Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 1 of 14 August 30 , 2015 

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Attn: 

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U.S. Department of Transportation, Docket Operations 

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West Building Ground Floor, Room W12

- 140 

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1200 New Jersey Avenue, SE 

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Washington, DC 20590 

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RE: Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act 

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of 2012 

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Kellen Razzano 

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SkyLogical 

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15642 Sand Canyon Ave. 

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PO BOX 54341 

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Irvine, CA 92619

- 4341 

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(949) 667

- 3617 

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kellen@skylogical.org 

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SUMMARY 

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KELLEN GREGORY RAZZANO d.b.a. SKYLOGICAL hereafter referred to as KELLEN RAZZANO 

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seeks exemption from the requirements from Federal Aviation Regulations pursuant to 

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14 C.F.R. and Section 333 of the FAA Moderni zation and Reform Act of 2012. 

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Section 333 states that the FAA may issue a certificate of waiver upon a finding that 

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a type of UAS, as a result of its size, weight, speed, operational capacity, 

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proximity to airports and populated areas, and operations within visual line of sight 

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do not create a hazard to users of the NAS or the public or pose a threat to national 

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security. The grant of such an ex emption is consistent with Congress’ intent, 

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reflected in Section 333, that safe systems be permitted in the national airspace 

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prior to the issuance of final regulations governing general use of these systems. 

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Being “unmanned aircraft and associated elements, including communication links and 

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the components that control the unmanned aircraft that are required for the pilot in 

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command to operate safely and efficiently in the national airspace system,” KELLEN 

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RAZZANO ’s UAS meet the Section 331 definitio n of “small unmanned aircraft.” 

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Section 332 provides for such integration of civil unmanned aircraft systems into our 

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national airspace system as it is in the public’s interest to do so. We would like 

### 47Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 2 of 14 to operate our small UAS(s) prior to the time period by which the Reform Act requires 

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the FAA to promulgate rules governing such craft, thereby providing direct experience 

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and valuable information for formal regulation. 

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KELLEN RAZZANO intends to use small UAS to provide aerial photography and videography 

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se rvices to businesses, organizations and community members. See the Public Benefit 

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section of this document for more details. More specifically, we intend to: 

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• Real

- estate marketing collateral (residential, commercial) 

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• Automotive and Marine photography 

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• Land scape cartography and documentation 

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• Special Event and Promotional videography 

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• Research and development of safety standards 

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• Private and governmental training 

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• E nable businesses to improve marketing and outreach through the use of 

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state

- of

- the

- art aerial ph ot ography and videography 

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• H elp to inspect buildings and structures, and map landscapes in a safe, 

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cost

- effective manner 

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• P rovide economic stimulus and public benefit by provid ing an effective 

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means by which companies or individuals can use up

- to

- date, high

- qu ality 

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p hotos and videos to learn about properties, neighborhoods and communities 

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• H elp communities realize economic benefit by encou raging public 

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participation and encouraging tourism; by showcasing community b uildings 

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and landscapes; and by documenting com munity events in low

- cost ways not 

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previously available to them 

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• I ncrease awareness/knowledge of the amenities of a local ar ea by the 

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general public and by visiting tourists 

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• P rovide non

- profit organizations as well as schools and univer sities and 

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local muni cipalities ways to showcase facilities, document events, and 

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educate the public 

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• A id e in search and rescue operations and accident investigators. 

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KELLEN RAZZANO has accrued over 1000 (one thousand) hours of UAS flight experience 

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and has safely piloted and operated electric

- powered airplanes, helicopters, multi



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rotors and other experimental aircraft since 2010. KELLEN RAZZANO additionally holds 

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an open member ship with the Academy of Model Aeronautic s (AMA), conforming to safety 

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regulations, upho lding to practice guidelines , and demonstrating advanced UAS pilot 

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maneuvers

. In the hobby sector KELLEN RAZZANO has also administered aircraft flying 

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instruction and safety protocols to individuals since approximately 2011

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We understand that we are entitled to submit a Petition for Exemption if we believe 

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that following a rule will burden us ; we can provide a level of safety at least equal 

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to that provide d by the rule; and our req uest is in the public interest. Therefore

, 

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KELLEN RAZZANO is seek ing e xemption from the fo llowing sections of the current 

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regulations: 

