Roger L. Durham

1 4147 FM 105 Orange, TX 77630 ( 409 )

- 718

- 0790 sycamoreair@gmail.com Dear Sir or Madam: This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Refor m Act), and 14 C.F.R. Part 11, Roger L. Durham , a n independent videographer, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below . Granting this exemption will allow operation of our Small U nmanned Aircraft System s (sUAS’s ) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Sect ion 333. The requested exemption would permit Roger L. Durham to pursue his commercial interests in provid ing services to clients using small advanced sUAS’s in the following areas: Real Estate, Marketing, Land Management/Surveying, Industrial infrastru cture inspection and special events. Roger L. Durham states that all sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the s UAS radius during filming and photography applications. Roger L. Durham has demonstrated the ability to safely and effectively fly the sUAS which will be used for all com mercial and private purposes. Roger L. Durham complies wi th local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS. All flights will occur in ordinance with any state or local laws regarding priva cy. I, Roger L. Durham , am seeking the exemption because I am committed to complying with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have described. Without the exemption request granted, I would be unable to safely and effectively run my business, and it is my intention to comply with the FAA and obtain an exemption of the following regulations. The following contain s the list of regulations from which I am seeking exemption, and a complete list of responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit and safety features, and similar petitions requests granted.**Regulations from which exemption is requested:**

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (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

**I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES** 1. Operations authorized by this grant of exemption are limited to the attached sUAS systems when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3. The s UAS may not be o perated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the s UAS be operated at airspeeds greater than th e maximum UAS operating airspeed recommended by the aircraft manufacturer. 4. The s UAS must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The s UAS must be operated within visual line of sight (VLOS) of the P ilot I n Command (PIC) at all times. This requires the P IC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical ce rtificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The s UAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the P IC always maintains VLOS capability. The VO and PIC must be able to communicate verbally or with headset intercom or electronically at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before t he flight and cannot transfer his or herdesignation for the duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO. 7. This exemption and all documents needed to operate the s UAS and conduct its operations in ac cordance with the conditions and limitations stated in this grant of exemption, are herein after referred to as the operating documents. The operating documents must be accessible during s UAS operations and made available to the Administrator upon request. If a discrepancy exi sts between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA grante d this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any s UAS that has un dergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the s UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the s UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the s UAS, the aircraft is prohibited from operating until the necessary maintenance has be en performed and the s UAS is found to be in a condition for safe flight. 11. The operator must follow the s UAS manufacturer’s maintenance ; overhaul, replacement, inspection, and life limit requirements for each aircraft and aircraft components. 12. Each s UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CF R § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely

operate the s UAS in a manner consistent with how the s UAS will be ope rated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.5 1(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the s UAS in a manner consistent with how the s UAS will be operated under this exempt ion are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are c onsidered nonparticipants, and the PIC must operate the s UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. s UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be condu cted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The s UAS may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA i ssued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The s UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the s UAS loses communications, the s UAS must return to a pre
- determined location within the private or controlled

- access property. 19. The PIC must abort the f light in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the s UAS to conduct the intended operation and to o perate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.23. Documents used by the operator to ensure the safe operation and flight of the s UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the s UAS any time the aircraft is operating. The se documents must be made available to the Administrator or any law enforcement official upon request. 24. The s UAS must remain clear and give way to all manned aviation operations and activities at all times. 25. The s UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the s UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the s UAS, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All op erations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's s UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

**SIMILAR EXEMPTIONS** They are similar in all/or many material respects t o relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 **Public Benefit and Safety** Small Unmanned Aircraft System ( sUAS’ s ) are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety.Roger L. Durham is petitioning for an exemption to operate DJI s UAS Phantom 2, S

- 900 and S

- 1000

systems with built

- in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no

-fly zone feature. The DJI s UAS’s also ha ve a failsafe function that is triggered in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safe l y. If the connection is restored, the PIC can regain co ntrol of flight and land manually. These specifications comply with the Model Aircraft Operating Standards as set below: The petitioner will only operate its sUAS in visual line

- of

- sight of a pilot and/or observer and will operate at sites that are su fficient distance from populated areas within the sterile area described in the operations safety manual . Such operations will ensure that the sUAS will "not create a hazard to users of the national airspace system or the public." W hen flying the sUAS wi thin five ( 5 ) 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. Maximum flight time for each operation will be 30 minutes. Flights will be terminat ed when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS. The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned. Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator. The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current FAA medical certificate. The sUAS operated by the petitioner weighs less than 5 5 pounds, including all payload (i.e. camera, lens, and stabilized gimbal). The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Given the small size of the sUAS and the restricted sterile environment within which it will operate, operations adhe re to the Reform Act's safety requirements.**Operations Safety Manual**

