October 8, 2015 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Ave., SE 

Room W-12-140, West Building Ground Floor 

Washington, DC 20590-0001 

VIA PRIORITY MAIL 

RE: Exemption Request under Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations from certain parts of the Federal Aviation 

Regulations. 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of2012 (the 

"Reform Act") and 14 C.F.R Part 11, KY3 Inc. ("Petitioner"), a company that owns 

and operates broadcast television station KYTV-DT, associated other broadcast 

facilities in its region, and broadcast production services facilities, hereby applies 

for an exemption from certain Federal Aviation Regulations ("FARs") to allow for 

commercial operation of a small Unmanned Aircraft System ("UAS') under the 

conditions, terms, and limitations set forth in this Petition. 

Petitioner is licensed by the Federal Communications Commission ("FCC") to 

provide broadcast television service in Missouri and northern Arkansas, has its 

main studios in Springfield, MO and wishes to better fulfill its obligation to serve the 

public with news, programming, and information though the use of a small UAS for 

aerial photography to be used for production of commercials, informational and 

promotional videos, and news gathering. 

Please consider this Petition pursuant to the FAA's "summary grant process" as 

announced by the FAA in April of 2015. Approval of this exemption would thereby 

enhance safety and fulfill the FAA Administrator's responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the National Airspace 

System "NAS")." (Section 333(c) of the Reform Act.) 

. ) 
Applicant: 

KY3, Inc. 

Attn: Brian McDonough, President and General Manager 

999 W. Sunshine 

Springfield, Mo. 65807 

Phone: (417) 268-3010 

Email: bmcdonough@ky3.com 

F ARs from which the exemption is requested 

Petitioner seeks relief from the following FARs: 

14 C.F.R. §§ 61.23(a) and (c), 

61.101(e)(4) and (5), 

61.113(a), 

61.315(a), 

91.7(a), 

91.119(c), 

91.121, 

91.151(a)(1) 

91.405(a), 

91.407(a)(1), 

91.409(a)(1) and (2), 

91.417(a) and (b), 

A level of safety at least equal to that provided by the each rule can be maintained 

after such exemption, as explained below. 

Background and the Federal Aviation Act 

This Petition is submitted to fulfill Congress' goal under Section 333(a) through (c) 

of the Reform Act, which directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Administrator must determine which types of UASs 

, do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

, • The UAS's size, weight, speed, and operational capability; 

~ ~ • Operation of the UAS in close proximity to airports and populated areas; -----y· 

, , .. and 

• Operation of the UAS within visual line of sight of the operator. 

,(Reform Act§ 333 (b)(l)). '· 

If the Ad~inistrator determines that such vehicles "may operate safely 

\ 

2 
in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system. (Reform Act §333(c).) 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions 

from its regulatory requirements for civil aircraft, a term defined under §40101 of 

the Act, which includes UAS. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or 

any sections 44 702-44 716 of the Federal Aviation Act if Administrator finds the 

exemption in the public interest. 

Intended Use 

Petitioner is licensed to operate television station KYTV-DT, an NBC Television 

Network affiliate, and other related broadcast facilities serving the Springfield, MO, 

television Designated Market Area (DMA). Petitioner also owns television station 

K15CZ, a CW Network affiliate. And Petitioner further has a joint sales/shared 

services agreement to operate television station KSPR-DT, an ABC Television 

Network affiliate. In its course of business, Petitioner produces video productions 

that include television commercials, promotional messages, community service and 

public service announcements, including those for charitable organizations, as well 

as news and weather broadcasts including information about local 

news/weather f sports events, businesses, community development, and 

governmental activities. Petitioner wishes to best serve the public, its clients, and 

charitable organizations with video information and services that most effectively 

"tell the story," and a UAS may enhance the ability to show and document 

commercial and news information that is not as effectively shown in other views. 

Petitioner has a DJI Phantom 1 with video and still camera image gathering 

capability, which employees have operated on a recreational and hobby basis. 

Petitioner now wishes to use it for commercial purposes under the terms of this 

Petition, per terms and limitations that may be set forth in an FAA grant of 

exemption, and under the "blanket CO A'' (pursuant to FAA information released 

March 24, 2015), or such other COA as Petitioner may later seek. 

Extent of Relief, Reasons Such Relief is Requested, and Equivalent Level of 

Safety 

CFR § 61.23(a) and (c) Medical Certificates 

Sections 61.23(a) and (c) address the requirement of medical certificates for pilots. 

