Alexander Young

September 21, 2015

5 Alford Lane

Frenchtown, NJ 08825

Cell (908) 894­3450

Email: youngtechphotography@gmail.com

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA­2014­0481 in the

matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the

matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA­2014­0355 in the

matter of the petition of FLYING CAM INC

To Whom It May Concern,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under

section 333 of the FAA Modernization and Reform Act of 2012, Youngtech Photography,

referred to hereafter as the petitioner, request exemption from the following sections of Title 14,

Code of Federal Regulations §§

61.113(a);

61.113(b);

91.119(c);

91.121;

91.151(a);

91.405(a);

91.407(a)(1);

91.409 (a)(1);

91.409(a)(2);

91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight operations

that could be performed safely and more cost effectively with the use of small UAS at low

altitude within the U.S. national airspace system as compared to a manned aircraft. UAS

operations will be performed only at the request of and with the authorization and permission of

clients or their authorized agents in order to facilitate commerce and raise awareness of the
beneficial uses of small unmanned air systems. These operations will be conducted within and

under the conditions outlined herein or as may be established by the FAA as required by

Section 333. The conditions identified and proposed by the petitioner are drawn from references

1­3.

The Federal Aviation Regulations

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of pilots, who hold a

PRIVATE PILOT (or greater) certificate. Any pilots, operating under this exemption would be

required to comply with any conditions as set forth and in a similar fashion to the previously

granted exemptions.

91.119(c)​As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted

closer than 500 feet to the ground may require that the UAS be operated closer than 500 feet to

essential persons, or objects that would not be possible without additional relief. The petitioner

requests modification, waiver or exemption and clarification concerning the terms “congested

areas” and “densely populated”. The petitioner requests waiver for this condition to allow for

reasonable and responsible operations in areas of subdivisions and neighborhoods if required.

91.121 ​As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS

does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for

altitude information.

91.151(a)​As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior

relief has been granted for manned aircraft to operate at less than the prescribed minimums,

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS­specific relief has

been granted for Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The

UAS provides battery power remaining in percent to the PIC. The UA batteries provide a

maximum of 25 minutes of powered flight. Endurance time of the aircraft is estimated at 19

minutes, under ideal cruising conditions. Information provided in the operating documents

discusses procedures regarding remaining battery power management. Those documents

contain a condition in which the PIC will initiate a landing procedure when battery remaining

reaches a specified level. Given the limitations on proposed operations and the location of those

proposed operations, The FAA found that a reduced minimum power reserve for flight in

daytime VFR conditions was reasonable.

91.405(a);

91.407(a)(1);

91.409 (a)(1) & (2);

91.417(a) & (b)
As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to

inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and the

conditions and limitations specified, describing the requirements for maintenance, inspection,

and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

Unmanned Aerial System (UAS) Description & Specification

The DJI Phantom 3 Advanced is a consumer grade small rotorcraft in the quadcopter

configuration and is designed primarily to carry aloft a high definition camera. It has an

advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less

than 1200 feet per minute (6 m/s). It is powered by four electric motors with a total width of less

than 600mm. It utilizes an internal inertial measuring unit (IMU) with integrated barometric

sensor augmented with global positioning system (GPS) to maintain its geospatial orientation

and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time

video information is transmitted back to a ground control station allowing the operator and/or

PIC camera imagery and control camera angle. It has failsafe modes of operation for either loss

of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum

altitude can be preprogrammed by the PIC. Battery life safety protocol limits flight times to

approximately 19 minutes or less. The onboard flight controller will warn the pilot via external

lighting and audio cues before reaching a low battery state. An automatic termination of flight

and landing will be initiated when the battery reaches a predetermined low state. It is anticipated

that flights will usually last less than 20 minutes. More information is available at this link, and in

the manual (attachment 1) http://www.dji.com/product/phantom­3/spec

Safety Protocol & Risk Mitigation

The petitioner has reviewed FAA exemptions reference’s 13 Conditions and Limitations

section and believes that the procedures specified therein are reasonable and will be utilized in

order to manage and mitigate risk and ensure public safety. A preflight checklist will be

developed and employed to ensure that the UA airworthiness will be verified before launch.

Airworthiness will be maintained by performance of routine inspections before each flight,

maintaining flight and maintenance logs to record time on failure­prone components. The UAS

will also be regularly updated to the latest manufacturer’s firmware. The petitioner request that

in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided

that;

“The UA may not operate in Class B, C, or D airspace without written approval from the

FAA. The UA may not operate within 5 nautical miles of the geographic center of a

non­towered airport as denoted on a current FAA­published aeronautical chart unless a

letter of agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA. The letter of

agreement with the airport management must be made available to the Administrator

upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is

requesting a mechanism to facilitate such activities without requesting a new and separate
exemption(s) should the need arise. Operations within class B airspace are not requested due

to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircraft of

greater proportions, carrying a crew and flammable fuel. The use of the UAS in order to facilitate

commerce could lead to economic growth. Operations for this petition will enable service for

property owners or their designees seeking an enhanced perspective for characteristics,

amenities, and benefits of their desired photographic subjects that cannot be displayed through

ground level videography/photography. Aerial photography is a valuable marketing tool that can

lead to increased commerce and enhance personal photography. Crop surveying applications

could lead to decreased use of pesticides and fertilizer and conservation of water as well as

increased crop yields and decreased costs. Aerial surveying and inspections can increase work

site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide

clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent

contractor. A visual observer will be utilized. Liability insurance will be obtained commensurate

with the granting of this request for exemption. Flight data including UA flight time, Control Unit

operation time, incident, accident, and details concerning any deviations from normal operations

will be available to FAA for use in collecting data regarding the use of UAS as part of this

application. This data may be submitted to FAA via traditional means, e.g. COA Monthly

Reports, or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight

operations”. The reason for such a general and broad based request is that the petitioner

wishes to utilize a business strategy of horizontal integration and maximize economies of scope

in order to capitalize on opportunities as they may arise in the future without the long turnaround

time associated with additional exemptions The petitioner's business model is based on the idea

of offering ad hoc small UAS services to individuals or companies who wish to employ these

services as a safe, effective, and legal option to enhance their business or hobby. Market

research shows pent up demand for these services currently exists in the real estate market and

other markets are just beginning to emerge. Videography and photography are included in the

request as the primary usage of the UAS will be for aerial real estate imagery. The petitioner

has identified universities and other agencies that could benefit from the operation requested in

this application.The primary purpose of seeking this exemption is to obtain the capability to offer

services while remaining in compliance. The petitioner has 12 years of experience in the radio

control model aircraft hobby.

Respectfully submitted,

Alexander Young