### 94Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 3 of 14 95

14 CFR 21 subpart H

- Certification procedures; Airworthiness Certificates 

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14 CFR 45.23

- Display of Marks 

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14 CFR 61.113 (a) & (b)

- Private Pilot Privileges and Limitations 

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14 CFR 91.105

- Flight crewmembers at stations 

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14 CFR 91.109 (a)

- Flight instruction 

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14 CFR 91.119 (c)

- Minimum safe altitudes 

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14 CFR 91.121

- Altimeter settings 

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14 CFR 91.151 (a)

- Fuel Requirements for Flight in VFR Conditions 

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14 CFR 91.203

- Carrying Civil Aircraft C ertification and Registration 

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14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2)

- Maintenance 

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required; Operation after maintenance, preventive maintenance, rebuilding or 

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alteration 

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14 CFR 91.417 (a) & (b)

- Maintenance Records 

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14 CFR 91.7 (a)

- Civil Aircraft Airworthiness 

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14 CFR 91.9 (b)

- Civil aircraft flight manual, marking, and placard 

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requirements. 

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This application is similar to many which have received FAA approval. As stated in 

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E xemption #11639, the FAA has found that the enhanced saf ety achieved using an UAS 

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wi th the specifications described by herein, and carrying no passengers or crew, 

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rather than a manned ai rcraft of significantly greater proportions, carrying crew in 

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addition to flammable fuel, gives the F AA good cause to find tha t such exemption is 

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in the public interest. Since we are applying at a time w hen the FAA is using a 

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“summary grant process” be informed that while developing this req uest we reviewed, 

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among others, exemptions #11636, #11639, #11595, #11596, #11564, #11569, and #11616. 

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Extent of Relief and Reason for Seeking Reli ef; Why the Exemption would not Adversely 

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Affect Safety, or How the Exemption would provide a Level of Sa fety Equal to Existing 

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Rule 

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Part 21 Airwort hiness Certification; Subpart H Certification pro cedures for products 

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and parts, Airworthiness Certificates 

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This section outlines requirements for the issue of design and prod uction approvals, 

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airworthiness certificates, and other airworthiness approvals. We seek relief from 

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thi s rule because the size, w eight and enclosed operational area of our UAS, as 

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described els ewhere in this document, permit exemption fr om Part 21 because our UAS 

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meet and exceed an equivalent level of safety pursuant to Section 333 of the Reform 

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Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

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requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform 

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Act. Therefore, relief from 14 CFR part 21, and any associated noise certifi cation 

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and testing requirements of part 36, is not necessary. 

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Instead of following this requirement, we will as outlined in t his document, as per 

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our Flight Operations and Procedures Manual and Training Manual (curr ently in 

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development), KELLEN RAZZANO seeks to uphold the same level or exceeded level of 

### 140Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 4 of 14 safet y as described in Part 21 of 14 C.F.R. Th erefore this exemption will not 

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adversely affect safety or will provide a level of safety equal to the existing rule. 

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14 CFR 45.23 Display of Marks 

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This section outlines regulations requiring specific location(s) and size of aircraft 

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marks. We seek relief from this rule because, given the size of our UAS, and the lack 

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of c abin, cockpit or pilot station, two

- inch lettering is difficult t o place on such 

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small aircraft. 

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Instead of following this requireme nt, we will mark the UAS in lettering that is as 

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large as practicable by placing an N number registered with the FAA on its fuselage 

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so that the PIC, VO, or other observer s will see the markings. This exemption will 

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therefore not adversely affect safety or will provide a level of safety equal to the 

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existing rule. 

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14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations 

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This section describes regulations concerning certification of pilots . We seek relief 

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from this rule because the risks associated with the operation of a UAS are lesser 

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t han and often uncorrelated with the risks associated with the commercial and private 

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aircraft ope rations contemplated by Part 61 when drafted. The skills required to fly 

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large, manned aircraft are substant ially diff erent from the skills required to 

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remotely operate a small UAS. Also, manned aerial vehic les weighing significantly 

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more than small drones (such as ultralight vehicles) as well as small UAS legally 

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operated by hobbyists, operate without the need for pilot certification. 

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Requiring a private or commercial pilot certificate would provide no appreciable 

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safety benefit and would needlessly impose an undue burden of time and cost on KELLEN 

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RAZZANO , most particularly in light of the FAA’s Small UAS Notice of Prop osed 

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Rulemaking which proposes that small UAS pilots be considered ‘operators’ required to 

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meet certain requirements that do not include pilot’s license. 