Section 61.23(c) permits the holder of a sport pilot certificate to act as PIC of a lightsport aircraft (landplane maximum takeoff weight 1,320 pounds, seating no more 

than two people) with either a medical certificate or U.S. issued driver's license. The 

Petitioner's UAS weighs about three pounds, and carries no people. Petitioner 

requests exemption from 61.23(a) upon a finding that an equivalent level of safety 

will be provided by allowing UAS operation by pilots with valid U.S. state-issued 

3 
driver's license or an FAA-issued medical certificate. Petitioner also requests relief 

from 61.23(c) to allow sport pilot certificate holders to operate aircraft other than 

LSA with a U.S. issued driver's license. 

CFR §§ 61.101(.e)(4) and (5). 61.113{il). and 61.315(a): Pilot Privileges 

Sections 61.101 (e)(4) and (5) and 61.113(a) limit recreational or private pilots to 

noncommercial operations. Section 61.315(a) addresses the privileges and 

limitations of the holder of a sport pilot certificate. Unlike a conventional aircraft 

that carries a pilot, passengers, and cargo, Petitioner's UAS is remotely operated 

with no pilot, passengers or property of others on board. The aircraft employs 

many automated features, such as GPS location hover, autonomous return to launch 

point, low-battery auto-land, and lost-control-link auto-land. Additionally, safety 

will be further assured in that Petitioner assures any UAS operator will have 

appropriate training and currency, in order to safely operate the UAS in a manner 

consistent with how the UAS will be operated under this Petition, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. Given its size, speed, operational capabilities, and 

lack of combustible fuel, and the UAS pilot training of the Petitioner, the risk 

associated with this UAS operation, as compared to the risk of commercial 

operations contemplated by Part 61 with conventional aircraft (fixed wing or 

rotorcraft) is minimal, allowing operations of the UAS as set forth in this Petition 

that are equivalent to, or exceed, the present level of safety provided under the FARs 

cited above and do not rise to the level of requiring a commercial pilot to operate 

the aircraft. 

14 CFR § 91.7 (a) Civil Aircraft Airworthiness 

As there will be no standard airworthiness certificate for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft, and use of manufacturer-recommended 

operational and maintenance procedures, as well and pre-flight checklists prior to 

each flight, an equivalent level of safety will be provided. 

14 C.F.R. § 91.119(£): Minimum Safe Altitudes 

Section 91. 119 establishes safe altitudes for operation of civil aircraft including 

limiting flight over other than congested areas to an altitude of 500 feet above the 

surface, except over open water or sparsely populated areas, and other than for 

takeoff or landing. Petitioner's UAS operation will be limited to a maximum height 

above the average terrain of 400 feet, and because its photography and aerial data 

collection gathering function is most functional at altitude below that, an exemption 

from Section 91.119(c) is needed. The equivalent level of safety will be achieved 

given the size, weight, speed, and material with which the UAS is built. Petitioner 

has noted that training and currency ofUAS pilots will be conducted, and operator 

will adhere to terms and limitations that the FAA may set forth in granting this 

Petition. It must be further noted that Petitioner has used manned aircraft and 

rotorcraft for aerial photography in the past, so FAA authorization for Petitioner to 

conduct photo flights with UAS may replace need for manned rotorcraft that weigh 

4 
thousands of pounds, may carry hundreds of pounds of combustible fuel, carry 

people on board, and can pose substantial risk in their operation to those on board 

or below, in the unfortunate event of an aircraft failure or mishap. Waiver of this 

rule for UAS operations thus assures an equivalent level of safety, and in fact may 

enhance safety when compared to operations of conventional aircraft or rotorcraft 

used to fulfill similar needs. 

14 CFR § 91.121 Altimeter Settings 

The regulation requires a person operating an aircraft to maintain altitude by 

reference to an altimeter set to the elevation of the departure airport or an 

appropriate altimeter setting available before departure. The UAS does not have a 

barometric altimeter, nor does it have a pilot aboard to read an altimeter, if it had 

one. The UAS does have an altitude readout on its control display, calculated 

continuously based on GPS data. An equivalent level of safety is achieved by the 

operator confirming GPS data is received properly prior to flight, confirming current 

altitude accuracy either in relation to the surface or the elevation of the launch 

location, and monitoring altitude during flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal 

cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At 

night, to fly after that for at least 45 minutes." The batteries powering the UAS 

