September 8, 2015

Robert Michael Karman 5376 Ohio Street, V

ermilion OH 44089 Cell 508

- 868

- 0881 Email: Rkarman950@gmail.com U.S. Department of T

ransportation Docket Management Sy stem 1200 New Jersey

Av e SE Wa shington, DC 2059 RE: Exemption Reque st Section 333 of the F AA Reform Act of 2012 Manuals Used For Operations: 1) DJII nspire 1 User Manual v1.4 2) DJII nspire 1 Maintenance Manual v1.0 3) DJII nspire 1 Safet y Guidelines v1.0 4) DJIPhantom 3 Professional User Manual v1.4 5) Intelligent Flight Battery S afety Guidelines v1.4 6) Yuneec Q500 User Manual V2 References: 1) FA A Exemption No. 1 11 38, Regulatory Docket No. F

AA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU 2) FA A Exemption No. 1 11 36, Regulatory Docket No. F

AA

–2014

– 0508 in the matter of the petition of ADV

ANCED AV IA

TI ON SOLUTIONS LLC 3) FA A Exemption No. 1 1080 Regulatory Docket No. F

AA

- 2014

- 0355 in the matter of the petition of FL YI NG CAM INC Dear Sir or Madam, In accordance with the F

AA ’s Guidelines for Submitting a Petition for Exemptio n under section 333 of the F AA Modernization and Reform Act of 2012, I, Robert Michael Karman, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations: 61.1 13(a); 61.1 13(b); 91.1 19(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 s ys tems (UAS) commercially in airspace regulated b y t he Federal Av iation Administration (F AA) for the purposes of ae rial photography , cinematography

, videography

, mapping, crop surveying, inspections and other flight operations that could be performed safel y and more cost ef

fectively with the use of small UAS at low altitude within the U.S. national airspace sy stem as c ompared to a manned aircraft. 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 a ir sy stems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the F AA as required by

Section 333. The conditions identified and proposed by the petitioner are drawn from references 1

- 3. The F ARs The petitioner seeks exemption from the above mentioned F ARs for the following reasons; 61.1 13(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVAT E PILOT(or greater) certificate. An y pilots operating under this exemption would be required to comply

with an y conditions as set forth and in a similar fashion to the previously granted exemptions.91.1 19(c) As discussed in Exemption 1 11 38 (DOUGLAS TRUDEAU), operations conducted clos er

than 500 feet to the ground may require that the UA

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 conce rning the terms “congested areas” and “densel y populated”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 91.121 As discussed in Exemption 1 11 38 ( 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 1 11 36 (ADV ANCED AV IA

TI ON SOLUTIONS LLC) prior relief ha s been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 881 1, 10808, and 10673 for daytime, VFR conditi ons. The UAS provides battery power remaining in percent to the PI C. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery

power management. Those documents contain a condition in which the PI C 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 F AA found that a redu ced minimum power reserve for flight in day time VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 1 11 38 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS i s in a condition for safe flight in accordance with the operating documents. The F AA found that adherence to the petitioner ’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and rec ord keeping, were suf ficient to ensure that safet y would not be adversely

af fected. The UAS The petitioner plans on utilizing separate, but similar airframes. The DJ I In spire 1, DJ I Phantom 3 Professional, and Yuneec Q500. These airframes are a "pro

- sumer" grade small rotorcraft in the quadcopter configuration powered b y electric motors each. DJII nspire 1

– We ight 6.47lbs. Tr ansmitter Frequency 2.4

- 2.83Ghz DJIPhantom 3 Professional

– We ight 2.82lbs. T ransmitter Frequency

2.4

- 2.83Ghz Yuneec Q500

– We ight 3.75lbs. Tr ansmitter Frequency 2.4Ghz These airframes utilize an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning sy stem (GPS) to maintain its geospatial orientation and position. It is controlled primarily

through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PI C to monitor battery level, GPS signal strength, altitude ( AGL), distance from PIC, camera imagery , and control camera angle. Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is limited and pre

- programmed to not exceed 400ft AGL. Battery life limits flight times to approximately 20

- 25 minutes for each airframe. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the batt er y reaches a predetermined low state. It is anticipated that flights willusually

last less than 10 minutes. More information is available in product manuals which are Attachments 1 through 6. Risk Mitigation The petitioner has reviewed F AA exe mptions reference’ s 1

- 3 Conditions and L imitations 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 to ensure that the UA ai rworthiness 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 failure

- prone components. If inspection reveals a condition th at af fects the safe operation of the UAS, it will be grounded immediately

and prohibited from operating until maintenance is performed and the UAS is found to be airworthy

. The petitioner also is a Company Check Airman for a 121 Air Carrier, holds a Class One Medical Certificate, and participate in an active drug testing program. As such I will maintain the highest safet y standards, continue with constant hands on training in a controlled area away from the public, and utilize flight simulators. Iwill also maintain awareness of current airspace closures, Prohibited Areas and “NO DRONE ZONES”
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. Additionally , 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 de signees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be display ed through ground level videography /photography

. Aerial photograph y is a valuable marketing tool that can lea d to increased commerce and enhance personal photography

. Crop survey ingapplications could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yi elds and decreased costs. Aerial surveying and inspection s 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 utili zed. L iability 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 wil l be available to F AA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to F AA via traditional means, e.g. COA Monthly Reports, or other means as required. Conclusion The petitioner is reque sting this exemption for the purposes of “aerial photography , cinematograph y, videography