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Instead of following this requirement, to minimize risk and maximize saf ety, all UAS 

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operations will be controlled and limited, and all flights will be planned and 

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coordinated prior to operations: 

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• P rior to operations, KELLEN RAZZANO’s PIC(s) will go through a 

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documented process of dedicated ground school and flight lessons in 

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accordance with manufacturer and industry guides. 

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• A ll PIC’s will only operate the UAS as stated in this document and in 

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our Flight Operations and 

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• Procedures Manual, flying at altitudes well below the permissible limit s 

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for other civil aircraft, and within a geographical envelope under the 

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control of KELLEN RAZZANO clients. 

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• T he PIC will be designated before a flight and will not transfer control 

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at any time during a flight. 

### 186Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 5 of 14 • KELLEN RAZZANO PICs will comply with upcoming FAA Operator Certification 

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and Responsibi lities once they are finalized. 

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This exemption will therefore not adversely affect safety or will provide a level of 

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safety equa l to the existing rule. More information about pilot safety can be found 

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in the Operation of the Unmanned 

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Aircraft to Minimize Risk to the NAS, Peop le and Property section of this document. 

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14 CFR 91.105 Flight crewmembers at stations 

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This section outlines regulations for flight crewmembers inside an air craft. We seek 

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relief from this rule because there is no flight crew onboard a small UAS. 

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Instead of following this requirement, in keeping with the direction of the 

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regulation, the PIC of the 

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UAS and VO will be at their respective crewmember stations on the gr ound during 

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takeoff and landing as well as the complete duration of the flight. By instituti ng 

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thi s procedure this exemption will therefore not adversely affect safety or will 

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provide a level of safety equal to the existing rule. 

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14 CFR 91.109 (a) Flight Instruction 

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This section provides that no person may operate a civil aircraft (except a man ned 

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free balloon) that is being used for flight instruction unless that aircraft has 

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fully functionin g dual controls. We seek relief from this rule because UAS do not 

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have f ully functioning dual controls. 

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Instead, flight control is accomplished through th e use of a control box that 

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communicates with the aircraft via radio communications. The FAA has approved 

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exemptions fo r flight training without fully functional dual controls for a number of 

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aircraft and for flight instruction in experimental aircraft. Th is exemption will 

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therefore not adversely affect safety or will provide a level of safety equal to the 

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existing rule. 

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14 CFR 91.119 (c) Minimum safe altitudes: General 

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This section establishes minimum altitudes for operation of civil aircraft . We seek 

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re lief from this rule because the services we intend to provide for the public good 

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may require photo or video images captured from an altitude of less than 500 feet. 

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Instead of following this requirement, all UAS flights will be conducted w ith within 

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visua l line of sight and with prior permission from the owner of the property or 

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municipality. All persons , vessels, vehicles, not directly involved with the 

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operation will be notified an d cleared of the area where UAS operations will be 

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conducted. Given our policies of advance notice and access restricted area, and given 

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the size, weight, maneuverability and speed of our UAS, we will maintain an 

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equivalent or higher level of safety of that described in this rule. 

### 232Petition for Exemption/Rulemaking

- KELLEN RAZZANO



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14 C FR 91.121 Altimeter settings 

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This section defines regulations for altimeter settings. We seek r elief from this 

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rule concerning altimeter settings because: our UAS has no altimeter settings. 

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In stead, electronic GPS downlinks telemetry data in real time to t he PIC’s ground



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based on

- screen display as to the altitude (AGL) of the UAS above the takeoff 

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location. 

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This exemption will not adversely affect safety, as our PIC will provide a level of 

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safety equal to the existing rule by confirming the altitude of the launch site shown 

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on the GPS altitude indicator prior to each flight. 

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14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions 

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This regulation prohibits an individual from beginning “a flight in a n airplane under 

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VFR conditions unless (consideri ng wind and forecast weather conditions) there is 

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enough fuel to fly to the first point of intended landing, and, assuming normal 

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cruising speed

– (1) During th e day, to fly after that for at least 30 minutes; or 

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(2) At night, to fly after that for at leas t 45 minutes. ” We seek relief from this 

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rule because our UAS runs on battery instead of fuel, most of our UAS fligh ts last 

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less than the 30 minute reserve requirement, and we do not fly at night. 

