UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

W ASIITNGTON, DC 

Ralph William Graham 

Commercial Pilot Rotorcraft Certificate Number 3047206 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF .FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 1/3D ROBOTICS SOLO UNMANNED 

AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on December 1, 2015 

207 Lakeshore Circle 

Bumpus Mills, Tn. 37028 
TABLE OF CONTENTS 

Page 

GLOSSARY OF ABBREVIATIONS .... .......................... ....... ..... ..... .................. .. ............ .... 3 

SUMMARY ........ ..... .. ...... .................. ............ .. .... .... .. .. .. ...... .... ............... ....... .. ...... .. ............. 4 

INTRODUCTION AND INTERESTS OF PETITIONER ....... ........ ........ .. ...... ............ ...... 4 

BACKGROUND .... ... ............... ... ... ... ................... .. ... ..... ........................ ....... .. .... ............... .... 4 

BASIS FOR PETITION ......... .......................... ...... .... ........ ..... .......... ... .................... ...... .. .... 5 

NAME AND ADDRESS OF PETITIONER .... ......... .... ...................... .............. .... .. 7 

THE SPECIFIC SECTIONS OF 14 C.F.R FROMWHICHRALPHWILLIAM 

GRAHAM SEEKS EXEMPTION ........... ...... ... .. .... ... .. .... ......... .... ... .. ..... .............. .... 8 

THE EXTENT OF RELIEF RALPH WILLIAM GRAHAM SEEKS AND THE 

REASON Ralph William Graham SEEKS THE RELIEF ... ...... ......... ............ .... 11 

THE REASONS WHY GRANTING RALPH WILLIAM GRAHAM REQUEST 

WOULD BE IN THE PUBLIC INTEREST ....... .............................................. .. 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY ......... ................................... .. .................... .... .. 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER .. . 34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT RALPH WILLIAM GRAHAM'S REQUEST ... . .. 34 

CONCLUSION .......... .......... ............. ....... .. .... ..... ......... ........ ........... ................. .... ... ....... ..... 3 5 

APPENDICES ............... . .. ......... . ... ... .... ....... ... ... .... ... .... .. ....... ....... ....... ... .36 

2 
GLOSSARY OF ABBREVIATIONS 

AGL 

AOI 

ATC 

ATO 

AV 

Pl 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

3DRS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

DJI Phantom 1 

Code ofFederal Regulations 

Certificate Of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

3D Robotics Solo 

Loss OfLink 

National Airspace System 

Notice To Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line Of Site 

Visual Meteorological Conditions 

Vertical Take-Off and Landing 

3 
SUMMARY 

Ralph William Graham seeks exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a) 

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of2012 (FMRA). This exemption will 

permit to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography of construction sites, real estate, insurance and 

landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Ralph William Graham provides his clients with expertise and knowledge in advanced 

photography and video solutions to increase efficiency, productivity and effectiveness. 

Ralph William Graham has over 15 years of experience in Photographic and Video 

Technology. He has over 40 years and 8000 hours in Military and Commercial aviation 

experience in single and multi engine Helicopters. He holds an FAA Commercial Pilot 

Rotorcraft - Helicopter; Instrument Helicopter Rating, Certificate Number: 3047206 and 

CFI Rotorcraft-Helicopter Number 3047206CFI. The objective of Ralph William 

Graham's aerial video and Photography operations is to provide high quality imaging for a 

variety of commercial, public, and residential uses, 

• Construction sites before, after and during 

• Appraisals 

• Real-estate marketing 

• Aerial acquisitions used for inspections of public and private structures. 

• Search and Rescue operations 

• Insurance work for commercial, Residential, and Farming 

4 
BACKGROUND 

Unmanned Aircraft Systems: DTIPl, 3DRS UAS's Ralph William Graham seeks an 

exemption to operate DTI Pl & 3D Robotics Solo (3DRS) systems for 

compensation or hire within the NAS. The Pl and 3DRS are vertical take off and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) Utilizing 

a 5.8GHz Remote Control system. Both are similar in size weight and performance. Both 

the Pl and 3DRs have a maximum gross weight of approximately 4 pounds 8 ounces, 

dimensions of approximately length of 19 inches, width of 16 inches, height of 8 inches, 

and a maximum speed of Approximately 30 knots. Both have four main rotors; utilizing 

Lithium Polymer batteries to power the electric motors. The PI and 3DRS UAS's that 

will be operated by Ralph William Graham will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F .R Part 4 7, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. 