provide approximately 15 minutes of powered flight. Without an exemption from 14 

C.F.R. § 91.151, the UAS's flights would not be possible. Given the limitations on its 

proposed operations and the location of those proposed operations, Petitioner 

believes an exemption from 14 C.F.R. § 91.151(a) is safe and within the scope of 

prior exemptions. Operating the small UAS without 30 minutes of reserve fuel does 

not engender the type of risks that Section 91.151 (a) was meant to prevent given 

the size, speed, an limited line-of-sight distance from pilot under which the UAS 

operates . The fact that it carries no pilot, passenger, or cargo also enhances its 

safety. In the unlikely event that the UAS achieves a low battery state, it would 

simply return to home and land. Given its weight and construction material, the 

risks are less than contemplated by the current regulation. Petitioner believes that 

an equivalent level of safety can be achieved by maintaining five minutes of reserve 

battery life, which would be more than adequate for aircraft return to its planned 

landing zone from anywhere in its planned operating area. 

14 CFR § 91.405 (a). 14 CFR § 91.407 (a) (1). 14 CFR § 91.409 (a) (2). 14 

CFR § 91.417 (a) and (b) Maintenance Inspections 

Section 91.405(a) requires that an aircraft operator or owner "shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter ... ". Section 91.407 similarly makes 

reference to requirements in Part 43; Section 91.409(a)(2) requires an annual 

5 
inspection for the issuance of an airworthiness certificate. Section 91.417 (a) 

requires the owner or operator to keep records showing certain maintenance work 

that has been accomplished by certificated mechanics, under Part 43, or licensed 

pilots and records of approval of the aircraft for return to service. Maintenance and 

preventive of the Petitioner's UAS will be accomplished by the owner/operator or 

proficient technicians, pursuant to the manufacturer's maintenance guidance and 

instructions. An equivalent level of safety will be achieved because the UAS is small 

in size, will carry only aerial data collection equipment, and carries no people, 

property of others, or combustible fuel, and will operate in conformance with this 

Petition and as the FAA may set forth in any grant of exemptions. The operator will 

ensure that the UAS is in working order prior to initiating flight, perform preventive 

maintenance and required maintenance, and keep a log of any maintenance that is 

performed; moreover, the operator and its personnel are the persons most familiar 

with the aircraft and are best suited to maintain the aircraft in an airworthy 

condition. An equivalent level of safety will be maintained with the grant of 

exemptions from these rules, as the FAA has done in its grants of numerous prior 

exemptions. 

Grant of Exemption Serves the Public Interest 

Petitioner operates broadcast television stations, serves the public with commercial 

messages, information in support of charitable organizations, provides information 

from local governments and organizations, and provides news, weather and sports 

information to hundreds of thousands of people within its stations' viewing areas. 

KYTV is, and has been, for quite some time, the most-viewed television station in its 

market area, reaching over 300,000 households during any given week, and is 

winner of various news and production awards in 2015, including recognitions from 

the Missouri Broadcast Association, Kansas City Press Club, and Edward R Murrow 

reporting awards. KSPR was awarded 2014 Missouri Broadcast Association "Station 

of the Year." Permitting commercial operation of the Petitioner's UAS to enhance its 

news, production and outreach functions will serve the public, governments and 

public agencies, charitable organizations, businesses and the many other types of 

organizations that rely on broadcast/cable television for messages and critical 

information. 

Grant of Exemption Would Not Adversely Affect Safety 

Petitioner has set forth above how exemptions from the regulations specified can be 

done while maintaining a level of safety equal to, or better than, that provided by the 

rules noted. 

Petitioner notes that it will operate in the safest manner possible. It has on its staff 

an FAA certificated private pilot who will be trained in the operation of the UAS so 

that person may serve as pilot-in-command of the operator's UAS. It has other 

experienced UAS pilots, who among them have years of accident-free UAS flight 

experience, operating for hobby or recreation, who will participate in training and 

6 
operations, and whom the operator will consider supporting if they choose to obtain 

FAA pilot certification .. And it has, and will further refine, checklists for safe 

operation and maintenance of the aircraft, and will maintain appropriate flight logs. 

UAS Aircraft 

Petitioner's aircraft is a Phantom 1, which has a maximum speed of about 22 mph, 

and normal weight, with battery, of under 3 pounds. Aircraft is equipped with 

optional DJI Prop Guards, used at all times, which further enhance its safety when 

operating near people. Downlinks for video information are supplied to a SOOmW 

transmitter on board the UAS that wirelessly transmits to an adjacent 

receiver /monitor mounted to the UAS radio controller. All software and firmware is 

up to date. All frequencies used by the UAS and the associated video 

transmitter /receiver comply with Federal Communications Commission 

requirements. 