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Instead of following this requirement, an equivalent level of safety wi ll be achieved 

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by following the UAS manufacturer’s operating documents with regard to battery 

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vo ltage. To ensure safety and maintain adequate communication between radio control 

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and the UAS, our PIC will not begin a flight with a battery holdin g less than 75% 

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charge; and will not begin a flig ht unless (considering wind and forecast weather 

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conditions) there is enough power to fly to the i ntended landing point at normal 

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cruising speed and land the UAS with no less than 30% of battery po wer. A lan ding 

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sequence will be initiated at the 30% warning and the UAS automatically initiates 

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landing sequence at 15 % charge while still under PIC control. 

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Through implementation of these procedures, this exemption will not adversely affect 

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safety or will provid e a level of safety equal to the existing rule. 

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14 CFR 91.203 Carrying Civil Aircraft Certification and Registration 

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This regulation pertains to display of airworthiness certification within a n aircraft. 

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We seek relief from this rule because our small UAS each weigh less than 10 poun ds, 

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and are operated without an onboard pilot. There are passengers or crew; and no cabin 

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or cockpit entrance upon which to display certificates. 

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An equivalent level of safety will be achieved by keeping these docume nts at the 

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ground control point where the PIC will have immediate access to them, and be able to 

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provide them upon request. 

### 278Petition for Exemption/Rulemaking

- KELLEN RAZZANO



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14 CFR 91.405 (a) Maintenance required ; 14 CFR 91.407 (a) ( 1) Operation after 

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maintenance, Preventive maintenance, rebuilding, or alterat ion ; 14 CFR 91.409 (a) (2) 

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Inspections; and 14 CFR 91.41 7 (a) & (b) Maintenance records 

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We seek relief from these 4 rules because these regulations only apply to aircraft 

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with an airworthiness certificate, and will not, therefore, apply to KELLEN RAZZANO’s 

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UAS. We seek relief also because the FAA has not developed maintenance standards for 

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UAS that would allow an UAS operator to meet the part 91 maintenance requirements. In 

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particular, there are no individuals authorized by the FAA to approve a UAS for 

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retu rn to service or to conduct the initial airworthiness and annual return to 

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service inspections as required. 

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Instead of following these requirements, we will: 

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• p erform preventative and required maintenance on each aircraft as per the 

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owner’s manuals. 

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• i nspect our UAS before and after each flight as per our Flight Operations and 

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Procedur es Manual to ensure that the UAS is in a condition for safe flight. 

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• w ill conduct a test flight on each aircraft following any major repairs. 

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• w ill properly note all discrepancies , maintenance, and alterations in a 

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Maintenance Log. 

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Therefore this exemption would not adversely affect safety or would pro vide a level 

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of safety equal to the existing rule. More information about maintenance procedures 

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c an be found in the Operation of th e Unmanned Aircraft to Minimize Risk to the NAS, 

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People and Property section of this document. 

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14 CFR 91.7 (a) Civil aircraft airworthiness 

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This section states that “no person may operate a civil aircraft unless it is in an 

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airworthy condition.” 

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We seek relief from this rule based on the fact that KELLEN RAZZANO’s UAS will n ot 

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require an airworthiness certificate in accordance with 14 CFR part 21, Subpa rt H. 

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Based on the fact that an air worthiness certificate will not be issued, exemption 

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f rom § 91.7(a) i s not necessary. An equivalent level of safety will be achieved 

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through the guidance from our Flight Operations and Procedures Manual, pilot training, 

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and operational ris k management for each activity. 

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14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements 

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This section requires an aircraft flight manual in the aircraft. We seek relief from 

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this rule based on the small size of our UAS and the fact that our UAS carries no 

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onboard pilots or passengers. Given its size and configuration there is no room or 

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capacity in our UAS to carry such an item. This regu lation is therefore inapplicable. 

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An equivalent level of compliance will be achieved by keeping our ver sions of these 

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documents at the ground control p oint where the PIC will have immediate access to 

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th em, and be able to provide them upon request. 

