David C. Richardson 3848 West 2261 h Street Apt. #120 Torrance CA. 90505 Home: (760) 400-9853 Cell: (310) 251-0155 Dave@rv-7.com

Dear Sir or Madam: 

## i I

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act), and 14 C.F.R. Part 11, I David C. Richardson an emplbyee ofthe CaliforniaDepartment ofTransportation, hereby applies for an exemption from the FederalAviation Regulations (FARs) listed belowto allow operation ofa Small Unmanned Aircraft System (sUAS) on behalfofthe Department in airspace regulated bythe Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be establishedbythe FAA as required by Section 333.

The requested exemption would permit David C. Richardson to operate a sUAS for various California State Agencies and Departments using a small advanced sUAV in the following areas: Inspection, Land Management/Surveying, Special Events, Mapping, Emergency Response, Environmental Assessment, Bridge Inspection, Structure and Antenna inspection, Aerial Videography, Still Photography and Slope Stabilization inspection and assessment.

I, David C. Richardson have demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 2 Vision+ which will be used for all proposed use activities. As part ofthis exemption I, David C. Richardson will comply with local ordinances and laws regarding the operation ofsUAS, and adheres to all weather and environmental restrictions orlimitations in reference to the operations ofsUAS.

All flights will occur in compliance with any state orlocal laws regarding privacy.

I, David C. Richardson, am seeking the exemptionbecause I am committedto complying with all ofthe rules, guidelines, limitations, and future legislation set forth bythe FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have described. Without the exemption request granted, I would be unable to safely and effectively provide these services for the benefit and safety ofthe citizens ofthe State of California without excessive and undue costs and potential risk to persons andproperty that would beborne bythe taxpayers ofthe State ofCalifornia. It is my intention to comply with all FAAregulations and procedures and obtain

an exemption ofthe following regulations.

The following contains my list ofregulations from which I am seeking exemption, and a complete list of responsibilities I assume as operator; it also contains informationregarding the aircraft, public benefit and safety features, and similarpetitions 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. 91.10914 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 14C.F.R.91.401-91.417



### I, the Operator, Assume the Following Responsibilities

1. Operations authorized bythis grant ofexemption are limited to the DJI Phantom 2 Vision 

### + when weighing less than 55 pounds including payload. Proposed operations ofany other aircraftwill require a new petition or a petition to amend this exemption. 2. Operations for the purpose ofclosed-set motion picture andtelevision filming are notpermitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles perhour). 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 greaterthan the maximum UA operating airspeed recommendedbythe aircraft manufacturer. 4. The UA mustbe operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude mustbe reported in feet AGL. 5. The UA must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaidedby any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate orU.S. driver's license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line ofsight (YLOS) ofthe PIC and YO at all times. The YO maybe used to satisfY the YLOS requirement as long as the PIC always maintains YLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the YO can perform the duties required ofthe YO. 7. This exemption and all documents neededto operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant ofexemption, are hereinafter referred to as the operating documents. The operating documents mustbe accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations hereintake precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update

orrevise its operating documents. Itis the operator's responsibility to track such revisions and presentupdated and revised documents to the Administrator or any law enforcement officiaLupon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to this grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted this exemption, then the operator mustpetition for an amendment to its grant ofexemption. The FAA'sUAS Integration Office (AFS-80)may be contacted ifquestions arise regarding updates orrevisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation orflight characteristics, e.g., replacement ofa flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conductedby a PIC with a YO and mustremain at least 500 feet from otherpeople. The functional test flight must be conducted in such a manner so as to not pose

an undue hazard to persons andproperty.9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Priorto 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. Ifthe inspectionreveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operatinguntil the necessary maintenance has beenperformed 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. EachUAS operatedunder this exemption must comply with all manufacturer safetybulletins. 13. Under this grant ofexemption, a PIC musthold either an airline transport, commercial, private, recreational, or sportpilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issuedby a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC must also meetthe flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate. 14. The operator may notpermit 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 operatedunderthis exemption, including evasive and emergency maneuvers andmaintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency mustbe logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes oftraining 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 howthe UAS will be operated under this exemption are permittedunder the terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operatethe UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119. 15. UAS operations may notbe conducted during night, as defined in 14 CFR § 1.1. All operations mustbe conductedunder visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles ofan airportreference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter ofagreement with that airport's management is obtained or otherwisepermittedby a COA issued to the exemption holder. The letter ofagreement with the airport management mustbe made available to the Administrator or any law enforcement official upon request. 17. The UA may notbe operated less than 500feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. IftheUAS loses communications withthe PIC, the UA must return to a pre-determined location within the private or controlled-access property. 19. The PIC must abort the flight in the event ofunpredicted 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 conductthe intended operation and to operate after that for at least five minutes orwith the reserve powerrecommended bythe manufacturer ifgreater. 21. Air Traffic Organization (ATO) Certificate ofWaiver orAuthorization (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 cannotbe conducted under the terms ofthe attached CO A. 6 22. All aircraft operated in accordance withthis exemption must be identifiedby serial number, registered in accordance with 14 CFRpart47, andhave identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings mustbe as large as practicable.23. Documents usedby the operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR 