Conduct of all s UAS operations will prioritize the safety of full scale aircraft, persons and property on the ground, and ground crew personnel. 1. I will utilize only models named in the operations manual s for UAS operations. I will operate the following s UAS aircraft: a) DJI Phantom 2, b) DJI Phantom 3 Professional, c) DJI Inspire 1, d) DJI Spreading Wings S900, e) DJI Spreading Wings S1000 Series. All s UAS’ s will weig h less than 55 pounds, including payload. 2. All operations will occur at an altitude of no more than 400 feet above ground level and at airspeeds of 5 0 knots per hour or less. 3. All s UAS’ s will be operated as directed by manufacturer guidelines, proced ures, limitations, and specifications for the particular make and model of aircraft. 4. The s UAS will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use human vision, unaided by any device other than corrective lenses or sunglasses, as specified on the PIC's FAA

- issued airman medical certificate or U.S. driver's license. 5. All s UAS operations will utilize a visual observer (VO). The UAS will be operated within VLOS of both the PIC and VO at all times. The PIC and VO must be able to communicate verbally at all times. The PIC will be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC is responsible for ensuring that the VO can perform the duties required of th e VO. 6. All operating documents, including those issued by the FAA will be accessible during s UAS operations and made available to the Administrator upon request. I will revise and update operating documents to reflect the latest manufacturer information regarding aircraft operating parameters and procedures as well as any information pertinent to the safety of flight. 7. Maintenance. Any s UAS that has undergone maintenance or alterations that affect s UAS operation or flight characteristics must undergo a functional test flight prior to conducting further operations. Functional test flights will only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test will be conducted in such a manner so as not to pos e an undue hazard to persons or property. I will follow the s UAS manufacturer's maintenance; overhaul, replacement, inspection, and life limit requirements for the air craft and aircraft components. I will comply with all manufacturer safety bulletins. 8. I am responsible for maintaining and inspecting the s UAS to ensure that it is in a condition for safe operation. Prior to each flight, the PIC will conduct a pre

-flight inspection to determine the s UAS is in a condition for safe flight. The pre

-flight insp ection will account for all potential discrepancies and will follow all available manufacturer guidelines. If the inspection reveals that the s UAS is not i n a condition for safe flight, I will not operate the aircraft until the necessary maintenance has be en performed and the s UAS is found to be in a condition for safe flight.9. The PIC will hold a private pilot certificate and a current FAA airman medical certificate, or a valid U.S.

driver's license issued by a state. 10. I will only conduct operations under visual meteorological conditions. 11. I will not conduct operations within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD), or for airports not denoted with an ARP, the center of t he airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued. The letter of agreement must be made available to the administrato r or any law enforcement official upon request. 12. I will not operate a s UAS less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 13. Emergencies. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. If the s UAS loses communications, the s UAS must return to a pre
- determined location within the private or controlled

- access property. If the s UAS suffers a flight malfunction which allows limite d control effectiveness, the PIC will immediately land the s UAS in a clear area so as not to cause any undue hazard to persons or property on the ground. 14. The PIC will not begin a flight (considering all factors to include wind and weather conditions) unless there is enough available power for the s UAS to conduct the intended operation and to operate after that for at least 3 minutes or with the reserve power recommended by the manufacturer. 15. The PIC will insure that the s UAS remains clear of and gi ves way to all manned aviation operations and activities. 16. I will conduct all s UAS flight operations at least 5 00 feet laterally and vertically from all non

participating persons, vessels, vehicles, and structures unless: a) Barriers or structures are present and sufficiently protect non

- participating persons from the s UAS and/or debris in the event of an accident. I will ensure that non

- participating persons remain under such protection. In this case the PIC will not opera te any closer than 30 feet to protected non

- participating persons. If a situation arises where non

- participating persons leave such protection and are within 5 00 feet of the s UAS, flight operations must cease immediately in manner ensuring the safety of no n participating persons; and b) The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determin ed that it does not pose an undue hazard. c) The PIC, Camera Operator (CO), VO, operator trainees, or essential persons are not considered non

participating persons.17. All s UAS operations shall be conducted over a private or controlled

- access property with permission

from the property owner/controller or other authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. s UAS operations may also be conducted in non

- pri vately owned areas (wilderness, remote areas, over water, public spaces where s UAS operations are not prohibited) if all other safety requirements outlined in this manual are met. 18. I will create a secured area or perimeter when needed, to ensure that n on - participating personnel do not enter a s UAS operations area. The secured area or perimeter will be created with plainly visible markings such as tape or rope as well as signs which indicate "Drone Operations in Progress: KEEP BACK". If necessary, observers will be placed as needed to ensure people do not cross into the secured area unintentionally.**UAS Specification Summary Sheet**

**1. DJI PHANTOM 2** General Features • Ready to Fly, Multifunctional Quad

- rotor System • Customized H3

- 2D and H3

- 3D Gimbal S upport • Precision Flight and Stable Hovering • 25min Flight Time & Smart Battery • Auto Return

-to
- Home & Landing • Advanced Power Management • Intelligent Orientation Control (IOC) • Easy Battery Replacement • Self

