August 8th, 2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New JerseyAvenue, SE Washington, DC 20590 :**-~** i.-'

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Re: Exemption Request under Section 333 ofthe FAA ReformActand Part 11ofthe FederalAviation Regulations from certain parts ofthe FARs. Dear Siror Madame, Pursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 (the ReformAct) and 14 C.F.R. Part 11, Justin Richardson, photographer, hereby applies for an exemption from the listed FederalAviation Regulations ("FARs") to allow him to operate a small UnmannedAircraft System ("UAS") underthe conditions and limitations setforth in this Petition. The proposed exemptions, ifgranted, would allow Petitionerto operate small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 pounds or less forthe purpose ofaerial filming of motion pictures, musicvideos, web videos, corporate videos, television programs and commercials, and still photography. The requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would provide safety enhancements to the already safe photography operations presently using manned helicopters and airplanes in LosAngeles County. Approval ofthis exemption would thereby enhance safety and fulfill the FAAAdministrator's responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act." The name and address ofthe applicant is: Justin Richardson29224 Bernardo Way Valencia Ca.

Regulations from which the exemption is requested: 14 CFR Part21 14 C.F.R. §45 .23(b) 14CFR§61.3 14C.F.R. § 91.7 (a) 14CFR § 91.9 (b) (2) 14C.F.R. §91.103 14C.F.R. §91.109 14 C.F. 

### R. §91.119 14 C.F.R. § 91.121 '

.. • '**~** • • •. , • • • • > :.._ • • ••**~** •,• r' v14 CFR 

### § 91.151 (a) 14 CFR§91.203(a)&(b) 14 CFR 

### § 91.205(b) 14 CFR 

### § 91.215 14 CFR 

### § 91.405 (a) 14 CFR 

### § 407 (a) (1) 14 CFR 

### § 409 (a) (2) 14CFR 

### § 417 (a) & (b) TheAppendix describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption. The Petition is submitted to fulfill Congress' goal underSection 333(a) through (c) ofthe Reform Act, which directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe ReformAct. In making this determination, theAdministrator must determine which types of UASs do notcreate a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following:
• The UAS's size, weight, speed, and operational capability;
• Operation ofthe UAS in close proximity to airports and populated areas; and
• Operation ofthe UAS within visual line ofsight ofthe operator

Reform Act§ 333 (a). IftheAdministrator determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ld. § 333(c) (emphasis added). The Secretary has delegated his aviation authority to theAdministrator ofthe FAA. The FederalAviation Act expressly grants the FAAthe authority to grant exemptionsfrom its regulatory requirements for civil aircraft, a term defined under §40101 oftheAct, which includes sUASs.The Administrator may grantan exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthe Federal Aviation Act ifAdministrator finds the exemption in the public interest. 49 U.S.C. § 44701 (f) See also 49 USC § 44711 (a); 49 USC § 44704; 14 CFR §91.203 (a) (1). The petitioner has overfifteen years ofexperience as a digital photographer, both as a profession and hobby, and has been a helicopterand airplane RC enthusiastwithout incidentfor overtwelve years. The wide availability ofsmall UnmannedAircraft Systems, also known as "micro drones, drones, or quadcopter" capable ofcarrying

### High-quality video cameras and priced at affordable levels attracted the petitioner. His entire involvement with photograp,hy has involved exploring new technologies and adapting them to capture better quality imagery. Petitioner currently has practiced flying various UAS models under 50 pounds, under 35 miles per hour, under400 feet, for total ofsixty hours over remote areas ofthe LosAngeles metropolitan area, over remote locations in Antelope Valley, and in the rural areas of LosAngeles County, and in Central California for recreational purposes, exploring the potential and the limitations of its video subsystem. He is pleased with the quality ofthe still and video imagery captured and overall safe maneuverability and controlled operation ofthe various UASs he's flown. Currently, a number of people, some professional colleagues and potential future clients, have been made aware of Petitioner's accomplishments and have seen the results and are requesting Petitioner to undertake additional "micro drones, drones, orquadcopter" photography for compensation

. He has been advised that this is not now permitted unless he obtains special permission from the FAA. Many competitors of Petitioner are actively flying UAS's to conduct aerial photography for commercial purposes, notwithstanding the FAA's stated prohibition. He also notes and has read the congressional mandate in sections 332 and 333 ofthe FAA Revitalization and Reform Act of2012 that the FAA move quickly to accommodate the economic and societal benefits that can result from widespread deployment of UAS technology. Accordingly, Petitionerapplies forauthorization underthe Federal Aviation Act, and the FARs rules to undertake the following activities for commercial purposes. Unless the Petition is granted, Petitionerwill be at a significant competitive dis-advantage if he, as he prefers, complies with FAA policy. Vehicle 