Operator and its pilots rely on, for its operations and flight procedures: 

Phantom Flying Flowchart v1.0 

Phantom Advanced Manual (EN) v1.4 

Phantom Quick Start Manual (EN) v1. 7 

Naza-M Quick Start Manual v1.26 

Battery and Charger Instruction v1.0 

P330CB-H3-2D Manual v1.00 

Phantom Slide Lever Manual vl.OO 

The most up-to-date version of the manuals are available online (User Manual and 

Specifications included as appendices with this Petition): 

All current operating and training documents and relevant information from DJI are 

downloadable here: 

https:/fwww.dji.com/product/phantomjdownload 

Detailed specifications for the DJI Phantom 1 are here: 

http://www.dji.com/product/phantom/spec 

UAS is equipped with a Go Pro 3 Black edition to record HD content internally as 

well as splitting it to a SOOmW transmitter running on board the UAS that transmits 

SD to an adjacent receiver /monitor mounted on the radio controller for the UAS. All 

manuals for transmit/receive equipment are kept at flight locations. Additionally, 

DJI on its website provides numerous other safety, operational, and airspace 

informational items, which will be reviewed continually by the Operator. 

Aircraft will be registered per FAA guidelines and any requirements pursuant a 

grant of exemption, marked with the registry number on the aircraft, and pertinent 

airworthiness and registry documents will be maintained per the FAA's 

7 
interpretation letter on this subject dated August 8, 2014, or any such applicable 

guidance in a grant of exemption. 

UAS Operations Procedures and Safety Considerations 

The PIC will complete a pre-flight planning and checklist prior to flight: 

• Verify daytime operation and VFR weather conditions, wind within 

acceptable parameters. 

• Verify flight is in compliance with any local laws or limitations. 

• Cross reference area of flight with map to ensure compliance with flight 

environment requirements, including compliance with airspace limitations 

per charting, COA, or Temporary Flight Restrictions (TFR). Services such as 

FAA app B4UFly (beta released Sept. 2015, not yet operational), UAV Zones 

Drone Buddy, or Android 'Hover' will be consulted. 

• Check area of flight to ensure there are no people (except participating and 

authorized individuals) within any specified limiting distances of anticipated 

flight 

• Review flight environment with visual observer noting any obstacles or 

anticipated over-water operations. 

• Ensure remote controller, battery and any additional batteries, Range 

Extender (if used) and smartphone or tablet are fully charged. 

• Ensure propellers are mounted correctly, and check aircraft integrity. 

• Ensure gimbal clamp and camera lens cover has been removed. 

• Ensure damping absorbers are in good condition, not broken or worn. 

• Ensure anti-drop kits have been mounted correctly. 

• Calibrate compass. 

• On startup, ensure motors are functioning as normal. 

• Verify operational control link. 

• Verify GPS signal reception, and position and altitude accuracy. 

• Conduct functional check ofUAS upon first lift-off before continuing flight. 

Abort flight if any deficiency is noted. 

This preflight checklist will be modified and adjusted pursuant to any applicable 

limitations or check items that may be set forth by the FAA in the grant of this 

Petition. It may be further modified to become standardized with the flight 

operations documents created by other business units associated with this 

Petitioner, which are also expected to be applying for regulatory relief to 

commercially operate UAS under Section 333. 

Pilot and visual observer will review respective responsibilities in advance of flight, 

assuring line-of-sight with the aircraft will be maintained, and assuring that visual 

observation and flight control is maintained even as any photography /aerial data 

collection is conducted. Operator is prepared to abort flight in the event of any 

anomaly, and will keep the "auto-land" and "auto-return" features of the aircraft 

8 
active, to safely assist with any loss of control link, battery power shortfall, or other 

unanticipated issue. 

As far as flight safety, Petitioner notes that it can conduct practice and instructional 

UAS flights on sites it controls. It owns a remote broadcast transmitter site with 

over 100 acres, with, on the site, two FAA-registered towers of nearly 2,000 ft. 

height above ground. Thus, there are no low flying aircraft nearby, and the site has 

no public access through it. It is located more than eight miles from the nearest 

airport, and about 17 miles from the lateral boundary of the nearest Class C 

airspace. The site may also be used as a safe location for UAS functional flighttesting after maintenance or modification. 

