Petition for Exemption/Rulemaking - KELLEN RAZZANO

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1 August 30, 2015

2

3

4

5 Attn:

6 U.S. Department of Transportation, Docket Operations

7 West Building Ground Floor, Room W12-140

8 1200 New Jersey Avenue, SE

9 Washington, DC 20590

10

11

12

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

14 of 2012

15

16

17 Kellen Razzano

18 SkyLogical

19 15642 Sand Canyon Ave.

20 PO BOX 54341

21 Irvine, CA 92619-4341

22 (949) 667-3617

23 kellen@skylogical.org

24

25

26

27

28 SUMMARY

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

30 seeks exemption from the requirements from Federal Aviation Regulations pursuant to 

31 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of 2012.

32

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

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

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

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

37 security. The grant of such an exemption is consistent with Congress’ intent, 

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

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

40

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

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

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

44 RAZZANO’s UAS meet the Section 331 definition of “small unmanned aircraft.”

45

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

47 national airspace system as it is in the public’s interest to do so. We would like 
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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48 to operate our small UAS(s) prior to the time period by which the Reform Act requires 

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

50 and valuable information for formal regulation.

51

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

53 services to businesses, organizations and community members. See the Public Benefit 

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

55

56 • Real-estate marketing collateral (residential, commercial)

57 • Automotive and Marine photography

58 • Landscape cartography and documentation

59 • Special Event and Promotional videography

60 • Research and development of safety standards

61 • Private and governmental training

62 • Enable businesses to improve marketing and outreach through the use of 

63 state-of-the-art aerial photography and videography

64 • Help to inspect buildings and structures, and map landscapes in a safe, 

65 cost-effective manner

66 • Provide economic stimulus and public benefit by providing an effective 

67 means by which companies or individuals can use up-to-date, high-quality 

68 photos and videos to learn about properties, neighborhoods and communities

69 • Help communities realize economic benefit by encouraging public 

70 participation and encouraging tourism; by showcasing community buildings 

71 and landscapes; and by documenting community events in low-cost ways not 

72 previously available to them

73 • Increase awareness/knowledge of the amenities of a local area by the 

74 general public and by visiting tourists

75 • Provide non-profit organizations as well as schools and universities and 

76 local municipalities ways to showcase facilities, document events, and 

77 educate the public

78 • Aide in search and rescue operations and accident investigators.

79

80

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

82 and has safely piloted and operated electric-powered airplanes, helicopters, multi83 rotors and other experimental aircraft since 2010. KELLEN RAZZANO additionally holds 

84 an open membership with the Academy of Model Aeronautics (AMA), conforming to safety 

85 regulations, upholding to practice guidelines, and demonstrating advanced UAS pilot

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

87 instruction and safety protocols to individuals since approximately 2011.

88

89

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

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

92 to that provided by the rule; and our request is in the public interest. Therefore,

93 KELLEN RAZZANO is seeking exemption from the following sections of the current 

94 regulations:
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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95

96 14 CFR 21 subpart H - Certification procedures; Airworthiness Certificates

97 14 CFR 45.23 - Display of Marks

98 14 CFR 61.113 (a) & (b) - Private Pilot Privileges and Limitations

99 14 CFR 91.105 - Flight crewmembers at stations

100 14 CFR 91.109 (a) - Flight instruction

101 14 CFR 91.119 (c) - Minimum safe altitudes

102 14 CFR 91.121 - Altimeter settings

103 14 CFR 91.151 (a) - Fuel Requirements for Flight in VFR Conditions

104 14 CFR 91.203 - Carrying Civil Aircraft Certification and Registration

105 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) - Maintenance 

106 required; Operation after maintenance, preventive maintenance, rebuilding or 

107 alteration

108 14 CFR 91.417 (a) & (b) - Maintenance Records

109 14 CFR 91.7 (a) - Civil Aircraft Airworthiness

110 14 CFR 91.9 (b) - Civil aircraft flight manual, marking, and placard 

111 requirements.

112

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

114 Exemption #11639, the FAA has found that the enhanced safety achieved using an UAS 

115 with the specifications described by herein, and carrying no passengers or crew, 

116 rather than a manned aircraft of significantly greater proportions, carrying crew in 

117 addition to flammable fuel, gives the FAA good cause to find that such exemption is 

118 in the public interest. Since we are applying at a time when the FAA is using a 

119 “summary grant process” be informed that while developing this request we reviewed, 

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

121

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

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

124 Rule

125

126 Part 21 Airworthiness Certification; Subpart H Certification procedures for products 

127 and parts, Airworthiness Certificates

128 This section outlines requirements for the issue of design and production approvals, 

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

130 this rule because the size, weight and enclosed operational area of our UAS, as 

131 described elsewhere in this document, permit exemption from Part 21 because our UAS 

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

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

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

135 Act. Therefore, relief from 14 CFR part 21, and any associated noise certification 

136 and testing requirements of part 36, is not necessary.

