# righthg/f

Mr. James Williams Manager, Flight Standards Service UnmannedAircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 U.S. Department ofTransportation, Docket Operation West Building Ground Floor, Roomw12-140 1200 NewJersey Avenue, SEWashington, DC 20590 

### PETITIONER Right HalfMedia llC Dennis E. Sawan, Esq., CEO 416 North Erie Street Suite 200 Toledo, Ohio 43604 9/9/2015



### RE: REQUEST FOREXEMPTION FROM MULTIPLE REGULATORY PROVISIONS OF TITLE 14 C.F.R 333
DearMr. Williams; Right HalfMedia LLC (hereinafter RHM) respectfully requests an exemption from several provisions ofTide 14 ofthe Code ofFederal Regulations (C.P.R.) to permit the use ofsmall unmanned aerial systems (sUAS) to assist in the evaluation ofinfrastructure and operations, aerial videography, aerial photography and aerial surveys for our clients. 1bisrequest is motivated primarily by the desire to maximize safety in the collection ofvisual data. 1bis exemptionwould abrogate the need for piloted flights to obtain aerial visual data, andit would allow RHM to broadly evaluate client assets with sUAS, as well as to document events andreal property for the benefit of our clients in a safe and cost effective manner. Accordingly, the grant ofan exemption is consistent with Congress' intent, reflected in Section 333 ofthe FAA Modernization and Reform Act of2012 (Modernization Act),1 that safe systems bepermitted in the national airspace prior to the issuance of final regulations governing general use ofthese systems. A summary ofthis request suitable for publication in the FederalRegister is provided as Appendix A. Appendix B provides the manufacturers information regarding the design, aircraft performance, and fail-safe features. We have provided manufacturer information related to operatinglimitations, normal and emergencyprocedures, andmaintenance andinspection procedures. As we add aircraft designs, we will update this appendix appropriately.

www.righthalfmedia.com

# right

# ht!:!f

BACKGROUND INFORMATION
RHM is in the business ofaerial data collection, included butnot limited to, surveying and videography/photography for clients ofall sizes. RHM clients look to us to safely and efficiendy document their subject properties in unique ways, without the necessity ofmanned aerial equipment. sUAS systems allow RHM to safely and efficiently realize this goal.
RHM is a media/technology company that plans to exploit the capabilities ofUnmanned Aerial Systems to offer a multitude ofservices, including: Aerial surveying Remote sensing EventPhotography /Videography Agriculture purposes Real Estate Photography Aerial filmmaking and photography Construction site inspections and monitoring Wildlife and forestry monitoring Educational andresearch operations
As part ofthis, RHM is requesting FAA Exemption for sUAS operations for safety, inspection, data collection andvideo capture usage 

### REGULATORY BASIS FOR EXEMPTION REQUEST
In addition to the waiver authority providedin §333 ofthe Modernization Act, the FAA may grant an exemption under 49 U.S.C. §44701(£) ifithas determined that such an exemption is in the public interest. TheFAA has imposed a separate requirement inits proceduralregulations, providing that the petitioner shall explain why granting the exemption would not adversely affect safety orhow the exemption would provide atleast an equivalent level ofsafety as compliance with the underlying regulation.
In Grants ofExemption Nos. 11062 to Astraeus Aerial (see DocketNo. FAA-2014-0352), 11109 to Clayco, Inc. (see DocketNo. FAA-2014-:-0507), 11112 toVDOS Global, LLC (see Docket No. FAA-2014-0382), and 11213 to AeryonLabs, Inc. (see Docket No. FAA-2014-0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft ofsignificantly greater proportions, carrying crewin addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemptionis in the public interest. To this end, RHM requests an exemption for aerial data collection to operate an

www.righthalfmedia.com

# righthglf

sUAS, in an effort to enhance the safety ofthe collection ofdata from the necessity offlying with a pilot, fuel and crew. 

### THE PETITIONER REQUESTS RELIEF FROM THE FOLLOWING: Regulations from which the exemption is requested:
14 C.P.R. Part 21 14 C.P.R. 45.23 

### (b) 14 C.P.R. 61.113(a) and 

### (b) 14 C.P.R. 91.7 (a) 14 C.P.R. 91.9 

### (b) (2) 14 C.P.R. 91.109 14 C.P.R. 91.119 14 C.P.R. 91.121 Page 3 14 C.P.R. 91.151(a) 14 C.P.R. 91.203 (a) & 

### (b) 14 C.P.R. 91.205 

### (b) 14 C.P.R. 91.215 14 C.P.R. (91.401

- 91.417) 

### UNMANNEDAIRCRAFT SYSTEM
sUA Vs are widely understood to be superior to full size helicopters for data collection, due in large part to the fact that smaller devices are cheaper, exhibitreduced noise, have a much smaller environmentalimpact and can be operated in a mannerwhich enhances the public safety.
RHM is petitioning for an exemption to enable itto operate a DJI Phantom 3 Advanced equipped with a three-axis gimbals and High-Definition cameras. This sUAVhas a built- in capability to limit the height it flies above the ground, to limit the radius ofthe distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The Phantom also has the failsafe function ofthe Naza-M autopilot system which means when the communication between the Main Controller and the transmitteris disconnected, the outputs ofall command sticks from controllerwill 

### go to the centerposition. Ifthe GPS signal is adequate, the system will automatically trigger Return to Home and will land safely. 