### The Petitionerwill fly various small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 pounds or less, at a speed no greaterthan 50 knots. This vehicle has built in capability to limit the height it flies above the ground, to limit the**radiu~** 

### ofthe distance it flies from the operator, and to exclude it from class B, C, and D airspace. The vehicle also has the built-in capability to return to the launching point ifthe wireless control link is interrupted or ifthe operator attempts to exceed any of the height, radius, or airspace limitations programmed into it. The vehicle weighs aboutfive pounds empty and has a maximum gross weight ofapproximately twenty pounds. It has a top speed ofabout 30 knots, carry neither a pilot nor passenger, carry no explosive materials orflammable liquids, and operate exclusively within a predetermined area. It has four fixed pitch rotors, thrustfrom which is varied by chang**in~ R~M.**  

### It is powered by a lithium polymer battery. Flight Profile 

### The petitionerwill notfly UAS above 400 feet above ground level, or morethan 1500feet away from him. Hewill carefully preflight check the vehicle before each mission to assurethat its navigation system are properly calibrated and that any included return-to-home features, altitude, and radius limitationswork. He will operate the vehicle for aerial photography missions only in the early morning hours and other times when few people are 

### oUt in the public.·He will operate itorily over largely unpopulated areas where the potential of uncontrolled descentto cause injury or damage is lowest.He will not operate it in controlled airspace whatsoever, without express written consent from the FAA. In the unlikely event that a manned aircraft flies below 400 feetAGL where the petitioners operating his Phantom, he will keep both the vehicle and manned aircraft in sight and avoid the manned aircraft. More particularly, the Petitioner will fly UASs only overthe following types of areas in Metropolitan Los Angeles:
• Over Lakes and various waterways of LosAngeles and the state of California, outward ofthe shoreline
• Overopen water in marinas, anchorages, and rivers amongst and surrounding the city of LosAngeles
• Over lines ofrailroad and rail classification yards
• Over metropolitan LosAngeles parks
• Over nonresidential and noncommercial large-scale industrial areas

• Over private propertywhen he has been commissioned by the person in legal possession ofthe property to do so.
• Over public or private events petitioner is hired as photographer.

The Petitioner's proposed operations satisfythe criteria provided in Section 

### 333 ofthe Reform Act relating to size, weight, speed operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security. The Petition justifies grant ofthe requested exemptions allowthe Petitionerto obtain aerial photographywith his drone. Respectfully submitted, Justin Richardson



### . 14 CFR § 45 .23(b)



### 14 CFR Part

### 21

14 OFR § 

### 61.3

14 CFR § 

### 91.7 (a) 

### APPENDIX Requirementto display
-- registration number onvehicleAircraft certification requirements and procedures Requirementfor pilot certificate

Airworthiness requirement ··- ·Insufficient space on vehicle
Designed for manned aircraft; not suitable for off-the-shelf sUAS Part

### 61 requirements designed for manned aircraft, not sUAS; petition describestraining for sUAS operator Designed for manned aircraft; not suitable for off-the-shelf sUAS14CFR § 91.9 (b) (2) Requirementfor manual to be No one aboard to read manual available in the cockpit 14 CFR § 91.103(b) Requirementfor crew Unmanned vehicle membersto be onboard 14 CFR § 91.109 Requirementfordual No one aboard to operate controls during flight controls 14 CFR § 91.119 Minimum altitudes forsafe Safety requires operation flight below these altitudes 14CFR § 91.121 Altimeter settings No one aboa rd to read altimeter 14 CFR § 91.203 (a) 

### &(b) Requirement for registration No one aboard to read and airworthiness certificates certificates to be onboard 14 CFR § 91.205(b) Cockpit instruments No one aboard to read 14 CFR § 91.215 [Transponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 14 CFR § 91.405 (a) Inspection requirE)ments I Designed for manned aircraft; not suitable foroffthe-shelf 14 CFR § 91.407(a) (1) Inspection approval Designed for manned requirements aircraft; not suitable foroffthe-shelf 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for offthe-shelf 14 CFR § 91.417 (a) 

### &(b) Maintenance records Designed for manned requirements aircraft; not suitable for offthe-shelf