### §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS anytime the aircraft is operating. These documents mustbe made available to the Administrator or any law enforcement official upon request. 24. The UAmustremain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may notbe operatedbythe 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 presentthat sufficientlyprotectnonparticipating persons from the UA and/or debris in the event ofan accident. The operatormust ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety ofnonparticipating persons; and b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determinedthat it does notpresent an undue hazard. The PIC, VO, operatortrainees or essentialpersons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted overprivate orcontrolled-access property withpermission 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 ofthe operational

area as defined bythe applicable COA mustbe reportedto the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must bereported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: www.ntsb.gov.



### SIMILAREXEMPTIONS
They are similar in all/or many materialrespects to reliefpreviouslyrequested in Grant ofExemptionNos. 11062, 11109, 11112, and 11213

PublicBenefit and Safety
Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead oftraditional manned aircraft, will benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Byusing batterypower and electric motors, the DJI Phantom 2 Vision+ UAS produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, four to six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 15-30 gallons perhour ofleaded aviation fuel. The DJI Phantom 2 Vision+ UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS
are propelledbybatterypoweredelectric motors, rather than an internal combustion engine. By using the DJI Phantom 2 Vision+ UAS to performaerial acquisitions, the substantial riskto life andproperty in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced
or completely eliminated. Aside from the lack offlight crew members located onboardthe aircraft, the DJI Phantom 2 Vision+ UAS (weighing approximately 2.9pounds atmaximum gross weight with diagonal dimension of23.2 inches, and with no fuel onboard), has less physical potential for collateral damage to lifeandproperty on the ground, and inthe air, comparedto the manned aircraft thattypically conduct similar operations (weighing approximately 1600-3500 pounds with a wingspan ofapproximately 36 feet, a length of26 feet, and a fuel capacity of50 gallons).I David C. Richardson ampetitioning for an exemptionto operate a DJI Phantom 2 Vision+ 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 limitthe radius ofthe distance itflies from the operator andto exclude it from operations within designated Class B, C andD airspace including a no-fly zone feature. The DJI Phantom 2 Vision+ also has a failsafe function that is triggered inthe event communication is lost betweenthe sUAS and the main controller transmitter. At thattime, the sUAS will returnto its point oftakeoffand land safety. Ifthe connection is restored, the PIC can regain controlofflight andlandmanually.

These specifications meetwith the Model Aircraft Operating Standards as setbelow:

• The petitioner will only operate its sUAS in line-of-sight ofa pilot and/or observer and will operate at sites that are 'sufficient distance' from populated areas within the sterile area described in the Flight Operations Procedures Manual. Such operations will ensure that the sUAS will "not create a hazard to users ofthe national airspace system

orthe public."

• When flying the sUAS within three (3) miles ofan airport, airport operators will be notified andthe operator will give the right-of-way to avoid flying inthe proximity offull-scale aircraft. Maximum flight time for each operation will be 30 minutes.

• Flights will be terminated whenbattery levels reach 20%, allowing sufficientreserve flight time to safely landthe sUAS.

• The sUAS will be programmed so it will notbe operatedat an altitude that exceeds 400 feet AGL, andnot more than 200 feet above an elevatedplatform from which videography is planned.

• Minimum crew for each operation shall consist of: sUAS pilot and a visual sUAS observer.

• The sUAS PIC will be an FAA licensed airman holding a minimum ofa Private Pilot certificate and a current FAA medical certificate.

• The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

• The sUAS will operate at speeds ofno more than 50 knots, canhover, and can simultaneously move vertically and horizontally.

• Given the small size ofthe sUAS, the proposeduses andthe restricted environment within which it will operate, the operations onbehalfofCaliforniaDepartment ofTransportation will adhere to the Reform Act's safety requirements.



### David C. Richardson