, mapping, crop surveying, inspections and other flight operations”. The petitioner's business model is based on the idea of of fering ad hoc small UAS services to indi viduals or companies who wish to employ

these services as a safe, ef fective, and legal option to enhance their business or hobby . The petitioner ’s own market research shows pent up demand for these services currently exists in the real estate market and other markets are just beginning to emerge. Adding to the level of safety and experience in these operations, the petitioner has experience in the radio control model aircraft hobby , 19 y ears experience in general and commercial aviation and holds the follo wing F

AA L icenses and Ratings: Airline T ransport Pilot Certificate (AMEL) Commercial Pilot L icense (ASEL )Certified Flight Instructor

- Single and Multi Engine Land, Instrument Airplane

Company Check Airman

– ExpressJet Airlines 121 Carrier Thank y ou in advance for y our time and consideration. Kind Regards, Robert Michael Karman

INSPIRE 1

**We ight**  2935g (Battery I ncluded) **Ta keoff**  **We ight**  3400g **Hovering Accuracy**  **(GPS mode)** Ve rtical : 0.5m ; Horizontal : 2.5m **Max Angular** 

**V elocity**  Pitch : 300°/s ; Yaw : 150°/s **Max Tilt Angle**  35° **Max Ascent/Descent Speed**  5/4 m/s **Max Speed** 22m/s ( AT TImo de , no wind ) **Max Flight Altitude**  4500m **Max Wind Speed Resistance** 10m/s **Operating Te**  **mperature Range**
- 10°~40°C **Max Flight Time** Approximately 18 minutes **Indoor Hovering**  Enabled b y default

 Advanced Read y - to
- Fl y Design  Intelligent Power  Management S ys te m  Full

- Featured App  Dedicated Controls  A Complete Read y - To

- Fly Sy stem

## Remote Contr **oller**

 Operating Frequency 922.7 ~ 927.7 MHz (Japan Only) 5.725 ~ 5.825 GHz 2.400 ~ 2.483 GHz

 Tr ansmitting Distance (outdoor and unobstructed: 2 km EI RP 10dBm@900M 13dBm@5.8G 20dBm@2.4G

 Output Power:9W  Battery : 6000 mAh LiPo 2S
 Max Mobile Device Width:170mm DJIPHANT OM3 PROFESSI ONAL

**Battery** 6000 mAh L iPo 2S **Phantom 3 Pr ofessional**  **We ight**  1280g (with battery & propellers) **Hover A**  **ccuracy (Ready to Fly)** Ve rtical: +/

- 0.1 m (when Vi sion Positioning is active) or +/

- 0.5 m Horizontal:1.5m **Max Ascent / Descent Speed**  Ascent: 5m/s Descent: 3m/s **Max Flight Speed** 16m/s((A TTI mode, no wind) **Diagonal Length** 590mm **Contr ollable Range of Gimbal**  Pitch

- 90°to +30°
 Operating Frequency : 2.400 GHz

- 2.483 GHz  Max Distance: 2000m (outdoors and unobstructed)  Receiver Sensitivity (1%PER):

- 101 dBm ±2 dBm  Tr ansmitter Power (EIRP): FCC: 20 dBm CE: 16 dBm
 Wo rking V

oltage: 1.2 A @7.4 VYuneec Q500

**Flight Time** up to 25 m inutes **We ight with Battery and Payload**  60.0 oz (1700g) **We ight without Battery and** 

**Payload** 40.0 oz (1 130g) **Battery** 5400mAh 3S 1 1.1V L iPo (included) **Charger** 3S 1 1.1V L iPo DC Balancing Smart Charger with AC Adapter (included) **Tr ansmitter**  10

- channel 2.4GH z with 5.8GHz video downlink (included) **3 Flight Modes** Smart (Follow Me and W atch Me), Angle and Home **Maximum Flying Height** Default 122m (400ft) above Ground Level (Adjustable via the Ty phoon GUI) **Maximum Rotation Rate** 65°/s **Maximum Roll Angle**  35° **Ope rating T** 

**emperature Range**

− 5°C to 80°C **Radio Contr ol Fr**  **equency Band** 2.4GHz **Max. Descent Speed** 2m/s **Max. Flight Speed** 8m/s **Tr ansmitter** 

**T ype**  ST10+ **Operating System** AndroidTM **Number of Channels**  10 **Contr ol**  **Tr ansmission**  **Range (Optimum Conditions)**  FCC Comp liance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m

(1312.34 ft) W

arning: Yo u Must Follow L ocal Laws and Maintain Vi sual Line of Sight of Aircraft at All Ti mes **Robust Radio Contr ol**  **Modulation** Yuneec Protocol **Vi deo Link Fr**  **equency Band**  5.8GHz **Vi deo**  **Tr ansmission Range**  **(Optimum Conditions)** FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) W

arning: Yo u Must Follow L ocal Laws and Maintain Vi sual Line of Sight of Aircraft at All Ti mes **Flight Systems T**

**elemetry Data On Scr**  **een Di splay**  Ye s **LED Backlit LCD Scr een**  Capacitive Multi

- touch 5.5 ′′ **Ta ctile (V** 

**ibrating) and Audible Feedback**  Ye s **Built -**  **in LiPo Battery** 3.6V/5200mAh 18.72Wh**Vo ltage / Capacity** 

**Scr een Resolution**  854 × 480px **Camera Settings** White balance, light exposure, ISO, s hutter speed, video resolution, FPS,

record video, take pictures