137

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

139 our Flight Operations and Procedures Manual and Training Manual (currently in 

140 development), KELLEN RAZZANO seeks to uphold the same level or exceeded level of 
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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141 safety as described in Part 21 of 14 C.F.R. Therefore this exemption will not 

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

143

144

145 14 CFR45.23 Display of Marks

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

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

148 of cabin, cockpit or pilot station, two-inch lettering is difficult to place on such 

149 small aircraft.

150

151 Instead of following this requirement, we will mark the UAS in lettering that is as 

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

153 so that the PIC, VO, or other observers will see the markings. This exemption will 

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

155 existing rule.

156

157

158 14 CFR61.113 (a) & (b) Private Pilot Privileges and Limitations

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

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

161 than and often uncorrelated with the risks associated with the commercial and private 

162 aircraft operations contemplated by Part 61 when drafted. The skills required to fly 

163 large, manned aircraft are substantially different from the skills required to 

164 remotely operate a small UAS. Also, manned aerial vehicles weighing significantly 

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

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

167

168 Requiring a private or commercial pilot certificate would provide no appreciable 

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

170 RAZZANO, most particularly in light of the FAA’s Small UAS Notice of Proposed 

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

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

173

174 Instead of following this requirement, to minimize risk and maximize safety, all UAS 

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

176 coordinated prior to operations:

177 • Prior to operations, KELLEN RAZZANO’s PIC(s) will go through a 

178 documented process of dedicated ground school and flight lessons in 

179 accordance with manufacturer and industry guides.

180 • All PIC’s will only operate the UAS as stated in this document and in 

181 our Flight Operations and

182 • Procedures Manual, flying at altitudes well below the permissible limits 

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

184 control of KELLEN RAZZANO clients.

185 • The PIC will be designated before a flight and will not transfer control 

186 at any time during a flight.
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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187 • KELLEN RAZZANO PICs will comply with upcoming FAA Operator Certification 

188 and Responsibilities once they are finalized.

189

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

191 safety equal to the existing rule. More information about pilot safety can be found 

192 in the Operation of the Unmanned

193 Aircraft to Minimize Risk to the NAS, People and Property section of this document.

194

195

196 14 CFR91.105 Flight crewmembers at stations

197 This section outlines regulations for flight crewmembers inside an aircraft. We seek 

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

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

200 regulation, the PIC of the

201 UAS and VO will be at their respective crewmember stations on the ground during 

202 takeoff and landing as well as the complete duration of the flight. By instituting 

203 this procedure this exemption will therefore not adversely affect safety or will 

204 provide a level of safety equal to the existing rule.

205

206

207 14 CFR91.109 (a) Flight Instruction

208 This section provides that no person may operate a civil aircraft (except a manned 

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

210 fully functioning dual controls. We seek relief from this rule because UAS do not 

211 have fully functioning dual controls.

212

213 Instead, flight control is accomplished through the use of a control box that 

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

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

216 aircraft and for flight instruction in experimental aircraft. This exemption will 

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

218 existing rule.

219

220

221 14 CFR91.119 (c) Minimum safe altitudes: General

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

223 relief from this rule because the services we intend to provide for the public good 

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

225

226 Instead of following this requirement, all UAS flights will be conducted with within 

227 visual line of sight and with prior permission from the owner of the property or 

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

229 operation will be notified and cleared of the area where UAS operations will be 

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

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

232 equivalent or higher level of safety of that described in this rule.
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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233

234

235 14 CFR91.121 Altimeter settings

236 This section defines regulations for altimeter settings. We seek relief from this 

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

238 Instead, electronic GPS downlinks telemetry data in real time to the PIC’s ground239 based on-screen display as to the altitude (AGL) of the UAS above the takeoff 

240 location.

241

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

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

244 on the GPS altitude indicator prior to each flight.

