Thomas Michael Haley

725 Kapiolani Blvd. c­311

Honolulu , Hawaii 96813

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: 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

4) FAA Exemption No. 11062 Regulatory Docket No. FAA­2014­0352 ​in the matter of the petition of ASTRAEUS AERIAL

5) Inspire 1 Pro User Manuals ­ http://www.dji.com/product/inspire­1­pro­and­raw/info#downloads

6) ShotoverU1 information ­ http://www.shotover.com/u1

7) DJI Phantom 3 Professional manuals ­ http://www.dji.com/product/phantom­3/download

8) Alta Freefly ­ http://freeflysystems.com/alta

9) G3D Robotics Solo ­ https://3dr.com/wp­content/uploads/2016/01/v8_01_05_16.pdf

Attachment

1) Motion Picture and Television Operations Manual for Thomas Michael Haley

Dear Sir or Madam,

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, Thomas Michael Haley 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 (b)&(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 data collection, closed set cinematography, 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. 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. So long as such operations are 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 1­4.
The FARs

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 SPORT

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(b) & (c) As discussed in Reference 1, Exemption 11138 (DOUGLAS TRUDEAU), operations

conducted closer 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 concerning the terms “congested areas” and “densely populated”. The petitioner requests

waiver for this condition to allow reasonable and responsible operations in developed areas as required. As

discussed in reference 4 Exemption 11062 (ASTRAEUS AERIAL) The petitioner additionally request exemption to

conduct “Closed set​” cinematography for the purpose of scripted, filming for the motion picture and television

industry. Petitioner proposes operations in a “sterile environment” of closed­set motion­picture filming. In this

controlled environment, their operations will remain within visual line of sight (VLOS) and below 400​feet AGL.

Petitioner has attached a copy of a proposed Motion picture and television operations manual (Attachment 1)

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 UAS specific relief has been granted in 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 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 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.
The UAS

The DJI Inspire 1 Pro/Raw, ShotoverU1, Alta Freefly, DJI Phantom 3 professional and 3D Robotics Solo are

highly successful ‘prosumer’ and professional grade small rotorcraft in the multi­rotor configuration. All are designed

primarily to carry aloft a high definition digital camera. All utilize an internal inertial measurement (IMU) with integrated

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

position. They are 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 PIC to monitor battery level,

GPS signal strength, altitude (GPS and BARO), distance from PIC, camera imagery, and control camera angle. All

have 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 limits flight times (See below for

aircraft specifics). 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 battery reaches a

predetermined low state.. More information is available in the referneces and further below.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1­4 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 and motion picture and television operations manual 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

failure prone components. 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 non towered airport as denoted on a current FAA

published 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.

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 designees seeking an enhanced perspective for

characteristics, amenities of their desired photographic subjects that cannot be displayed through ground level

videography/photography. Aerial photography/cinematography is a valuable tool that can lead to increased

commerce and enhance productivity. The petitioner will provide clients with photographic data for these purposes on

a ‘for hire’ basis. 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 data collection and closed set

cinematography. 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. The primary

purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance.

The petitioner is an individual with numerous years of experience in general aviation and holds an airman certificate,

PRIVATE PILOT, as well as current FAA medical certificate.

Respectfully submitted,

Thomas Michael Haley
The sUAS

DJI Inspire 1 Pro/Raw
Model T600

Weight 2870 g (Battery and propellers included, Zenmuse X5

excluded)

3400 g (Battery, propellers and Zenmuse X5 included)

Max Takeoff Weight 3500 g

Hovering Accuracy (P Mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°
Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 18 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 4,500 m (Default altitude limit: 120 m above takeoff point)

Max Wind Speed Resistance 10 m/s

Max Flight Time Approxi. 15 minutes

Motor Model DJI 3510H

Propeller Model DJI 1345T

Indoor Hovering Enabled by default
Operating Temperature 14° to 104° F (­10° to 40° C)

Diagonal Distance 559 mm
DJI Phantom 3 professional
Aircraft Weight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

● Vertical: +/­ 0.1 m (when Vision Positioning is active) or +/­ 0.5 m

● Horizontal: +/­ 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level

6000 m (Software altitude limit: 120 m above takeoff point)

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS
Vision Positioning Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

50 cm­300 cm

Operating Range

50 cm­300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote Controller Operating Frequency

2.400 GHz­2.483 GHz

Max Distance

Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant

Battery

6000 mAh LiPo 2S
Receiver Sensitivity (1%PER)

­101 dBm ±2 dBm

Transmitter Power (EIRP)