-tightening Propeller • Video Downlink Support • CAN

- Bus Expansion Module Aircraft • Weight (Battery & Propellers included): 1000g • Hover Accuracy (Ready to Fly): Vertical: 0.8m; Horizontal: 2.5m • Max Yaw Angular Velocity: 200°/s • Max Tilt Angle: 35° • Max Ascent / D escent Speed: Ascent: 6m/s; Descent: 2m/s • Max Flight Speed: 15m/s(Not Recommended) • Diagonal Length: 350mm • Flight Time: 25mins • Take

- off Weight: ≤1300g • Operating Temperature:

- 10°C ~ 50°C DJI Smart Battery • Type: 3S LiPo • Capacity: 5200m Ah, 11.1V • Charging Environment Range: 0 °C to 40 °C • Discharging Environment Range:

- 20 °C to 50 °C 2.4GHz Remote Control • Operating Frequency: 2.4GHz ISM • Communication Distance (open area): 1000m • Receiver Sensitivity (1%PER):

-97dBm • Working Current/Voltage: 120 mA@3.7V • Built

- in LiPo Battery Working Current/Capacity: 3.7V, 2000mAh**2. DJI SPREADING WINGS S900**

Frame • Diagonal Wheelbase: 900mm • Frame Arm Length: 358mm • Frame Arm Weight: (Including Motor, ESC, Propeller ) 316g • Center Frame Diameter: 272mm • Center Frame Weight (with Landing Gear Mounting Base, Servos): 1185g • Landing Gear Size: 460mm(Length)×450mm(Width)×360mm(Height) Motor • Stator Size: 41×14 mm • KV: 400rpm/V • Max Power: 500W • Weight(with Cooling Fan): 158g ESC • Working Current: 40A • Working Voltage: 6S LiPo 22.2V • Signal Frequency: 30Hz ~ 450Hz • Drive PWM Frequency: 8KHz • Weight(with Radiators): 35g Foldable Propeller: (1552/1552R) • Material: High strength performance engineered plastics • Size: 15×5.2inch • Weight: 13g Flight Parameters • Takeoff Weight: 4.7Kg ~ 8.2Kg • Total Weight: 3.3Kg • Power Battery: LiPo (6S 、 10000mAh~15000mAh 、 15C(Min) ) • Max Power Consumption: 3000W • Hover Power Consumption: 1000W (@6.8Kg Takeoff Weight) • Hover Time: 18min (@12000mAh& 6.8Kg Takeoff Weight) • Working Environment Temperature:

- 10 °C ~ +40 °C Gain Value Settings: For A2 flight controller • Basic : Roll 110%, Pitch 110%, Yaw 120% • Attitude: Roll 220%, Pitch 220%, Vertical 120% For WooKong

- M flight controller • Basic: Roll 160%, Pitch 160%, Yaw 160% • Attitude: Roll 190%, Pitch 190%, Vertical 100% 2.4GHz Remote Control • Operating Frequency: 2.4GHz ISM • Communication Distance (open area): 1000m• Receiver Sensitivity (1%PER):

-97dBm

• Working Current/Voltage: 120 mA@3.7V • Built

- in LiPo Battery Working Current/Capacity: 3.7V, 2000mAh

**3 . DJI SPREADING WINGS S1000/S1000+**  Frame • Diagonal Wheelbase: 1045mm • Frame Arm Length: 386mm • Frame Arm Weight (Including Motor, ESC, Propeller ): 325g • Center Frame Diameter: 337.5mm/337mm • Center Frame Weight (with Landing Gear Mounting Base, Servos): 1330g • Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm) Motor • Stator Size: 41×14mm • KV: 400rpm/V • Max Power: 500W • Weight(with Cooling Fan): 158g ESC • Working Current: 40A • Working Voltage: 6S LiPo 22.2V • Signal Frequency: 30Hz ~ 450Hz • Drive PWM Frequency: 8KHz • Weight(with Radiators): 35g Foldable Propeller (1552/1552R) • Material: High strength performance engineered plastics • Size: 15×5.2inch • Weight: 13g Flight Parameters • Takeoff Weight: 6.0Kg ~ 11.0Kg • Total Weight: 4.2Kg/4.4kg • Power Battery: LiPo (6S 、 10000mAh~20000mAh 、 15C(Min)) • Max Power Consumption: 4000W • Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight) • Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) • Working Environment Temperature:

- 10 °C ~ +40 °C Gain Value Settings: For A2 flight controller • Basic: Roll 120%, Pitch 120%, Yaw 120% • Attitude: Roll 170%, Pitch 170%, Vertical 120%For WooKong

- M flight controller

• Basic: Roll 180%/ 130%, Pitch 180%/130%, Yaw 120% • Attitude: Roll 180%, Pitch 180%, Vertical 120% 2.4GHz Remote Control • Operating Frequency: 2.4GHz ISM • Communication Distance (open area): 1000m • Receiver Sensitivity (1%PER):

-97dBm • Working Current/Voltage: 120 mA@3.7V • Built

- in LiPo Battery Working Current/Capacity: 3.7V, 2000mAh