245

246

247 14 CFR91.151 (a) Fuel Requirements for Flight in VFR Conditions

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

249 VFR conditions unless (considering wind and forecast weather conditions) there is 

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

251 cruising speed – (1) During the day, to fly after that for at least 30 minutes; or 

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

253 rule because our UAS runs on battery instead of fuel, most of our UAS flights last 

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

255

256 Instead of following this requirement, an equivalent level of safety will be achieved 

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

258 voltage. To ensure safety and maintain adequate communication between radio control

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

260 charge; and will not begin a flight unless (considering wind and forecast weather 

261 conditions) there is enough power to fly to the intended landing point at normal 

262 cruising speed and land the UAS with no less than 30% of battery power. A landing 

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

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

265

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

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

268

269

270 14 CFR91.203 Carrying Civil Aircraft Certification and Registration

271 This regulation pertains to display of airworthiness certification within an aircraft. 

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

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

274 or cockpit entrance upon which to display certificates.

275

276 An equivalent level of safety will be achieved by keeping these documents at the 

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

278 provide them upon request.
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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279

280

281 14 CFR91.405 (a) Maintenance required; 14 CFR91.407 (a) (1) Operation after 

282 maintenance, Preventive maintenance, rebuilding, or alteration; 14 CFR91.409 (a) (2) 

283 Inspections; and 14 CFR91.417 (a) & (b) Maintenance records

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

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

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

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

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

289 return to service or to conduct the initial airworthiness and annual return to 

290 service inspections as required.

291 Instead of following these requirements, we will:

292 • perform preventative and required maintenance on each aircraft as per the 

293 owner’s manuals.

294 • inspect our UAS before and after each flight as per our Flight Operations and 

295 Procedures Manual to ensure that the UAS is in a condition for safe flight.

296 • will conduct a test flight on each aircraft following any major repairs.

297 • will properly note all discrepancies, maintenance, and alterations in a 

298 Maintenance Log.

299 Therefore this exemption would not adversely affect safety or would provide a level 

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

301 can be found in the Operation of the Unmanned Aircraft to Minimize Risk to the NAS, 

302 People and Property section of this document.

303

304

305 14 CFR91.7 (a) Civil aircraft airworthiness

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

307 airworthy condition.”

308 We seek relief from this rule based on the fact that KELLEN RAZZANO’s UAS will not 

309 require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. 

310 Based on the fact that an airworthiness certificate will not be issued, exemption 

311 from § 91.7(a) is not necessary. An equivalent level of safety will be achieved 

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

313 and operational risk management for each activity.

314

315

316 14 CFR91.9 (b) Civil aircraft flight manual, marking, and placard requirements

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

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

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

320 capacity in our UAS to carry such an item. This regulation is therefore inapplicable.

321 An equivalent level of compliance will be achieved by keeping our versions of these 

322 documents at the ground control point where the PIC will have immediate access to 

323 them, and be able to provide them upon request.
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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324

325

326

327

328

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

330

331 Granting KELLEN RAZZANO the ability to operate small UAS safely and legally in the 

332 National Airspace System will have the following positive economic and societal 

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

334 • benefit local business marketing by offering state-of-the-art aerial 

335 photography and videography

336 • help to inspect buildings and structures, and map landscapes in a safe, cost337 effective manner

338 • provide economic stimulus and public benefit by providing an effective means 

339 by which companies or individuals looking to relocate to an area can use up340 to-date, high-quality photos and videos of real estate properties to learn 

341 about properties, neighborhoods and communities

342 • help communities realize economic benefit by encouraging public participation 

343 and encouraging tourism by showcasing community buildings and landscapes and 

344 by documenting community events in low-cost ways not previously available to 

345 them

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

347 public and by visiting tourists

348 • provide non-profit organizations as well as schools and universities and local 

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

350 public

351 • aid in search and rescue operations and accident investigators.

352

353 All of the above services:

354 • are otherwise unavailable to the public, given the UAS’s the ability to:

355 ▪ safely capture images from 0 to 400 feet.

356 ▪ create images that are more up-to-date and more closely defined than Google

357 Earth-type satellite images.

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

359 airplane photography and videography.

360 • increase safety of and reduce risk to the public and the NAS by:

361 ▪ replacing large manned helicopter and airplane flights with small UAS 

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

363 inherent in flying aircraft loaded with crewmembers and combustible fuel 

364 close to people and property.

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

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

367 • reduce environmental pollution and reliance on fossil fuels by replacing 

368 fueled aircraft flights with battery-operated UAS flights.
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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369

370

371 Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property

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

373 clearly define operational borders, and implement operational risk management 

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

375 the ground.

