1 Jeremy R Skeens, DPT Jeremy R. Skeens, DPT 10807 N Oakland Ave Kansas City, Missouri (402) 587 - 1548 Jrskeens@gmail.com July 21, 2015 U.S. Department of Transportation, Docket Operations We st Building Ground Floor Room W 12 - 140 1200 New Jersey Avenue, SE Wa shington, DC 20590 To W hom It May Concern: I, Jeremy Skeens, am petitioning for an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. I, Jeremy Skeens, an owner and operator of small unmanned aircraft, is applying for e xemption from the federal aviation regulations (“FARs”) listed below so that I, Jeremy Skeens, may operate an unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration. **Petition:** Regulations from which the exemption is requested: 14 CFR 61.23(a) and(c) 14 CFR 61.101(e)(4) and (5) 14 CFR 61.113(a) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a)(1) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2) 14 CFR 91.417 ( a) and (b) to the extent necessary to allow the petitioner to operate the DJI Phantom 3 Professional UAS to perform aerial video and photographic collection. **Regarding the Unmanned A ircraft Sy** **stem:** I, Jeremy Skeens, am petitioning to use the Phantom 3 P rofessional Unmanned Aircraft System to capture aerial photography and videography for commercial use. The DJI Phantom 3 is a quad - rotor Unmanned Aircraft System (UAS) weighing less than 3 pounds. The Phantom 3 UAS that I will be responsible for also utili zes a mobile ground station. The UAS features a safety Return to Home function that in the event of a signal loss, will return to a preset position and land. The Return to Home feature can also be triggered manually. The remote connects to your phone or ta blet and a 720p HD view of everything your camera sees as you fly is displayed live. This immersive view streams to you in absolute clarity, enabling safe flying. From takeoff to landing, the Phantom 3 responds to commands while automatically handling the most complex aspects of safe, stable flight.2 Jeremy R Skeens, DPT

Attached, you’ll find a copy of the Phantom 3 Advanced user manual that explains the excess safety measures taken to ensure no issues arise.

**UA S Operating Parameters & the Unmanned Aircraft PIC:**  I will abide by the following additional operating conditions under this exemption, which ensures a level of safety at least equal to existing rules:
● Operate UAS below 250 feet AGL and within a radius distance of 1000 feet from the controller to aid in di rect line of sight visual observation
● Obtain permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessmen t of the risk of operating closer to those objects and determine that it does not present an undue hazard
● Operate the UAS for 5 - 15 minutes per flight
● Land UAS prior to the manufacturer’s recommended minimum level of battery power
● Operate UAS during dayl ight hours only within visual line of sight (VLOS)
● Use the UAS global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost
● Conduct all operations under the flight sa fety protocols contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance safety protocols
● Contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information
● Always obtain all necessary permissions prior to operation
● Have procedures in place to abort flights in the event of safety breaches or potential danger
● Onl y operate in safe environments that are strictly controlled, are away from power lines, elevated lights and airports
● Conduct extensive preflight inspections and protocols, during which safety carries primary importance. UAS Pilot in Command (PIC) All PICs will demonstrate the required aeronautical knowledge and the ability to safely operate the UAS in a manner consistent with how the UAS will be operated for the requested exemption, including evasive and3 Jeremy R Skeens, DPT

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures
● The pre - flight inspection section in the operating documents wil l account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents
● I will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspect ion, and life limit requirements
● I will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service
● Each UAS operated will comply with all manufacturer's Safety Bulletins
● UAS operations will not be conducted during night, as defined in 14 C FR 1.1. All operations will be conducted under visual meteorological conditions (VMC)
● The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA- published aeronautical chart
● If a UA loses communications or l oses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents
● The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accor dance with the operating documents
● The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaini ng ● The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon re quest ● The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times
● The UAS will not be operated by the PIC from any moving device or vehicle
● Flight operations will be conducted at least 500 feet from a ll nonparticipating persons, vessels, vehicles, and structures unless:4 Jeremy R Skeens, DPT ○ a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. We will ensure that nonparticipating persons remain under such protection. If a situation arises where nonpartic ipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; ○ b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures h as granted permission 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
● All operations will be conducted over private or controlled - access property with permis sion from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
● Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS - 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB We b site: www.ntsb.gov . 

### Public Interest: Aerial videography and photography for marketing has been around for a long time through manned fixed wing aircraft and helicopters. Its cost, however, has been nearly unreachable for many small businesses. Granting this exemption to me would allow me to p rovide this service at a much lower cost. My UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to manned aircraft. The return to home feature proves to be a failsafe plan that will ensure safety is not an issue.



### Conclusion: As set forth herein, Jeremy Skeens seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially u sing aerial photography and videography. By granting the Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing myself, Jer emy R. Skeens, to safely and efficiently operate its UAS commercially within the NAS.5 Jeremy R Skeens, DPT

Regards; Jeremy R. Skeens, DPT