### 323Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 8 of 14 324

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**PUBLIC BENEFIT: HOW OUR REQUEST WOULD BENEFIT THE PUBLIC AS A WHOLE** 

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Granting KELLEN RAZZANO the ability to operate small UAS safely a nd legally in the 

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National Airspace System will have the following positive economic and societa l 

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impacts on local communities, businesses, organizations and community members: 

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• benefit local business marketing by offering state

- of

- the

- a rt aerial 

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photograph y and videography 

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• help to inspect buildings and structures, and map landscapes in a safe, cost



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effective manner 

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• provide economic stimulus and public benefit by provid ing an effective means 

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by which companies or individuals looking to relocate to an area ca n use up



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to

- date, high

- quality photos and videos of real estate properties to learn 

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abou t properties, neighborhoods and communities 

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• help communities realize economic benefit by encouraging public participation 

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and encouraging tourism by showcasing communit y buildings an d landscapes and 

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by documenting commun ity events in low

- cost ways not previously available to 

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them 

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• increase awareness/knowledge of the amenities of a local area by the general 

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publ ic and by visiting tourists 

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• provide non

- profit organizations a s well as schools and univer sities and local 

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municipalities ways to showcase facilities, document events, and educate the 

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public 

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• aid in search and rescue operations and accident investigators. 

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All of the above services: 

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• a re otherwise unavailable to the public, given the UAS’s the ability to: 

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▪ safely capture images from 0 to 400 feet. 

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▪ create images that are more up

- to

- date and more closely defined than Google 

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Earth

- type satellite images. 

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▪ create images at prices lower than that of traditional helicopter and 

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airplane photography and videography. 

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• i ncrease safety of and reduce risk to the public and the NAS by: 

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▪ replacing large manned helicopter and airplane flights with small UAS 

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flights, thereby reducing air and noise pollution as well as the dangers 

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inherent in flying aircraft loaded with crewmembers and combustible fuel 

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close to people and property. 

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▪ offering safer ways to inspect tall structures and remote locations, e.g. 

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removing the physical risk of climbing on a roof or structure to inspect it. 

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• r educe envi ronmental pollution and reliance on fossil fuels by re placing 

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fueled aircraft flights with battery

- operated UAS flights. 

### 368Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 9 of 14 369

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Operation of the Unmanned Aircraft to Minim ize Risk to the NAS, People and Property 

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Concerning our commercial UAS flight operations, we take seriously o ur obligation to 

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clearly define operational borders, and implement operational risk management 

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procedures to ensure the public safety of persons and property both in the air and on 

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the ground. 

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While KELLEN RAZZANO currently provides pho tography and videography services in 

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southeastern 

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New England, we may at times contract with clients throughou t the U.S. Our area of 

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intended operations include a range of population areas, from urban to rur al, with 

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some areas, especially coastal ones, exp eriencing seasonal increases and decreases in 

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activity from both people and aircraft. 

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Our operations will take into account these variations in populations a nd activities. 

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My experience in navigation, vessel operations, search and rescue, and maritime 

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enfo rcement as a veteran of the U.S. 

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Coast Guard enables me to apply operational risk management techn iques when assessing 

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situations where the safety of the general population and the NAS are concerned. 

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Meeting or exceeding COA requirements to perform commer cial ope rations in low

- risk, 

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controlled environments, our UAS will be operated: 

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• during daytime Visual Flight Rules (VFR) conditions and visual meteorological 

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conditions (VMC). 

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• within visual line of sight (VLOS) of the Pilot in Command (PIC) or the Visual 

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Observer (VO), in accordance with the statutory Section 333(b)(1) mandate. 

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• in such a manner that the PIC and VO are able to communicate verbally at all 

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times; and that the VO can assist the PIC with seeing and avoiding other air 

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traffic and o ther ground

- based obstacles/obstructions. 

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We will not operate our UAS: 

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• at altitudes exceeding 400 feet AGL 

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• in winds exceeding 25 knots. 

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• from any moving vehicle or device. 

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• at airspeeds greater than the maximum recommended by the manufacturer. 

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• less than 500 feet below or less than 2000 feet horizontally from a cloud o r 

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when visibility is less than 3 statute miles from the PIC. 

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• unless (considering wind and forecast weather conditions) ther e is enough 

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available power for the UAS to conduct the intended operati on and to operate 

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after that for at least 5 minutes or with the reserve power recommended by the 

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manufacturer if greater. 

