UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASIITNGTON, DC



### Ralph William Graham Commercial Pilot Rotorcraft Certificate Number 3047206 FORAN 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
. 37028TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS
.... . ........ .. . ..... . ... ..... ... .... ..... ..... ........... ....... .. ..... .. ..... .... 3 SUMMARY ........ ..... .. ...... ............. . .... ... ......... .. .... .... .. .. .. ... ... .... ......... ...... ....... .. .... .. .. ..... . .......4 INTRODUCTION AND INTERESTS OF PETITIONER ....... ........ ........ .. ... . .. ......... . .. ...... 4 BACKGROUND
.... ... ......... ...... ... ... ... ....... .......... .. .. ... ..... ......... ............ ... ....... .. .... ..... . ...... ... .... 4 BASIS FORPETITION
......... .... ........ .. ........ .... ...... .... ........ ..... ..... ..... ... ......... .... ....... ...... .. .... 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 GRANTINGRALPH WILLIAM GRAHAM REQUEST WOULD BE IN THE PUBLIC INTEREST ....... . ............................................. .. 15 THE REASONS WHY GRANTING THEEXEMPTION 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



### 2GLOSSARY 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 ofInterest Air Traffic Control Air Traffic Organization Aerial Vehicle DJI Phantom 1 Code ofFederal Regulations Certificate OfAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System 3D Robotics Solo Loss OfLink National Airspace System Notice To Airman PilotIn Command FAAModernization and Reform Act of2012 (FMRA) Section 333 Safety Observer Standard OperatingProcedures Unmanned Aircraft Unmanned Aircraft System Visual FlightRules Visual Line OfSite Visual Meteorological Conditions Vertical Take-Offand Landing 

### 3SUMMARY 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 ofthe 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 ofconstruction sites, real estate, insurance and landscape over certain areas ofthe 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 ofexperience 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 ofcommercial, public, and residential uses,
• Construction sites before, after and during • Appraisals • Real-estate marketing • Aerial acquisitions used for inspections ofpublic and private structures. • Search and Rescue operations • Insurance work for commercial, Residential, and Farming



### 4BACKGROUND 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 offand 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 ofapproximately 4 pounds 8 ounces, dimensions ofapproximately length of 19 inches, width of 16 inches, height of 8 inches, and a maximum speed ofApproximately 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 47, Aircraft Registration, and marked in accordance with 14 C
.F
. R. Part 45, Identification and RegistrationMarking.
BASIS FOR PETITION Petitioner Ralph William Graham, pursuant to the provisions ofthe Federal Aviation Regulations (14 C
.F
.R. 

### § 11
.61) and the FAA Modernization and Reform Act of20I2 (FMRA), Section 333, SpecialRules for Certain Unmanned AircraftSystems, 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 ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Ralph William Graham's operation of


### 5P1 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 reliefis proper since an equivalent level ofsafety 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
. Relieffrom certain requirements of Section 61.113(a) and (b), entitled 

### Privatepilot 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 relieffrom 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., 

### 6Monthly Maintenance Log, and P1 and 3DRSinstructionManual), and that the aircraft are in

a condition for safe flight. Ralph William Graham also seeks an exemption from the requirements ofSection 91.I2I, entitledAltimeter Settings, as the PI and 3DRS 

### VAS's will not have a typical barometric altimeter onboard. However, altitude information ofthe 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 ofthe flight path
. This altitude information, combined with Ralph William Graham's operation ofthe PI and 3DRS 

### VAS's within visual line ofsight, at or below 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.I21.Additionally, Ralph William Graham seeks an exemption from the requirements ofSection 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 ofapproximately 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 ofits petition for exemption: A. Name And Address OfThe Petitioner The name and address ofthe Petitioner and point ofcontact 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 71. 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) ofan aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC ofan 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 aircraftairworthiness, 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 ofthat 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 ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting ofan appropriate available station;or 

### 8(iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe 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 , entitledFuel requirements for flight in VFR conditions, subsection (b), states the following: (b) Noperson may begin a.flight in a rotorcraft under VFR conditions unless (considering windand forecast weather conditions) there is enough fuel to fly to thefirstpoint of intended landingand , 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, entitledMaintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- 

### (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis 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, oralteration, 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) ofthis 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 ofthis chapter and has been approved for return to service by a person authorized by § 43
.7 ofthis chapter or (2) 

### An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 8. Ralph William Graham Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitledMaintenance 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) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 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 ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service
. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance
. (iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis
. (iv) The current inspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD 

### or Safety directive number and revision date
. If

### the AD or safety 10directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis 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) ofthis 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) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operatorunder § 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 OfReliefRalph William Graham Seeks And The Reason Ralph William Graham Seeks The Relief. 

### 1. Extent 

### OfReliefRalph William Graham Seeks And The Reason Ralph

William Graham Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitledPrivatepilot 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 reliefis 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 ofan 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 orproperty for compensation or hire. As set forth more fully below, Ralph William Graham submits that an equivalent level of safety will be maintained because noPIC will be allowed to operate the 

### 11Pl 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 ofthe PI and 3DRS UAS's, conducted by the PIC pursuant to the grant ofthis 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 OfReliefRalph William Graham Seeks And The Reason

Ralph William Graham Seeks ReliefFrom Section 91.7(a). Relieffrom 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 reliefbecause 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.



### 123. Extent OfReliefRalph William Graham Seeks And The Reason Ralph William Graham Seeks ReliefFrom Section 91.121. Relieffrom Section 91.I2I, entitled Altimeter settings, may be required to allow flight operations ofthe 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 reliefbecause 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 ofthe proposed operations, relieffrom 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 ofsafety 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 ofthe UA on the heads-up display ofthe GCS
. 4. Extent OfReliefRalph William Graham Seeks And The Reason Ralph William Graham Seeks ReliefFrom Section 91.151(b). Relieffrom Section 91.I5I(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe 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 I0 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. Ralph William Graham seeks the requested reliefbecause without an exemption from Section 9I.I51(b), the flight time duration ofthe battery powered PI and 3DRS UAS's will severely constrain the practicality 13ofany 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 ofthe 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 ofintended landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. 

### 5.Extent OfReliefRalph William Graham And The Reason Ralph

William Graham Seeks ReliefFrom 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 relieffrom 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 

### 14construction 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 OfThe 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 ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofthe Pl and 3DRS UAS's would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the air and on the ground. Furthermore, by reducing the number ofmanned 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 takeoffor land. Likewise, a reduction ofmanned 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 offlight operations. 2. The Public Will Benefit From The Safety And Efficiency OfThe 

### Pl and 3DRS UAS's. Conducting aerial acquisitions with the 

### Pl and 3DRS UAS's instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair 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,
15six 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 UAS's, while reducing the carbon footprint ofaerial acquisit ions, 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 offlight crew members located onboard the aircraft, the Pl and 3DRS UAS ' s (weighing approximately under 5 Pounds respectively, attheir 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 ofthe Pl and 3DRS UAS ' s will allow United States based companies, like Ralph William Graham' s to remain competitive and contribute to growth ofthe U.S
. economy. Specifically, with the rising cost ofaviation 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 operat ional flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft
. 

### 16By operating the PI and 3DRS UAS's, companies such as Ralph William Graham's can remain competitive and profitable and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe 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 ofthe 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 OfThe FAA

Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe 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