The terrain of southwestern Missouri is comprised of rolling hills, lakes, and river 

valleys. and thus produces no meaningful obstacles to flight. Petitioner is aware of 

the public and private airports in the Springfield area, and while UAS flight at 200 

feet or below above the surface, per the blanket COA, is unlikely to affect flight of 

any manned aircraft, Petitioner will be sensitive to airport and airspace 

considerations, including boundaries of Class C and Class D airspace as it relates to 

SGF Airport, and provide notification to FSDO or other FAA/airport personnel 

where appropriate, and file for alternative COA, if a planned flight requires such. 

It should be further noted that, as an FCC licensee, the ownership credentials and 

business operations of this Petitioner are regularly reviewed in a licensing process 

of the Federal Communications Commission. Additionally, Petitioner's news 

operation is credentialed by various police agencies in the region. Besides the fact 

that the UAS of the Petitioner is small, can carry only a few pounds of payload, and 

has limited endurance and range, and thus itself poses no credible threat to national 

security, the fact that the operator is vetted by the FCC and by local police agencies 

further assures that this operation poses no security threat. 

The public's safety is additionally served in that any time a UAS replaces the use of a 

conventional aircraft or rotorcraft, there is no risk to people on board, and because 

of the small size and weight of the UAS, and the fact it carries no combustible fuel, 

risk to people or persons on the surface is virtually eliminated. Use of a UAS, as 

compared to conventional aircraft, reduces fuel use, and further saves time, and 

reduces emissions and noise. 

Special Consideration Requests 

Certain of the Petitioner's intents of use ofUAS can be accomplished within the 333 

Exemption grant framework currently in place. However, Petitioner respectfully 

requests that two of the conditions that are now normally included in 333 

Exemption grants be modified, in order to better meet the public interest, and the 

Petitioner's obligation to provide news and information. 

1) It is requested that the limitation (commonly item 26 of grant letters) of 

flight not closer than 500 feet to non-participating persons, vessels, vehicles, and 

9 
structures except in certain narrowly defined circumstances, be modified to permit 

operations closer than that, perhaps with no specific stated limit, particularly since 

the blanket COA limits altitude to 200 feet. It is quite limiting, notably in a news, 

weather, and information presentation role (consider for instance, tornado impact 

reporting, a common and critical subject for television stations in Missouri) for 

Petitioner to provide the expected public service and maintain 500 feet separation 

from persons, vessels, vehicles, and structures, particularly with a 200-foot COA 

altitude imitation. Petitioner's UAS is equipped with optional Prop Guards for 

further safety to people. Petitioner would at all times maintain particular attention 

to safety in takeoff and landing to maintain distance from all non-participating 

persons, but flight of a 3 pound UAS rather than a helicopter provides infinitely less 

risk to persons and property. An equivalent level of safety will be achieve without 

this limitation. 

2) It is requested that the limitation (commonly item 27 in grant letters), 

specifying flight over private property or controlled-access areas with advance 

permission, not be applied to this grant. Helicopters and fixed wing aircraft are not 

subject to advance permission requirements for flight over private property, nor are 

UAS flights for hobby or recreation. Such flight may be necessary to Petitioner's role 

in serving the public interest; in fulfilling its FCC license mandate; may be quite 

fleeting in nature; and poses virtually no risk to people or property, given the nature 

of the UAS the operator is flying, its technology-driven safety provisions, and the 

care and attention to safety that Petitioner has, and will, apply to its flight 

operations. An equivalent level of safety will be maintained without this limitation. 

Such adjustments may be made to serve the public interest, to enhance Petitioner's 

flexibility, efficiency and effectiveness of its UAS operations, will maintain an 

equivalent level of safety, and can better meet the FAA Administrator's stated 

commitment "to the safe and efficient integration of UAS into the NAS" ("Integration 

of Civil Unmanned Aircraft Systems in the National Airspace System Roadmap"), and 

Congress's objective in Sec. 332 of the Reform Act to attain "safe and routine 

operation of civil unmanned aircraft systems in the national airspace system." 

Summary and Publishing in the Federal Register 

Petitioner believes this Petition may be considered under the FAA's "summary grant 

process" where, as permitted under Section 333 of the Reform Act, the Secretary of 

Transportation may determine if certain low-risk UAS operations can be authorized, 

and can issue a summary grant when it finds it has already granted a previous 

exemption similar to the new request. Petitioner believes that this Petition fits 

directly within the aerial data collection category of Exemption requests, for which 

hundreds of Exemption grants have been issued to date. Given this, Petitioner 

believes that good cause exists for not publishing a summary of the Petition in the 

Federal Register because the requested exemption would not set a precedent, and 

any delay in acting on this Petition would be detrimental to the Petitioner. 

