS's may not have a barometric altimeter, but instead does have a GPS altitude read out; an exemption may be needed. An equivalent level of safety is achieve

bythe operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS altitude indicator. 14 CFR 91.203 (a) and (b) Similar to14 CFR 91.9 (b) (2), given the size and configuration, the UAS's have no ability to

carry certificate and registration documents onthe aircraft. There isno room, capacity,or pilot on board to adequately such documents. An equivalent level of safety will be achieved by keeping these documents, tothe extent they are applicable tothe UAS's, at the ground control point where pilot has immediate access to them. 14 CFR 91.405 (a). 14 CFR 91.407 (a) (1). 14 CFR 91.409 (a) (2). 14 CFR 91.417 (a) and (b) Given these section only apply to aircraft with an airworthiness certificate, these sections do not apply tothis applicant. Asa safety precaution, operator will perform preflight inspections and ensure the UAS's arein working condition before initiating each flight.

Travis Knoop Photography, LLCis seeking relief from all FARs above preventing applicant from conducting aerial photography and video ofreal estate taken at levels less than 400ft, at a speed less than 40 mph, and witha maximum flight time of25 minutes. The UAS's tobe used isaOJI Phantom 2andaDJI Inspire 1.At 3.08 pounds (OJI Phantom 2and gimbal/camera) and 6.6 pounds (OJI Inspire 1)the weight ofthe UAS meets the definition of "small unmanned aircraft" found in section 331.

"The Reform Act". In order to obtain high quality photography and video the UAS willbe used at speeds much less than itstop speed of 33.5 (Phantom 2) and 49 (Inspire 1) mph. Due tothe UAS being battery powered there are no combustible fuels on board. Maximum flight time for these particular UAS's varies between 18 and 25 minutes battery life, and flights will be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated with the aircraft tobe utilized Ifind this exception tobe reasonable with an equivalent, orgreater, level of safety tobe reached bythe operator. The UAS's Both UAS's utilize internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. They are controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back toa ground control station allowing the operator and/or PICto monitor battery level, GPS signal strength, altitude (AGL), distance from . PIC, camera imagery, and control camera angle. They have failsafe modes of operation for either loss ofRCor GPS signal. Altitude can be limited bythe onboard flight controller and maximum altitude can be preprogrammed bythe PIC. Battery life limits flight times to approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry andexternal lighting cues before reaching alow battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. Itis anticipated that

flights will usually last less than 15 minutes. More information is available in Attachment 1and2.

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 will be developed and employed 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. These documents will be made available tothe FAA and SOT to assist in future implementation of safety standards and regulations. The petitioner will only operate the UAS over designated properties with the owner's consent. Flight plans will be predetermined to limit the UAS'ss flight time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating the UAS. UAS operation will always be within VLOS ofthe PIC and the observer.Public Interest The useofan UAS inthe real estate industry provides both buyers and sellers a higher level of service. Fora seller a higher level of marketing and advertising is achieved, appealing to more buyers, resulting ina quicker sale of their home. Quicker home sales also helps accelerate the economy asa whole. Buyers experience the benefit of encompassing a whole property, sometimes several

acres, inone photo ora short video. Aerial photography provides the opportunity to view the topography, setting and orientation ofa particular property. Not only does this benefit the specific home selleror home buyer, butit benefits the general public because itis much more efficient than traditional ways of using a plane or helicopter to achieve the same result. We can now provide this level of service while being conservative with fuel, time, emissions, noise, and other resources. Considering size, weight, speed, and absence of combustible fuels, my UAS's will pose much less ofa safety concern for the general public when compared

to larger manned aircraft.**~~sideration.** Travis Knoop, owner**~** Travis Knoop Photography, LLC

'l'l•Attachment 1:DJI Phantom 2 System Specs Aircraft: Weight (Battery & Propellers included) -1OOOg

Hover Accuracy (Ready toFly)- Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity- 200°/S Max Tilt Angle -35° Max Ascent I Descent Speed - Ascent: 6m/s; Descent: 2m/s Max Flight Speed - 15m/s Diagonal Length -350 mm Flight Time - 25mins Take-off Weight- :s1300g Operating Temperature- -10°C- 50°C Supported Battery -OJI Smart Battery 2.4GHz Remote Control: Operating Frequency - 2.4GHz I SM Communication Distance (open area)- 1000m Receiver Sensitivity (1%PER)- -97dBm Working CurrenWoltage -120 mA@3. ?V

Built-in LiPo Battery Working Current/Capacity- 3.7V, 2000mAh Full user manual available at: http://www.dji.com/productlphantom-2/download...**..,-;~"..**.;:-.-·...._ Attachment 2:DJI Inspire 1 System Stats Aircraft: Weight (Battery & Propellers included) - 2935g

Hover Accuracy (Ready toFly)- Vertical: 0.5m; Horizontal: 2.5m

Max Yaw Angular Velocity- 150°/s Max Tilt Angle- 35° Max Ascent I Descent Speed - Ascent: 5m/s; Descent: 4m/s Max Flight Speed - 22m/s Diagonal Length -559to581 mm Flight Time-18 mins Operating Temperature- -10°C- 40°C Supported Battery- DJI Intelligent Flight Battery 4500 -5700 mAh 2.4GHz Remote Control: Operating Frequency- 5.725-5.825 or 2.400-2.483 GHz SM Communication Distance (open area)- 2km Receiver Sensitivity (1%PER)- 10dBn@900m, 13dBn@5.8G, 20dBm@2.4G Built-in LiPo Battery Working Current/Capacity- 6000mAh LiPo 2S Full user manual available at: http://www.dji.com/productlinspire-1/download