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• near areas where general public is within 200 feet; or directly over any 

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person except authorized KELLEN RAZZANO personnel and consent i ng inspection 

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personnel, unless operations nearer to the PIC do not present an undue hazard 

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to those persons; or unless the owner/controller of any vessels, vehicles or 

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structures has g ranted permission for operating closer to those objects and 

### 414Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 10 of 14 the PIC ha s made a safety asse ssment of the risk of operating closer to those 

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objects and determined that it does not present an undue hazard. 

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• near power lines, wind turbines, or elevated lights; or within areas of 

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airspace restrictions such as the one imposed by th e National Park Service. 

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• near airports, heliports, or military bases; more specifically: 

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▪ In accordance with the statutory Section 333 mandate r egarding proximity to 

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airports, we will stay certain distances away from airports or heliports: 5 

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NM from an airp ort having an operational control tower; or 3 NM from 

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ai rport w/ a published instrument flight procedure, but not operational 

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tower; or 2 NM from an airport w/out published instrument flight procedure 

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or an operational tower; or 2 NM from a heliport with a published 

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instrument flight procedure. 

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▪ We will not operate within 5 nautical miles of an a irport reference point 

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(ARP) as denoted in the current FAA Airport/Facility Directory (A FD) or for 

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airports not denoted with an ARP, the center of the airport s ymbol as 

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denoted on the current FAA

- published aeronautical chart, unless a letter o f 

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agreement with that airport’s management is obtained or otherwise permitted 

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b y a COA issued to the exemption holder. The letter of agreement with the 

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airport ma nagement will be made available to the Administrator or any law 

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enforcement official upon request. 

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• If we intend to conduct operations in controlled airspaces w hich have existing 

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requirements to notify Flight Standards District Offices (FSDOs) prior to 

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oper ations

– such as motion picture and telev ision filming, or pipeline and 

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power line patrol

– we will contact the local FSDO and comply with their 

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procedures, such as filing a NOTAM as per their request. 

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• Our Flight Operations and Procedures Manual, will include procedures for: 

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conducting a preflight safety risk assessment to determine tha t the UAS is in 

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a condition for safe flight, i.e. completing a preflight inspection checklist 

### 442

to ens ure the UAS’s airworthiness. If the inspection reveals a condition that 

### 443

affects the safe operation of the UAS and/or the 

### 444

• Ground Control Station, the aircraft will be prohibited fro m operating until 

### 445

the necessary maintenance has been performed and the UAS is found to be in a 

### 446

condition for safe flight. 

### 447

• maintaining a Flight Log (noting UAS flight time, Control Unit operation time, 

### 448

incident reports, etc.); and making said Log available to the FAA if requested. 

### 449

• conducting initial and ongoing training of PICs and VOs, to include classroom 

### 450

training, and training, proficiency and experience

- building fl ights; all 

### 451

persons no t essential for flight operations will be considered nonparticipants, 

### 452

and th e PIC will operate the UAS with appropriate distance from 

### 453

nonparticipants in accordance with 14 CFR 91.119. 

### 454

• evaluating the operational abilities of PICs and VO s on a regular basis. 

### 455

• maintaining and repairing the aircraft to ensure that it is in a condition for 

### 456

safe operation by: 

### 457

▪ following the UAS manufacturer’s maintenance, overhaul, replacement 

### 458

inspection, and life limit requirements and safety bulletins for the 

### 459

aircraft and its components. 

### 460

▪ installing firmware updates provided by the manufacturer. 

### 461Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 11 of 14 ▪ keeping a Maintenance Log noting all maintenance, insp ection, alterations, 

### 462

and status of replacement/overhaul component parts in the aircraf t records, 

### 463

including total t ime in service, description of work, and signature of the 

### 464

authorized person returning the 

### 465

▪ UAS to service; and making said Log available to the FAA if requested. 

### 466

▪ verifying condition of flight batteri es and calibrating the Inertial 

### 467

Measurement Unit 

### 468

▪ (IMU) usi ng manufacturer software. 

### 469

▪ conducting a functional test flight on any UAS th at has undergone 

### 470

maintenance or alterations that affect the UAS operation; said functiona l 

### 471

test flight will be conducted by a PIC with a VO and so as to not pose an 

### 472

undue hazard to persons and property; and recorded in the aircraft records. 

### 473

• P rocedures that ensure that the planned operation can be completed safely, 

### 474

such as: 

### 475

▪ checking local sectional (air) charts, notam (notice to airmen), etc. prior 

### 476

to the flight. 