If Publication in the Federal Register is deemed necessary, the following is provided. 

10 
Summary That Can Be Published In The Federal Register: 

The Rules From Which KY3, Inc. Seeks Exemption: 

KY3, Inc. seeks exemption from the requirements of 14 C.F.R Sections 

61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315,(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption KY3, Inc. Seeks: 

This exemption will permit KY3 , Inc. to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Conclusion 

As set forth above, Petitioner seeks an exemption pursuant to 14 C.F.R § 11.61 and 

Section 333 of the Reform Act, which will permit safe operation of the DJI Phantom 

1 UAS commercially for the limited purpose of conducting aerial video and 

photography (aerial data collection) over certain areas of the United States. By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the Reform Act of 2012, while also advancing the interests of the public, 

by allowing Petitioner to safely, efficiently, and economically operate the DJI 

Phantom 1 UAS commercially within the National Airspace System. Petitioner 

respectfully requests that the Administrator grant this Petition for an exemption 

from the requirements the F ARs cited in the Petition to operate the DJI Phantom 1 

UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States. 

Thank you for your consideration of this Petition. 

Sincerely, 

Brian McDonough, President and General Manager 

KY3, Inc. 

999 W. Sunshine 

Springfield, Mo. 65807 

Phone: ( 417) 268-3010 

Email: bmcdonough@ky3.com 

11 
Serving as an agent and consultant in the preparation of this Petition: 

Berl Brechner 

NewsDrones ® 

540 N. State Road 

Briarcliff Manor, NY 10510 

914-941-7146 

Appendices: 

Phantom Advanced Manual (EN) v1.4 

DJI Phantom 1 technical specifications 

12 
Appendices 

Submitted with Petition of KY3 Inc. 

October 8, 2015 

Phantom I Advanced Manual (EN) v1.4 

DJI Phantom 1 technical specifications 
M Index INDEX ......................................................................................................................... 2 

Al SOFTWARE AND DRIVER INSTALLATION .................................................................. 3 

al A2 CONFIGURATION AND FIRMWARE& SOFTWARE UPGRADE ..................................... 3 

A3 LINKING THE TRANSMITTER AND RECEIVER ............................................................ 4 

A4 CHANGING THE CONTROL MODE OF THE TRANSMITTER ......................................... 5 

AS TRANSMITTER CAUBRATION .................................................................................. 7 

A6 MOUNT CAMERA AND CAMERA FRAME ................................................................. 8 

A71NTELLIGENT ORIENTATION CONTROL (IOC) FLIGHT (WITH GPS & COMPASS MODULE) 

................................................................................................................................... 9 

AB MAINTENANCE ..................................................................................................... 11 

1 I ©20 J 3 DJI Innovations. All Rights Reserved 21 
Installation 

of 2.0 version (or above 2.0) to carry out firmware upgrade 

ZA-M assistant software bellow 2.0 version. 

le!J and NAZA-M assistant software from the PHANTOM 

ons.com/products/phantomldownloadsl). 

 USB cable, power on the PHANTOM system. 

instructions strictly to finish installation. 

low the instructions strictly to finish installation. 

ware& Software Upgrade 

omputer is connected to the Internet for the first time you 

r on the aircraft. Connect the aircraft to the PC with the 

 until configuration or upgrade is finished. 

ation->Step3" section of NAZA-M Quick Start Guide to 

istant Software Upgrade' section of NAZA-M Quick Start 

e usage. 

"Manual' from the drop down list of Basic->RC->Control 

er to the 'Flying Test-> Step 1 Control Mode Knowledge" 

et the detail about the Manual Mode. 

3 I 

A3 Linking the Transmitter and Receiver 

The linking of the transmitter to the receiver of the PHANTOM was carried out before they left the factory. If 

necessary you can link the transmitter to the receiver as follows, for example you replace the transmitter. The 

default receiver type is PPM. 

DO NOT use the PHANTOM transmitter (receiver) with the third party remote control equipment. 

1. Please remove the housing by referring to the section of A8 Maintenance -> Remove the 

Housing. 

