Richard King 1478 Gunnison St. Mt. Pleasant, SC 29466 843-475-4271 

### mckelvie37@gmail.com

I, Richard King, owner and operator ofa DJI Phantom 3 Professional am submitting

an Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.40S(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b).

in orderto conduct Commercial UAS operations thatwill include aerial photography, aerial videography, and aerial inspection ofReal Estate, and Commercial Structures in the NAS as regulated bythe FAA.

Richard King is anAirline Transport Pilot, rated pilot and operator ofa DJI Phantom 3 Professional UAS. Due to my background as a Real Estate agent and Photographer, Iwould use the UAS to conduct aerial photography and surveying which was previously done in manned aircraft. Given the UAS's inherentadvantages and margins ofsafety over using manned aircraftto conductthe photography and video, I am requesting an Exemption Request Pursuantto Section 333 ofthe FAA Reform Act.

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Richard King, operator ofUnmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofdesignated UAS, provided such operations are conducted within and underthe conditions outlined herein or
as may be established bythe FAA as required by Section 333. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas:1. Aerial photographyand/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and otherrelated professional activities. 2. Aerial video and/or photographyfor public and/or private use including television, public events, cinematography and newsgathering. 3. Aerial inspection/photography ofresidential/commercial structures under
contractwith the owners or local governmentauthority. 4. Aerial inspection/photography ofresidential/commercial utility infrastructure including butnot limited to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography orproviding live video feed to assistwith search and

rescue operations in cases ofan emergency or natural disaster only when the local authorities or governmenthas requested itby contract. 6. Trainingto persons individually orbelonging to both private andjor public organizations to increase awareness and improve safety for currentand future UAS operations within theNAS.



### Iplan to operate a UAS, the 

### DJI PHANTOM 3 Professional which is comprised ofan unmanned aircraft and a transportable ground station. The Phantom 3 is referred to

as a quad-copterwith a maximum gross weightofabout 3 pounds. It is equipped with four rotors that are driven by electric motors powered bybatteries. The UA has

a maximum airspeed of 16 mfs.

Given the small size ofthe UAS involved and the restricted controlled environment within which they will operate, the applicantfits within thatzone ofsafety (an equivalentlevel ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofUASs to commence. Also due to the size ofthe UASs and the controlled areas in which the relevant UASs will operate, approval ofthe application presents no national security issue. Given the following, the grant ofthe requested exemptions is clearly in the public interest: Richard King proposes thatthe exemption requested herein applyto civil aircraftthat have the characteristics and that operatewith the limitations listed herein. These limitations provide for an exceptional level ofsafetyto operations. These limitations and conditions to which Richard King agrees to be bound when conducting commercial operations under an FAA issued exemption including: 1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofoperator. (Day VMC conditions) 3. Maximum total flight time for each operational flight will be 20 minutes. 4. Flights will be terminated at 15% batterypower reserve. 5. Flights will be operated at an altitude ofno more than 400 feetAGL 6. UAS operatorwill be trained and certified in the proper safety and operations. 7. The UAS will only operate within a controlled area as defined in the Procedures. 8. The operator will post advisor notice around the controlled area. 9. Ifthe UAS loses communications or loses its GPS signal, the UAS will have capabilityto return to a pre-determined location within the Security Perimeter and land.10. The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles

or emergencies. Accordingly, the applicant respectfullyrequests thatthe FAA grantthe requested exemption and are prepared to modify or amend any part ofthis requestto satisfy the need for an equivalentlevel ofsafety. We look forward to workingwith your office. A copy ofthe DJI Phantom 3 User Manual is available upon request.

Public InterestThe planned 

### UAS user will increase ground safety for aerial mapping, photography and surveying operations. This type ofdata collection has previouslybeen done by manned aircraft or by individuals on the ground. Both are more time consuming and

are more expensive than using a UAS. Use ofmanned aircraft poses enhanced risk to the pilot and onboard crew, who would be several hundred feet in the air. The enhanced safety and reduced environmental impact achieved using a UAS and carrying no passengers or crew, ratherthan a manned aircraft ofsignificantly greaterproportions, carrying crew in addition to flammable fuel, gives the FAA good

cause to find thatthe 

### UA operation enabled by this exemption is in the public interest.

With the exemptions ofthe mentioned rules Iwill be seekingto make my drone photography jvideography services available to the public. Alternativelythe public had seeked to use helicopters and aircraftto achieve what I can offer in a safer,

more cost efficient manner. By not using fuel, flying at safe heights and strictly following the usage recommendations from DJI and the regulations as setforth by the FAA.

Exemptions Requested Below: 14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associated with the aircrafts to be utilized, an exemption from Part 21 meets the requirements ofan equivalent level ofsafety under Part 11 and Section 3 3 3 ofthe reform Act. In all cases, an analysis ofthese criteria demonstrates thatthe 

### UA operated without an airworthiness certificate, in the restricted environmentand under the conditions proposed will be atleastas safe, or safer, than conventional aircraft operatingwith an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display ofmarks: general The UAs will nothave a cabin, cockpit, pilot station, fuselage, boom, ortail on which to mark certain words orphrases. Further, the two-inch lettering is difficult
to place on such a small aircraftwith dimensions smaller than the minimal letteringrequirement. 14 C.F.R. 61.113(a) 

### & (b): Private pilotprivileges and limitations: Pilot in command The FAA has previously declared that additional manned airship experience ofa commercially certified pilot would not correlateto the airmanship skills necessary for similarly proposed operations in previously issued exemptions to thisregulation through Exemption Nos. 11062 and 11138. However, I am an ATP (Airline Transport Pilot) Rated Pilot and do carry a Class 2 Medical Certificate. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAS in question, this regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraftflight manual, marking, and placard requirements Requires an aircraftflight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining a safety /flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes UAS will not operate anyhigher than 400 feet atground level. Iwill not fly over congested areas. Iwill plan operations beforehand, for properflight safety, and properheight analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS with a barometric sensor. An equivalentlevel of safety will be achieved by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions The UAS that Iwill fly are powered byelectricity, using lithium polymerbatteries that currentlyhave a flight limit ofapproximately no more than 20 minutes. Therefore, due to the limitations ofthe batteries, itis currentlyimpossible to complywith part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. However I will always fly safely while having the manuals with me at all times during operation. 14 C.F.R. 91.405(a): Maintenance Required, All maintenance will be accomplished according to manufacture based recommendations. 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections maybe required and should be granted since they only applyto aircraftwith an airworthiness certificate. However I, will perform preflight inspections ofthe UAS before each flight as outlined in the operating documents and will also follow manufacturer recommendations from said operating documents.

Sincerely,

Richard King 1478 Gunnison St Mt. Pleasant, SC 29466