### THEABOVE SPECIFICATIONS MEET WITH THE MODELAIRCRAFT OPERATING STANDARDS AS SET BELOW:

www.righthalfmedia.com

# righthglf

1) RHM will only operate its sUAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public." 2) When flying a sUAV within 3 miles ofan airport, airport operators will be notified and the operatorwill give the right ofway to avoid flying in the proximity offull-scale aircraft. a. Maximum flight time for each operational flight will be 30 minutes. b. Flights will be terminated at 25% batterypowerreserve should that occurpriorto the 30-minute limit. c. The sUAVwill be programmed so thatitwill notbe operated at an altitude ofno more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. d. Minimumcrew for each operation will consist ofthe sUAS Pilot, andVisual Observer e. The sUAS operated by the petitionerweighs less than 55 pounds,including the payload (i.e. camera, lens, and gimbal). f. The sUAV will operate at speeds ofno more than 50 knots, can hover, and can simultaneously move vertically and horizontally. g. Given the small size ofthe sUAS and the restricted sterile environmentwithin which they will operate, our sUAS operations adhere to the Reform Act's safety requirements. The UAS, poweredby batteries, is smaller, lighter andmore maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard andwill thereby reduce currentrisklevels and thereby enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little or no risk to national security orpublic safety.
Low level oblique photos andvideo from several angles are far more effective than ground basedimagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. The applicants have utilized large aircraft in the pastto obtain similar aerial data collection, which has proven cost prohibitive and less safe than a sUAS. The benefits ofreduced cost andimproved quality ofpresentation from the UAwill bevaluable to and benefitmany buyers and sellers ofreal property. Additionally, RHM requests thatitbe allowed to use it's sUAS system to benefit first responders nearby who mightrequire assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. 1) All operations must occurin FAA Class G airspace at no more than 400ft. AGL, at an airspeed ofno more than 25 knots and no further than 3/4NM from the PIC;

www.righthalfmedia.com

# right

# htJ:lf

2) All operations mustutilize a visual observer (VO). The VO and PIC must be able to communicate byvoice at all times during a flight operation; 3) Operations will be restricted to flights overprivate propertywith the permission ofthe property owner; 4) All required permits will be obtained from state and local governmentprior to operation; 5) RHM will not be operate over densely populated areas 6) RHM will notbe operatingover any open-air assembly ofpeople; 

### 7) RHM will notbe operatingover heavily trafficked roads; 8) RHM will notbe operatingwithin 5 NM ofan airport orheliport;
RHM respectfully request exemption under Section 333 to enable Right HalfMedia LLC to safely operate efficient, limited, low-risk commercial sUAV operations for the activities stated herein, while respecting the space andprivacy ofcitizens.

www.righthalfmedia.com

# righthglf

Appendix A Summary for Federal Register Publication
Pursuant to 14 C.F.R. Part 11, the following summaryis provided for publication in the Federal Register should the FAA determine that publication is needed. Petitioner: Right HalfMedia

### ILC (RHM)
Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417) Description ofReliefSought:
Petitioner seeks relieffrom the requirements of333 Aircraft Exemption Status, 14C.F.R. Part 21, 45.23 (b), 61.113(a) and (b), 14 C.F.R. 91.7 (a), 14 C.F.R. 91.9 (b)(2), 91.109, 91.119. 91.121, 91.151(a), 91.203 (a) & (b), 91.205 (b), 91.215 and 91.401-91.417 and to conduct sUAS operations primarily over RHM Client's owned or controlled land to conduct aerial data collection, including but not limited to aerial surveys, photography andvideography. In general, sUAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature of operations anticipated by RHM requires that the sUAS be flown atrelatively low altitudes. RHM expects thatin most instances, the sUAS will be flown less than 75 feet from the highest structure along the path ofthe sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk ofinterference with other aircraft is minimal.

www.righthalfmedia.com

### AppendixB Specific type(s), make, and model
DJI Phantom 3 Advanced

'7] (1] GPS [2] Propeller [3) Motor [4] Front LED Indicator [5] Landing gear [6] Gimbal and Camera [7] Camera Status Indicator [8] Aircraft Micro-USB 

### Port [9] Aircraft Status Indicator [10} Intelligent Flight Battery 

### f11] Vision Positioning Sensors [12] Antennas {13] Camera Micro-SO Card Slot [14] Camera Micro-USB Port [15] Link Button

www.righthalfmedia.com