2. Locate the receiver module according to the following figure. 

3. After powering on the aircraft and the transmitter, if the LED indicator of the receiver on the control 

board is lit solid red, this means the receiver currently has no connection with any transmitter. 

4. Press down the link button for more than two seconds until the LED indicator blinks, then release the 

button. 

5. Push the throttle stick to the lowest position and tum on the transmitter. Then if the LED indicator of 

the receiver turns off, the link between the transmitter and the receiver has succeeded. (Linking 

operation can be done only when the LED indicator of the transmitter changes to blinking red .) 

Note: 

• If the transmitter can' enter the linking mode, please check that the throttle stick lies in the lowest 

position. 

• You can use your RIC system normally only after the linking is done successfully . 

---- ··- ---···-- ------

Receiver Module----i 

Link Button---• 

©2013 DJI Innovations. All Rights Reserved, 41 
ode of the Transmitter 

er according to the following procedures if necessary.( The 

 below. ) 

ion, if the Control Mode of the Transmitter is changed. 

hrottle, it cannot hold the central position when released . 

oll, it can return to the central position when released. 

itch, it can return to the central position when released. 

aw, it can return to the central position when released. 

hrottle, it cannot hold the central position when released . 

Roll, it can return to the central position when released . 

Pitch, it can return to the central position when released. 

Yaw, it can return to the central position when released. 

e Ratchet Nut. Assemble the Ratchet Nut to the Nut Hole 

e Ratchet Nut and the Screw Hole Location. Adjust the 

 the tension, so as to give you the required operating feel. 

ing Spring. Assemble them to the corresponding position 

of the transmitter). Then adjust the height of the Adjusting 

ng feel. (Note: Be careful not to excessively tension the 

ge.) 

N2 ) and Channel 3 (AIN3). (Note: Take care about the 

Mode2 

.Ndf 

2 

Screw Hole Location 

Centering Unit 

3 Adjusting Screw 

4 Ratchet Nut 

5 Throttle Ratchet 

6 3rd Channel 

7 2nd Channel 

8 Centering Spring 

9 Nut Hole Loc tion 

5 I 

The following figure shows the successful change of transmitter mode to Mode 1. 

f, 

©20 l3 Dll Innovations. All Rights Reserved 6\ 
 or calibration has not been carried out for a long time, 

..----Control Mode Switch 

f}GPS 

RATTI 

OATTI 

Sl 

m-------Joystick 

Throttle(Mode1) 

/Pitc,a. (Mode2) 

+;+Roll 

 the switch S 1 at the GPS position 

nd push the Pitch stick to the top position. Keep the Pitch 

an return to the central position when released. 

r, you should hear the indicator sound of "Di-Di Di" from 

tch S2 to the CL position, you should hear an indicator 

case, the transmitter has entered the calibration mode. 

e Pitch stick must be kept at the top position all the time.) 

e stick to the central position. Toggle the switch 51 to the 

r sound of "Di" from the transmitter. Then move all of the 

veral times. After this, put the Throttle stick to the bottom 

L position, you should hear an indicator sound of "Di" from 

 has been calibrated successfully. 

7 I 

A 6 Mount Camera and Camera Frame 

Please mount the Camera and camera Frame if necessary. 

( 1 ) Mount the Camera to the Camera Frame 

lif 

= 

( 2 ) Mount the Camera and Camera Frame to the aircraft 

Make sure to use the dedicated cross screws of the type M3.0*6, since an over long screw will puncture the 

battery by passing through the battery compartment and could lead to explosion or fire. 

©2013 DTI Innovations. All Rights Reserved 8 I 
ntrol (IOC) Flight (with GPS & compass module) 

AZA-M assistant software before using. 

ll fly along this direction when you push the elevator stick. 

 Homepoint • •• • Over 1Om from Home point 

e same as the nose direction. By using IOC, wherever the 

 with nose direction: 

same as a recorded nose direction. See the following 

er is corresponding to pitch and roll operations): 

ame as the direction from home point to aircraft. See the 

 transmitter is corresponding to pitch and roll operations): 

In home lock / point 

Recording 

ard Direction of Course Lock Flying and the home point of 

wo ways to record the forward direction and the home point: 

one record method. 

the 

and 

s to 

as 

you 

30s. 

When 6 or more GPS satellites are found, you can 

toggle the S2 switch between CL and HL position 

quickly 3 to 5 times to record the current position 

of the quad-rotor as the new home point. (CL -> 

HL -> CL is one time.) 

91 

IOC Flying Test 

Realize an IOC flight by the following procedures. 