376

377 While KELLEN RAZZANO currently provides photography and videography services in 

378 southeastern

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

380 intended operations include a range of population areas, from urban to rural, with 

381 some areas, especially coastal ones, experiencing seasonal increases and decreases in 

382 activity from both people and aircraft.

383 Our operations will take into account these variations in populations and activities. 

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

385 enforcement as a veteran of the U.S.

386 Coast Guard enables me to apply operational risk management techniques when assessing 

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

388

389 Meeting or exceeding COA requirements to perform commercial operations in low-risk, 

390 controlled environments, our UAS will be operated:

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

392 conditions (VMC).

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

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

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

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

397 traffic and other ground-based obstacles/obstructions.

398

399 We will not operate our UAS:

400 • at altitudes exceeding 400 feet AGL

401 • in winds exceeding 25 knots.

402 • from any moving vehicle or device.

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

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

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

406 • unless (considering wind and forecast weather conditions) there is enough 

407 available power for the UAS to conduct the intended operation and to operate 

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

409 manufacturer if greater.

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

411 person except authorized KELLEN RAZZANO personnel and consenting inspection 

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

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

414 structures has granted permission for operating closer to those objects and 
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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415 the PIC has made a safety assessment of the risk of operating closer to those 

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

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

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

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

420 ▪ In accordance with the statutory Section 333 mandate regarding proximity to 

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

422 NM from an airport having an operational control tower; or 3 NM from 

423 airport w/ a published instrument flight procedure, but not operational 

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

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

426 instrument flight procedure.

427 ▪ We will not operate within 5 nautical miles of an airport reference point 

428 (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

429 airports not denoted with an ARP, the center of the airport symbol as 

430 denoted on the current FAA-published aeronautical chart, unless a letter of 

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

432 by a COA issued to the exemption holder. The letter of agreement with the 

433 airport management will be made available to the Administrator or any law 

434 enforcement official upon request.

435 • If we intend to conduct operations in controlled airspaces which have existing 

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

437 operations – such as motion picture and television filming, or pipeline and 

438 power line patrol – we will contact the local FSDO and comply with their 

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

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

441 conducting a preflight safety risk assessment to determine that the UAS is in 

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

443 to ensure the UAS’s airworthiness. If the inspection reveals a condition that 

444 affects the safe operation of the UAS and/or the

445 • Ground Control Station, the aircraft will be prohibited from operating until 

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

447 condition for safe flight.

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

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

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

451 training, and training, proficiency and experience-building flights; all 

452 persons not essential for flight operations will be considered nonparticipants, 

453 and the PIC will operate the UAS with appropriate distance from 

454 nonparticipants in accordance with 14 CFR 91.119.

455 • evaluating the operational abilities of PICs and VOs on a regular basis.

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

457 safe operation by:

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

459 inspection, and life limit requirements and safety bulletins for the

460 aircraft and its components.

461 ▪ installing firmware updates provided by the manufacturer.
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462 ▪ keeping a Maintenance Log noting all maintenance, inspection, alterations, 

463 and status of replacement/overhaul component parts in the aircraft records, 

464 including total time in service, description of work, and signature of the 

465 authorized person returning the

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

467 ▪ verifying condition of flight batteries and calibrating the Inertial 

468 Measurement Unit

469 ▪ (IMU) using manufacturer software.

470 ▪ conducting a functional test flight on any UAS that has undergone 

471 maintenance or alterations that affect the UAS operation; said functional 

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

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

474 • Procedures that ensure that the planned operation can be completed safely, 

475 such as:

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

477 to the flight.

478 ▪ conducting a pre-flight visual survey of the area to consider 

479 characteristics of the area

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

481 proximity to populated areas.

482 ▪ remaining clear and giving way to all manned aviation operations and 

483 activities at all times.

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

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

486 obstacles or emergencies.

487 ▪ using a fresh, fully-charged battery with each flight as a safety 

488 precaution, to ensure safety and maintain adequate communication between 

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

490 manufacturer recommend minimum charge levels for operation.

491

492 Also:

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

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

495 authorized representatives.

496 • Caution signs will be placed at the site of aerial operations to warn people 

497 that aircraft operations are in progress.

498 • Our Client Agreements will reserve us the right to decline a photo shoot if 

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

500 unacceptable risk; and to reschedule a photo shoot if weather conditions such 

501 as precipitation or wind speed become a factor.

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

503 during UAS operations and made available to the Administrator or law 

504 enforcement official upon request.

505 • We carry comprehensive general liability insurance coverage and an additional 

506 insurance policy specifically covering our UAS.

