righthg/f 

Mr. James Williams Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE Washington, DC 20590 

PETITIONER 

Right Half Media llC 

Dennis E. Sawan, Esq., CEO 

416 North Erie Street Suite 200 

Toledo, Ohio 43604 

9/9/2015 

RE: REQUEST FOR EXEMPTION FROM MULTIPLE REGULATORY PROVISIONS 

OF TITLE 14 C.F.R 333 

Dear Mr. Williams; 

Right Half Media LLC (hereinafter RHM) respectfully requests an exemption from several 

provisions of Tide 14 of the Code of Federal Regulations (C.P.R.) to permit the use of small 

unmanned aerial systems (sUAS) to assist in the evaluation of infrastructure and operations, aerial 

videography, aerial photography and aerial surveys for our clients. 1bis request is motivated 

primarily by the desire to maximize safety in the collection of visual data. 1bis exemption would 

abrogate the need for piloted flights to obtain aerial visual data, and it would allow RHM to broadly 

evaluate client assets with sUAS, as well as to document events and real property for the benefit of 

our clients in a safe and cost effective manner. Accordingly, the grant of an exemption is consistent 

with Congress' intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 

(Modernization Act),1 that safe systems be permitted in the national airspace prior to the issuance of 

final regulations governing general use of these systems. 

A summary of this request suitable for publication in the Federal Register 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 

operating limitations, normal and emergency procedures, and maintenance and inspection 

procedures. As we add aircraft designs, we will update this appendix appropriately. 

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BACKGROUND INFORMATION 

RHM is in the business of aerial data collection, included but not limited to, surveying and 

videography /photography for clients of all sizes. RHM clients look to us to safely and efficiendy 

document their subject properties in unique ways, without the necessity of manned 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 of Unmanned 

Aerial Systems to offer a multitude of services, including: 

Aerial surveying 

Remote sensing 

Event Photography /Videography 

Agriculture purposes 

Real Estate Photography 

Aerial filmmaking and photography 

Construction site inspections and monitoring 

Wildlife and forestry monitoring 

Educational and research operations 

As part of this, RHM is requesting FAA Exemption for sUAS operations for safety, 

inspection, data collection and video capture usage 

REGULATORY BASIS FOR EXEMPTION REQUEST 

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may 

grant an exemption under 49 U.S.C. §44701(£) if it has determined that such an exemption is in the 

public interest. The FAA has imposed a separate requirement in its procedural regulations, providing 

that the petitioner shall explain why granting the exemption would not adversely affect safety or how 

the exemption would provide at least an equivalent level of safety as compliance with the underlying 

regulation. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. F AA-2014-0352), 

11109 to Clayco, Inc. (see Docket No. FAA-2014-:-0507), 11112 to VDOS Global, LLC (see 

Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, 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 of significantly greater proportions, carrying crew in addition to flammable 

fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the 

public interest. To this end, RHM requests an exemption for aerial data collection to operate an 

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sUAS, in an effort to enhance the safety of the collection of data from the necessity of flying 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) 

UNMANNED AIRCRAFT SYSTEM 

sUA V s 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, exhibit reduced noise, have a much smaller 

environmental impact and can be operated in a manner which enhances the public safety. 

RHM is petitioning for an exemption to enable it to operate a DJI Phantom 3 Advanced 

equipped with a three-axis gimbals and High-Definition cameras. This sUAV has a built- in 

capability to limit the height it flies above the ground, to limit the radius of the 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 of the Naza-M autopilot system which means when the 

communication between the Main Controller and the transmitter is disconnected, the outputs of all 

command sticks from controller will go to the center position. If the GPS signal is adequate, the 

system will automatically trigger Return to Home and will land safely. 

THE ABOVE SPECIFICATIONS MEET WITH THE MODEL AIRCRAFT 

OPERATING STANDARDS AS SET BELOW: 

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1) RHM will only operate its s UAS in line of sight of a 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 of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. 

a. Maximum flight time for each operational flight will be 30 minutes. 

b. Flights will be terminated at 25% battery power reserve should that occur prior to 

the 30-minute limit. 

c. The sUAV will be programmed so that it will not be operated at an altitude of no 

more than 400 feet AGL, and not more than 200 feet above an elevated platform 

from which filming is planned. 

d. Minimum crew for each operation will consist of the sUAS Pilot, and Visual 

Observer 

e. The sUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal). 

f. The sUAV will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

g. Given the small size of the sUAS and the restricted sterile environment within which 

they will operate, our sUAS operations adhere to the Reform Act's safety 

requirements. 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or 

serious bodily injury. With a small payload and maximum flight time of only 20 minutes, this is 

offers little or no risk to national security or public safety. 

Low level oblique photos and video from several angles are far more effective than ground 

based imagery for displaying the characteristics of large, complex properties with several buildings 

and large trees. The applicants have utilized large aircraft in the past to obtain similar aerial data 

collection, which has proven cost prohibitive and less safe than a sUAS. The benefits of reduced 

cost and improved quality of presentation from the UA will be valuable to and benefit many buyers 

and sellers of real property. 

Additionally, RHM requests that it be allowed to use it's sUAS system to benefit first 

responders nearby who might require 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 occur in FAA Class G airspace at no more than 400ft. AGL, at an 

airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; 

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2) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 

3) Operations will be restricted to flights over private property with the permission of the 

property owner; 

4) All required permits will be obtained from state and local government prior to operation; 

5) RHM will not be operate over densely populated areas 

6) RHM will not be operating over any open-air assembly of people; 

7) RHM will not be operating over heavily trafficked roads; 

8) RHM will not be operating within 5 NM of an airport or heliport; 

RHM respectfully request exemption under Section 333 to enable Right Half Media LLC to 

safely operate efficient, limited, low-risk commercial sUAV operations for the activities stated 

herein, while respecting the space and privacy of citizens. 

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Appendix A 

Summary for Federal Register Publication 

Pursuant to 14 C.F .R. Part 11, the following summary is provided for publication in the Federal 

Register should the FAA determine that publication is needed. 

Petitioner: Right Half Media 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 of Relief Sought: 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.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 and videography. 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 at relatively low altitudes. RHM 

expects that in most instances, the sUAS will be flown less than 75 feet from the highest structure 

along the path of the sUAS and in no instances will be flown higher than 400 feet above the ground. 

Accordingly, the risk of interference with other aircraft is minimal. 

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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 

f 11] Vision Positioning Sensors 

[12] Antennas 

{13] Camera Micro-SO Card Slot 

[14] Camera Micro-USB Port 

[15] Link Button 

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