BASIS FOR PETITION 

Petitioner Ralph William Graham, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F.R. § 11 .61) and the FAA Modernization and 

Reform Act of20I2 (FMRA), Section 333, Special Rules for Certain Unmanned 

Aircraft Systems, hereby petitions the Administrator to commercially operate the 

PI and 3DRS UAS's in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b ), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Ralph William Graham's operation of 

5 
P1 and 3DRS VAS's meets the conditions ofFMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Ralph William Graham requests relieffrom Sections 91.405(a), 

91.407(a)(l), 91.409(a)(I) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Ralph William Graham submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Ralph William Graham will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance on 

the UAS's using the methods, techniques, and practices prescribed in the operating 

documents (i.e., Monthly Maintenance Log, and Pl and 3DRS Instruction Manual). 

Furthermore, Ralph William Graham will document and maintain all maintenance 

records for the PI and 3DRS UAS's. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Ralph William Graham 

to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher 

level certificate, as well as an airman medical certificate, and who has demonstrated, by 

meeting minimum flight- hour and current requirements, that the PIC is able to safely 

operate the P1 and 3DRS UAS's in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Ralph William Graham seeks relief from Section 91.7(a), entitled Civil aircraft 

aifworthiness, because the P1 and 3DRS UAS's do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Ralph William Graham submits 

that he will ensure that the PI and 3DRS UAS's are in an airworthy condition, prior to every 

flight, by determining that the UAS's are in compliance with the operating documents (i.e., 

6 
Monthly Maintenance Log, and P1 and 3DRSinstruction Manual), and that the aircraft are in 

a condition for safe flight. Ralph William Graham also seeks an exemption from the 

requirements of Section 91.I2I, entitled Altimeter Settings, as the PI and 3DRS VAS's will 

not have a typical barometric altimeter onboard. However, altitude information of the 

PI and 3DRS VAS's will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communic,!ltions telemetry data link, which downlinks from the UAS 

to the GCS for active monitoring of the flight path. This altitude information, combined 

with Ralph William Graham's operation of the PI and 3DRS VAS's within visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.I21. 

Additionally, Ralph William Graham seeks an exemption from the requirements 

of Section 9I.I5I(b), entitled Fuel requirements for flight in VFR conditions. Ralph 

William Graham submits that safety will not be affected by operation ofthe Pl and 

3DRS VAS's during daylight hours in visual meteorological conditions (VMC) under visual 

flight rules (VFR), with enough battery power to fly for a total duration of approximately 10 

minutes for the intended photo shoot and, assuming normal cruising speed, to fly after that 

for at least 2.5 minutes for recovery and landing. 

In accordance with I4 C.F.R. § II.8I, Buckley Thomas Burkhardt provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner 

The name and address of the Petitioner and point of contact is: 

Ralph William Graham 

207 Lakeshore Circle 

Bumpus Mills, Tn. 37028 

912-484-3902 

Email: r.w.graham@hotmail.com 

B. The Specific Sections Of 14 C.F.R. From Which Ralph William Graham 

seeks Exemption 

7 
1. Ralph William Graham Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if-

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Ralph William Graham Seeks Exemption From The Requirements Of 

Section 91.7(a). 

Section 91. 7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Ralph William Graham Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles ofthe aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station;or 

8 
(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Ralph William Graham Seeks Exemption From The Requirements Of 

Section 91.151(b). 

Section 91.151 , entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following: 

(b) No person may begin a .flight in a rotorcraft 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, to 

fly after that for at least 20 minutes. 

5. Ralph William Graham Seeks Exemption From The Requirement Of 

Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft-

(a) 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[.] 

6. Ralph William Graham Seeks Exemption From The Requirements Of 

Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

( 1) It has been approved for return to service by a person authorized under § 

43.7 ofthis chapter. 

7. Ralph William Graham Seeks Exemption From The Requirements Of 

Sections 91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had--

9 
(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43 .7 of this 

chapter or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Ralph William Graham Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with§§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD 

or Safety directive number and revision date. If the AD or safety 

10 
directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(l) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after 

the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Ralph William Graham Seeks And The Reason 

Ralph William Graham Seeks The Relief. 

1. Extent Of Relief Ralph William Graham Seeks And The Reason Ralph 

William Graham Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding 

a private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and 

(b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Ralph William Graham submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the 

11 
Pl or 3DRS UAS's unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the PI or 

3DRS UAS's in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Further, Ralph William Graham submits that all flights of the PI and 3DRS 

UAS's, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 

Ralph William Graham's business; and (2) will not carry passengers or property for 

compensation or hire. 

2.Extent Of Relief Ralph William Graham Seeks And The Reason 

Ralph William Graham Seeks ReliefFrom Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Ralph William Graham to determine that the Pl and 3DRS 

UAS's are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Monthly Maintenance Log and Pl 

and 3DRS manuals. 

Ralph William Graham seeks the requested relief because the PI and 3DRS UAS's do 

not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. 