507
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508

509

510 SUMMARY FOR FEDERAL REGISTER

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

512 Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization 

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

514 Aircraft Systems (UAS) safely and legally in the National Airspace System.

515

516 Specifically, KELLEN RAZZANO seeks relief from the following sections of the current 

517 regulations: 14 CFR 21 subpart H - Certification procedures; Airworthiness 

518 Certificates; 14 CFR 45.23 - Display of Marks; 14 CFR 61.113 (a) & (b) Private Pilot 

519 Privileges and Limitations; 14 CFR 91.105 Flight crewmembers at stations; 14 CFR 

520 91.109 (a) Flight instruction; 14 CFR 91.119 (c) Minimum safe altitudes; 14 CFR 

521 91.121 - Altimeter settings; 14 CFR 91.151 (a) – Fuel Requirements for Flight in VFR 

522 Conditions; 14 CFR 91.203 Carrying Civil Aircraft Certification and Registration; 14 

523 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required; 

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

525 91.417 (a)&(b) Maintenance Records; 14 CFR 91.7 (a) - Civil Aircraft Airworthiness; 

526 14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.

527

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

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

530 intend to:

531 • enable businesses to benefit through the use of state-of-the-art visual 

532 marketing materials

533 • help to inspect buildings and structures, and map landscapes in a safe, cost534 effective manner

535 • provide economic stimulus and public benefit by providing an effective means 

536 by which companies or individuals can use up-to-date, high-quality photos and 

537 videos to learn about properties, neighborhoods and communities

538 • help communities realize economic benefit by encouraging public participation 

539 and encouraging tourism; by showcasing community buildings and landscapes; and 

540 by documenting community events in low-cost ways not previously available to 

541 them

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

543 public and by visiting tourists

544 • provide non-profit organizations as well as schools and universities and local 

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

546 public

547 • aid in search and rescue operations and accident investigators.

548

549 The enhanced safety achieved using an UAS with the specifications described herein, 

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

551 greater proportions, carrying crew in addition to flammable fuel, should give the FAA 

552 good cause to find that such exemption is in the public interest. By granting this 

553 request for exemption, the FAA will facilitate the smooth integration of UAS into the 

554 NAS.
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555

556

557

558 Additional Information

559

560 Design Characteristics, Aircraft Performance and Performance Limitations, and

561 Conditions of UAS to be operated:

562

563 All three UAS described below:

564 • utilize propellers for balance, control and stability

565 • are equipped with GPS to maintain geospatial orientation and position

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

567 transmitter signal

568 • are controlled primarily through FCC approved RF spectrum 

569 transmitter/controller/receivers; and FCC approved RF spectrum EIRP with 

570 transmitting power of 100 mW for dedicated wifi transmitter/receiver between 

571 UAS, Range Extender attached to transmitter and mobile viewing device 

572 displaying operational telemetry and video/photography functions.

573 • send real time video and telemetry information is transmitted back to a ground 

574 control station, allowing PIC to monitor battery level, GPS signal strength, 

575 altitude (AGL), distance from PIC, camera imagery, and control camera angle.

576 • have failsafe modes of operation for either loss of RC or GPS signal. Altitude 

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

578 preprogrammed by the PIC.

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

580 controller will warn the pilot via telemetry and external lighting cues before 

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

582 battery reaches a predetermined low state. 

583

584

585 UAS01 – TBS Discovery (multirotor)

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

587 batteries.

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

589 altitude of 800m

590 • Maximum flight time of 30 minutes

591 • FCC compliant Radio Frequency (RF) spectrum 2400.0MHz-2483.5MHz band

592 • manual available at http://www.team-blacksheep.com/tbs-discovery-manual.pdf

593

594

595

596 UAS02 – Lumenier QAV250 (multirotor)

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

598 batteries.

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

600 altitude of 800m

601 • Maximum flight time of 30 minutes
Petition for Exemption/Rulemaking - KELLEN RAZZANO

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602 • FCC compliant Radio Frequency (RF) spectrum 2400.0MHz-2483.5MHz

603 • manual available at http://www.lumenier.com/products/multirotors/qav250

604

605

606 UAS03 – Zeta Science Phantom FX-61 (fixed wing)

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

608 batteries.

609 • Cruising speed of 15 knots with maximum speed of 45 knots and maximum altitude 

610 of 1600m

611 • Maximum flight time of 60 minutes

612 • FCC compliant Radio Frequency (RF) spectrum 2400.0MHz-2483.5MHz

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

614

615

616

617

618

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620 END DOCUMENT

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