William H Rudiger 1 Wilson Rd#14577 Annapolis, MD 21412

U.S. Department ofTransportation Docket Operations, M-30 1200 NewJersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 ofthe FAA Reform Act of2012

References: January 26,2016

1) FAAExemptionNo. 11410, Regulatory Docket No. FAA-2015-0186 in the matter ofthe petition ofRALPH J. APEL 2) FAA ExemptionNo. 11341, Regulatory DocketNo. FAA-2015-0037 inthe matter ofthe petition ofBOB SOKOLER 3) FAAExemptionNo. 11728 Regulatory DocketNo. FAA-2015-0850 inthe matter ofthe petition ofALON SICHERMAN 4) FAA ExemptionNo. 11728 Regulatory Docket No. FAA-2015-2773 inthe matter ofthe petition ofMANUEL HEREDIA III

Dear Sir orMadam,


### In accordance withthe FAA's Guidelines for Submitting a Petition for Exemption under section 333 ofthe FAA Modernization and Reform Act of2012, I William Hampton Rudiger, referred to hereafter as the petitioner, request exemption from the following sections ofTitle 14, Code ofFederal Regulations§§


### 61.113 

### (a) 

### & (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l), 91.409(a)(1) & 

### (2), and 91.417(a) & 

### (b);
In orderto operate small unmanned aircraft systems (UAS) commercially in airspace regulated bythe Federal Aviation Administration (FAA) for the purposes ofaerial photography, cinematography, videography, mapping, crop surveying, inspections and other flight operations that could be performed safely and more cost effectively with the use ofsmall UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations

### ------------------------~-~will beperformed only at the request ofand with the authorization andpermission ofclients or their authorized agents in orderto facilitate commerce and raise awareness ofthe beneficial uses ofsmall unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as maybe established bythe FAA as required by Section 333.

The petitioner seeks exemption from the above-mentioned FARs for the following
reasons; 61.113(a) 

### & (b): The petitionerrequests reliefin orderto facilitate the utilization of pilots, who hold a Sportpilot (or greater) certificate. The petitioner holds and maintains a Private Pilot's license. 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. 91.7(a): Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extentrequired to allowpetitionerto determine that the DJI Phantom 3 Advanced UAS is in airworthy conditionpriorto every flight byensuring thatthe UAS is incompliance withthe operating documents (i.e., the Monthly Maintenance Log and Phantom 3 Advanced Instruction Manual). Additionally a thorough visual andphysical inspection will be performed to asses the general condition ofthe UAS before each flight. Petitioner seeks the requested reliefbecause the Phantom 3 Advanced UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, petitioner will ensure thatthe DJI Phantom 3 Advanced UAS is in airworthy conditionbased upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Advanced Manual) priorto every flight, and further, determine that the aircraft is in condition for a safe flight. 91.119(c): The petitionerrequests waiver to allowreasonable and responsible operations in areas ofsubdivisions and neighborhoods ifrequired.

91.121: This 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)(1): The UAS provides battery powerremaining inpercent to the PIC. The UA p_11tteries prov.idepowerfor approximately 23 miJ:mtes offlightfo:LDJI Phantom 3 Advanced

... Informationprovided inthe operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in whichthe PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location ofthose proposed operations, The FAA found that a reduced minimumpowerreserve for flight in daytime VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) 

### & (2); 91.417(a) & (b): Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a)(2), and 91.417(a) 

### & (b) only apply to aircraft with an airworthiness certificate, the petitioner requests relieffrom these Sections becausethe DJI Phantom 3 Advanced UAS does not require an airworthiness certificate. The DJI Phantom 3 Advanced UAS meets the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, the petitionerwill use trained technicians to perform maintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques,

### and practices prescribed inthe UAS operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3Advanced Instruction Manual). Furthermore, the petitioner will document and maintain all maintenance records for the Dn Phantom 3 Advanced UAS.

TheUAS


### The DJI Phantom 3 Advanced UAS is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight ofless than 46 Ounces (1280g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed ofless than 30 knots (16m/s) and a maximum climb rate ofless than 1200 feet per minute (5 m/s). It is powered by four electric motors with a distance between motors oflessthan 14 inches (350mm) 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 and telemetry information is transmitted backto a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It

### has failsafe modes ofoperation for either loss ofRC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight time to approximately 23 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination offlight and landing will be initiated when the battery reaches a predetermined low state. It

### is anticipated that flights will usually last less than 10 minutes. More information is available on http://www.dji.com/product/phantom-3-adv

Public interest


### Use ofthe UAS in lieu ofa 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 ofthe UAS in order to facilitate commerce couldlead to economic growth. Operations for

### this petitionwill 

### enable service for property owners ortheir designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheir 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 ofpesticides and fertilizer and conservation ofwater 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 'forhire' basis acting as an independent contractor. A visual observer will be utilized. Liability insurance will be obtained corruuensurate with the granting ofthis 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 ofUAS as part ofthis application. This datamay be submittedto FAA viatraditional 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 ofhorizontal integration and maximize economies ofscope in orderto capitalize

# on opportunities as they 111ay arise inthe future withoutthe long turnaroundtime**~­** associated with additional exemptions. The petitioner's business model is based onthe ideaof offering adhoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal optionto enhance their business orhobby. The petitioner's discussions with realtors and otherUAS operators shows thatthere is significant demand for these services.