### 477

▪ conducting a pre

- fli ght visual survey of the area to consider 

### 478

characteristics of the area 

### 479

▪ of intended operation(s) and the associated potential hazards regarding 

### 480

proximity to populated areas. 

### 481

▪ remaining clear and giving way to all manned aviation operations a nd 

### 482

activities at a ll times. 

### 483

▪ aborting a flight and landing the UAS at the nearest and safest ground 

### 484

point in the event of safety breaches, potential danger, unpredicted 

### 485

obstacles or emergencies. 

### 486

▪ using a fresh, fully

- charged battery with each flight as a safety 

### 487

precaution, to ensure safety and maintain adequate communication betwee n 

### 488

radio control and the UAS; and not operating our UAS at or below 

### 489

manufacturer recommend minimum charge levels for operation. 

### 490

491

Also: 

### 492

• Flight operations will be performed only at the request of and with the 

### 493

authorization and permission of clients (property owner/controller) or their 

### 494

authorized representatives. 

### 495

• Caution signs will be placed at the site of aerial operatio ns to warn people 

### 496

that aircraft operations are in progress. 

### 497

• Our Client Agreeme nts will reserve us the right to decline a p hoto shoot if 

### 498

conditions of the location (e.g. proximity of power lines) may cause 

### 499

unaccep table risk; and to reschedule a photo s hoot if weather conditions such 

### 500

as precipitation or wind speed become a factor. 

### 501

• The operating documents for our UAS, and any revisions , will be accessible 

### 502

during UAS operations and made available to the Administrator or law 

### 503

enforcement official upon request. 

### 504

• We carry comprehensive general liability insurance cover age and an additional 

### 505

in surance policy specifically covering our UAS. 

### 506

507Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 12 of 14 508

509

S UMMARY FOR FEDERAL REGISTER 

### 510

KELLEN RAZZANO d.b.a. SkyLogical, Irvine, California, seeks exemption from Federal 

### 511

Avi ation Regulations pursuant to 14 C.F.R. and Section 333 of the F AA Modernization 

### 512

and Reform Act of 2012 for the purpose of commercially operating small Unmanned 

### 513

Ai rcraft Systems (UAS) safely and legally in the National Airspace System. 

### 514

515

Specifically, KELLEN RAZZANO seeks relief from the following secti ons of the curren t 

### 516

regulations: 14 CFR 21 subpart H

- Certification procedures; Airworthiness 

### 517

Certific ates; 14 CFR 45.23

- Display of Marks; 14 CFR 61.113 (a) & (b) Private Pilot 

### 518

Privileges and Limitations ; 14 CFR 91.105 Flight crewmembers at sta tions; 14 CFR 

### 519

91.109 (a) Fl ight instruction; 14 CFR 91.119 (c) Minimum safe altitudes; 14 CFR 

### 520

91.121

- Altimeter settings; 14 CFR 91.151 (a)

– Fuel Requirements for Flight in VFR 

### 521

Conditions; 14 CFR 91.203 Carrying Civil Aircraft Cer tification and Registration; 14 

### 522

CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance require d; 

### 523

Operation after maintenance, preventive maintenance, rebuilding or alteration; 14 CFR 

### 524

91.4 17 (a)&(b) Maintenance Records; 14 CFR 91.7 (a)

- Civil Aircraft Airworthiness; 

### 525

14 CFR 91.9 (b) Civil aircr aft flight manual, marking, and placard requirements. 

### 526

527

KELLEN RAZZANO intends to use small UAS to provide aerial photo graphy and videography 

### 528

services to businesses, organizations and community members. More specifically, we 

### 529

intend to: 

### 530

• enable businesse s to benefit through the use of state

- of

- the

- art visual 

### 531

marketing materials 

### 532

• help to inspect buildings and structures, and map landscapes in a safe, cost



### 533

effective manner 

### 534

• provide economic stimulus and public benefit by provid ing an effective means 

### 535

by which companies or individuals can use up

- to

- date, high

- quality p hotos and 

### 536

videos to learn about properties, neighborhoods and communities 

### 537

• help communities realize economic benefit by encouraging public participation 

### 538

and encouraging tourism; by showcasing commun ity b uildings and landscapes; and 

### 539

by documenting commun ity events in low

- cost ways not previously available to 

### 540

them 

### 541

• increase awareness/knowledge of the amenities of a local ar ea by the general 

### 542

public and by visiting tourists 

### 543

• provide non

- profit organization s as well as schools and univer sities and local 

### 544

municipalities ways to showcase facilities, document events, and educate the 

### 545

public 

### 546

• aid in search and rescue operations and accident investigators. 