Therefore, Ralph William Graham will ensure that the P1and 3DRS UAS's are in 

airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and PI and 3DRS Instruction Manual) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

12 
3. Extent Of Relief Ralph William Graham Seeks And The Reason 

Ralph William Graham Seeks Relief From Section 91.121. 

Relief from Section 91.I2I, entitled Altimeter settings, may be required to allow 

flight operations of the PI and 3DRS UAS's, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). Since the 

FAA requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Ralph William Graham seeks 

the requested relief because the PI and 3DRS UAS's altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

each flight. 

Considering the limited altitude of the proposed operations, relief from I4 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since the P1 and 3DRS UAS's are equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA on 

the heads-up display of the GCS. 

4. Extent Of Relief Ralph William Graham Seeks And The Reason 

Ralph William Graham Seeks Relief From Section 91.151(b). 

Relief from Section 91.I5I(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered PI and 3DRS UAS's 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of I 0 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 2.5 minutes. Ralph William Graham 

seeks the requested relief because without an exemption from Section 9I.I51 (b), the flight time 

duration of the battery powered PI and 3DRS UAS's will severely constrain the practicality 

13 
of any aerial video or still photo flight operations that Ralph William Graham proposes to 

conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Pl and 3DRS 

UAS's, the Pl and 3DRS operating documents and Ralph William Graham's 

proposed operating limitations, ensure that Ralph William Graham will safely operate the 

battery powered Pl and 3DRS UAS's during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 10 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 2.5 minutes. 

5.Extent Of Relief Ralph William Graham And The Reason Ralph 

William Graham Seeks Relief From Sections 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Ralph William Graham requests 

relief from these Sections because the PI and 3DRS UAS's do not require airworthiness 

certificates. As set forth more fully below, the Pl and 3DRS UAS's meet the conditions 

ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

Ralph William Graham will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS's using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the Aerial Operations Manual, Monthly 

Maintenance Log, and Pl and 3DRS Instruction Manual). Furthermore, Ralph William 

Graham will document and maintain all maintenance records for the Pl and 3DRS 

UAS's. 

D. The Reasons Why Granting Ralph William Graham Request Would Be In 

The Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Ralph William 

Graham to safely, efficiently, and economically perform aerial video and photography of 

14 
construction sites, real estate, insurance and landscape over certain areas of the United 

States. Additionally, use of the Pl and 3DRS UAS's will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the 

benefits of Ralph William Graham's proposed operation of the Pl and 3DRS 

UAS's will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The PI and 3DRS UAS's are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of the Pl and 3DRS UAS's would reduce the amount of manned aircraft in 

the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the 

air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

Pl and 3DRS UAS's do not require an airport to takeoff or land. Likewise, a reduction 

of manned aircraft conducting aerial video and photography missions would result in 

fewer aircraft that must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The Pl and 

3DRS UAS's. 

Conducting aerial acquisitions with the Pl and 3DRS UAS's instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the Pl and 3DRS UAS's produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, 

15 
six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography while burning approximately 20-30 gallons per hour ofleaded aviation 

fuel. The P 1 and 3DRS U AS's, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA's are propelled by battery powered 

electric motors, rather than an internal combustion engine. 

By using the Pl and 3DRS UAS's to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the Pl and 3DRS UAS's (weighing approximately under 5 Pounds 

respectively, at their maximum gross weights with respectively (and with no fuel on 

board) has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations weighing approximately 6,000 pounds, and a fuel capacity of 180 gallons. 

3. Performing Aerial Video and Photography Operations With The Pl and 

3DRS VAS's Will Benefit The Economy. 

In addition to being safe and efficient, the Pl and 3DRS UAS's are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the Pl and 3DRS UAS's will allow United States based companies, like 

Ralph William Graham's to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. Operating 

the battery powered Pl and 3DRS UAS's is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. 

16 
By operating the PI and 3DRS UAS's, companies such as Ralph William 

Graham's can remain competitive and profitable and therefore, provide greater job stability 

to employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance ofU.S. companies, through commercial use of 

the P1 and 3DRS UAS's, provides a stable workforce that increases consumer spending, 

improves local, state, and federal tax revenues and allows companies to invest in research 

and development in order to remain competitive both in the United States and abroad. 

4.There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Buckley Thomas Burkhardt's proposed operation of the PI and 3DRS UAS's will 

not implicate any privacy issues. Specifically, the PI and 3DRS UAS' swill be operated only 

in compliance with operating documents (i.e. Aerial Operations Manual, Monthly Maintenance 

Log, and the Pl And 3DRS Instruction Manual's) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F. R. § 91.1I9. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To 

That Provided By The Rule From Which Ralph William Graham Seeks 

Exemption. 

1. Reasons Why The Pl and 3DRS VAS's Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation Ralph William Graham's operation of 

the PI and 3DRS UAS's meet the conditions ofFMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of 

17