STE\:l3: OFF $,.64: "ON agatri.: 

, ' ''· ' ' ' ' - --' - '' ' - . . 

Course 

Lock 

Switch 

Setting 

Record forward 

direction 

Set switch S1 to GPS or 

Arn position, S2 to CL 

position 

Set • switch S2 Toggle switch • S2 from 

to OFF position OFF to CL position 

Home Lock ' ••• • 'w., Switch 

Setting 

Record 

home point 

••• 

position and S2 to HL 

position 

., .... ' . ... 

Set switch S2 ! Toggle switch S2 from 

to OFF position ! OFF to HL position 

IOC FLYING NOTES ! ! ! 

• LED will blink equickly if recording is successful. LED will blink between • and e slowly to indicate 

the IOC mode only when MC is ready to fly in course lock or home lock modes. 

• Home lock flying requires that 6 or more GPS satellites are found and the aircraft is further than 1Om 

away from the home point . 

• Before you do the home lock flight, you have to fly the aircraft out of the 1Om range around home 

point, and then flip the switch S2 to HL position to fly in home lock when all the requirements are 

met. If you have already toggled the switch S2 to HL position when the aircraft is still in 1Om range 

around home point, and this is the first time you are going to fly in home lock during the current 

flight, then if all the requirements are met, MC will change into home lock automatically when the 

aircraft flies out of the 1Om range around home point. 

• • 

• • 

When flying in Home Lock mode, if any of the following situations happen, then the system will quit 

Home Lock flying and automatically enter Course Lock flying. The aircraft will fly in Course Lock 

using the earlier forward direction. 

1. The aircraft fly's within 10m range of the home point. 

2. You toggle the control mode switch to the A TTl. Mode. 

3. The GPS signal becomes bad (The GPS signal LED is blinking Red twice or three times). 

When the aircraft is flying in home lock mode far away from you and the home point, please do not 

toggle the IOC switch many times quickly so as to avoid the change of home point without you 

intentionally knowing. 

We suggest that you should know clearly which flight lock method you are going to fly, and you know 

the locked forward direction or home point, before you switch on IOC mode during the flight. 

Continuously spinning the aircraft in flight will cause a yaw error. In this case, you can stop or slow 

down the spinning, so as to have better flight performance. 

©2013 Dn InnovaTions. All Rights Reserved 10 I 
he assistant wrench. 

e below using a Phillips Screwdriver and a Hexagon 

, for example, screws. Make sure to keep them safe and 

read locker may corrode the shell of Phantom, may cause 

••• 

... ·® 

111 

2. Extension Power 

There is an extension power cable in the Phantom for DIY use. The voltage from the Extension Power Cable is 

the same voltage as the power battery. The red cable is for positive and the grey cable is for negative. Make 

sure to keep the red cable and the grey cable separated, to avoid short circuit. 

©2013 DJI Innovations. All Rights Reserved. 12 I 
--------------------

OJI Phantom 1 Specifications, from OJI 

(Source: https://www.dji.com/product/phantom/spec) 

Size and Weight 

Basic Parameters Operating Temperature -1 0°C ~ 50°C 

Power Consumption 3.12W 

Take-offWeight <1200g 

Hovering Accuracy (GPS Mode) Vertical: 0.8m 

Horizontal: 2.5m 

Max Yaw Angular Velocity 200°/s 

Max Tilt Angle 45° 

Max Ascent I Descent Speed 6m/s 

Max Flight Velocity 1 Om/s 

Diagonal distance (motor center to motor center) 350mm 

Phantom Prop Guard Weight(Single):l8.7g 

Size(Single): Angle(155.0°) Radius(112.32mm) 

Whole Size with Four Prop Guards: 575.5mm 

ESC Sound Introduction Ready /1234567 

Throttle stick is not at bottom BBBBBB ... 

Input signal abnormal B-B B ... 

Input voltage abnormal BB-BB-BB-BB ... 

Charger & Battery Parameters Charger AC Input 100-240V 

Charge Current 1A/2A/3A 

Current Drain for Balancing 200mA 

Power20W 

Battery Type LiPo 

________________ ......... 
TX Parameters Working Frequency 2.4GHz ISM 

Control Channels 7 Channels 

Communication Distance 1 OOOm 

Receiver Sensitivity (1 %PER) > -1 OOdBm 

Power Consumption of TX < 20dBm 

Working Current Nottage 52 mA@6V 

AA Battery 4 Required