FCC: 20 dBm

Working Voltage

1.2 A @7.4 V

Battery Charger Voltage

17.4 V

Rated Power

100 W

Intelligent Flight Battery Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh
Net Weight

365 g

Max Flight Time

Approximately 23 minutes

Operating Temperature

­10°C to 40°C

Max Charging Power

100 W
Alta Freefly

DIMENSIONS

UNFOLDED

Diameter 1126 mm

Height (to base of TITH) 220 mm

FOLDED

Diameter 550 mm

Height (to base of TITH) 220 mm
PROPELLERS

Material Carbon fiber with balsa core

Propeller Orientation (3) CW and (3) CCW Props

Propeller Type 18 x 6 Folding

BATTERY

Nominal Battery Voltage 6S / 22.2V

Maximum Battery Size 240 x 180 x 80 mm

Maximum Battery Quantity 2 Battery Packs (Parallel)

Battery Connectors 2x EC5 (Parallel)

WEIGHTS

Maximum Gross for Takeoff​1 13.6 kg (30.0 lbs)

Maximum Useful Load​2 9.1 kg (20.0 lbs)

Maximum Payload​3 6.8 kg (15.0 lbs)

Typical Standard Empty Weight 4.5 kg (10.0 lbs)
FLIGHT CONTROLLER

Model Name Freefly Synapse Flight Controller

Flight Modes Manual

Height Hold

Position Mode

Return­To­Home

Auto­land

Supported Inputs DSMX, DSM2, S.Bus, S.Bus 2, PPM, FPV

SD Video

Supported Radios Futaba S.Bus & S.Bus 2

DSMX, DSM2 (Spektrum/JR)

PPM, PPM Invert, PPM Graupner

Supported Radio Controller

Telemetry Systems

Futaba w/ built­in voltage sense port

LIGHTING AND INDICATION

Orientation Lights 3 Watt RGB LEDs

Orientation Light Locations Outboard on Boom Ends

Orientation Light Color Red, Yellow, Blue, Green, White
Shotover U1

Shotover U1

WEIGHT Empty ­ 10.5kg (23lbs)

MAXIMUM WEIGHT ­ LESS THAN 55 lbs

FLIGHT TIME 9­22 Minutes

U1 SYSTEM SPECIFICATIONS POWER 12S 100 Amps Max Draw (at 44V)

ENVIRONMENTAL Operating temperature

­20 to +50 degrees °C (­4 to 122 degrees °8)

http://www.shotover.com/u1
3D Robotics Solo

Specifications Solo is a quad­rotor aerial vehicle powered by the 3DR Pixhawk 2

autopilot system and APM:Copter flight control software. Solo communicates

with the controller and Solo app over the 3DR Link secure Wi­Fi connection.

Autopilot: 3DR Pixhawk 2

Flight code: ArduPilot Copter Control: 3DR

Solo Controller Wireless communication: 3DR Link 1.0 Frequency: 2.4 GHz

Height: 10 in. (25 cm)

Motor­to­motor dimension: 18 in. (26 cm)

Propulsion: 880 KV motors, two clockwise rotating motors and two

counterclockwise rotating motors

Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm)

Weight with battery: 3.3 lbs. (1.5 kg) Controller

battery life: 3 hours

Extended controller battery life: 6 hours

Controller battery: Li­ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery)

Power: Electric (rechargeable lithium polymer battery)

Battery: Lithium polymer, 5200 mAh, 14.8 Vdc

Battery weight: 1 lb. (.5 kg)

Estimated flight time: 25 minutes*

Maximum altitude: 328 ft. (100 m)

Range: .5 miles** (.8 km)
Payload capacity: 1.1 lbs. (500 g)

Cruise speed: 5.7 mph (2.5 m/s)

Maximum speed: 55 mph (25.5 m/s)

Maximum climb rate: 11 mph (5.0 m/s)

Maximum descent rate: 5.5 mph (2.5 m/s)

Headwind limitation: 25 mph (11 m/s)

Crosswind limitation: 25 mph (11 m/s)

Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4 Full

compatibility with GoPro® HERO 4 Solo app compatibility: iOS 8.0 or later /

Android 4.3 or later

Operating temperature: 32° F ­ 113° F (0° C ­ 45° C)

Operating relative humidity: 0­85% RH

*Flight time varies with payload, wind conditions, elevation, temperature,

humidity, flying style, and pilot skill. Listed flight time applies to elevations less

than 2,000 ft above sea level.

**Range varies with location, antenna orientation, background noise and

multi­path.