### 547

548

The enhanced safety achieved using an UAS with the specific ations de scribed herein, 

### 549

and carrying no passengers or crew, rather than a manned aircraft of significantly 

### 550

greater proportions, ca rrying crew in addition to flammable fuel, should give the FAA 

### 551

good cause to fin d that such exemption is in the public int ere st. By granting this 

### 552

request for exemption, the FAA will fa cilitate the smooth integration of UAS into the 

### 553

NAS. 

### 554Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 13 of 14 555

556

557

Additional Information 

### 558

559

Design Characteristics, Aircraft Performance and Performance Limitations, and 

### 560

Conditions of UAS to be o perated : 

### 561

562

All three UAS described below: 

### 563

• utilize propellers for balance, control and stability 

### 564

• are equipped with GPS to maintain geospatial orientation and position 

### 565

• use Return Home safety technology and Auto Landing feature if UAS loses 

### 566

transmitter signal 

### 567

• are controlled primarily through FCC approved RF spectrum 

### 568

tr ansmitter/controller/receivers; and FCC approved RF spectrum EIRP with 

### 569

transmitting pow er of 100 mW for dedicated wifi tra nsmitter/receiver between 

### 570

UAS, Range Extender att ached to transmitter and mobile viewing device 

### 571

displaying operational telemetry and video/photography functions. 

### 572

• send real time video and telemetry information is trans mitted back to a ground 

### 573

control station, allowing PIC to monitor battery level, GPS signal str ength, 

### 574

altitude (AGL), distance f rom PIC, cam era imagery, and control camera angle. 

### 575

• have failsafe modes of operation for either loss of RC or GPS sig nal. Altitude 

### 576

can be limited by the onboard flight controller and maximum altitude can be 

### 577

preprogrammed by the PIC. 

### 578

• have audible and visual sequential low battery warnings . The onboard flight 

### 579

controller will warn the p ilot via telemetry and external lighting cues before 

### 580

reaching a low battery state. An automatic termination of flight when the 

### 581

battery rea ches a predetermined low state. 

### 582

583

584

UAS01

– TBS Discovery (multirotor ) 

### 585

• Gross weight of less than 55 pounds including electronics, camera s and 

### 586

batter ies. 

### 587

• Cruising speed of 15 knots, with a maximum speed of 30 knots and maximum 

### 588

altitude of 800m 

### 589

• Maximum flight time of 30 minutes 

### 590

• FCC compliant Radio Frequency (RF) spectrum 2400 .0MHz

- 2483.5MHz band 

### 591

• manual available at http://www.team

- blacksheep.com/tbs

- discovery

- manual.pdf 

### 592

593

594

595

UAS02

– Lumenier QAV250 (multirotor) 

### 596

• Gross weight of less than 55 pounds including electronics, cameras and 

### 597

batteries. 

### 598

• Cruising speed of 15 knots, with a maximum speed of 3 0 knots and maximum 

### 599

altitude of 8 00m 

### 600

• Maximum flight time of 30 minutes 

### 601Petition for Exemption/Rulemaking

- KELLEN RAZZANO



### Page 14 of 14 • FCC compliant Radio Frequency (RF) spectrum 2400.0MHz

- 2483.5MHz 

### 602

• manual available at http://www.lumenier.com/products/mult irotors/qav250 

### 603

604

605

UAS03

– Zeta Science Phantom FX

- 61 (fixed wing) 

### 606

• Gross weight of less than 55 pounds including electronics, cameras and 

### 607

batteries. 

### 608

• Cruising speed of 1 5 knots with maximum speed of 45 knots and maximum altitude 

### 609

of 1600 m 

### 610

• Maximum flight time of 60 minutes 

### 611

• FCC compliant Radio Frequency (RF) spectrum 2400.0MHz

- 2483.5MHz 

### 612

• manual available at http://www.newzeta.com/download/fx61_manual.pdf 

### 613

614

615

616

617

618

619

END DOCUMENT 

### 620

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### 621