Ryan Media Lab, Inc.

-Section 333 Exemption Petition P a g e | **1**

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

-140 1200 New Jersey Avenue, SE Washington, DC 20590 January 17, 2016 **RE: Exemption Request**  **Section 333**  **of the**  **FAA Reform Act**  **of 2012**  **and Part 11**  **of the**  **Federal Aviation**  **Regulations** DearSiror Madam; In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, Ryan Media Lab, Inc. request exemption from the Federal Aviation Regulations to allow for commercial operations of a 3D Robotics Solo, 3D Robotics X8+, DJI S1000+ and DJI Phantom 3 Professional, Unmanned Aerial System (UAS) for purposes of aerial photography and videography; but only so long as such operations are conducted within and undertheconditions outlined herein or as may be established by the FAA as required by Section 333 or Section 49 USC § 44701. The requested exemption would permit the operation of UAS platforms previously approved by the FAA forcommercial operations in the United States. **Applicant:** Mr. Mark A. Ryan Ryan Media Lab, Inc. 31794 Carneros Avenue Lewes, DE 19958 412.389.7097 Mark@ryanmedialab.comRyan Media Lab, Inc.

-Section 333 Exemption Petition P a g e | **2**

**Regulations from**  **which the**  **exemption is**  **requested:** 14CFR 21, Subpart H 14CFR45.23 (b) 14CFR 61.113 (a)& (b)& 14 CFR 61.133 (a) 14CFR 91.7 (a) 14CFR 91.9 (b) (2) 14CFR 91.103 (b) (2) 14CFR 91.109 14CFR 91.119 (c) 14CFR 91.121 14CFR 91.151 (a) 14CFR 91.203 (a)& (b) 14CFR 91.405 (a) 14CFR 91.407 (a) (l) 14CFR 91.409 (a) (l)& (a) (2) 14CFR 91.417 (a)& (b) **14 CFR**  **21, Subpart**  **H -**  In consideration of the size, weight, speed, and limited operating area associated with this UAS and its operation, I, Mark A. Ryan, of Ryan Media Lab, Inc., request relieffrom 14 CFR part 21, Subpart H, and any associated noise certification and testing requirements of part 36. The UAS will carry neither pilot, passenger, explosive materials norflammable liquids. **14 CFR**  **45.23 (b)** **-** Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and othersworkingwith the UASwillsee the identification ofthe UAS as "Experimental." **14 CFR**  **61.113 (a)**  **& (b)**  **& 14**  **CFR 61.133**  **(a) -**  Since the UAS will not carry a pilot or I, Mark A. Ryan, of Ryan Media Lab, Inc., request a relief from these regulations. Any pilot in command or (PIC) operating the UAS will hold a Sport Pilot (or greater) certificate. A visual observer or (VO) will be utilized and required to communicate verbally at all times. The UAS will be limited to operations within visual distance of both the PIC and VO. All UAS operations will take place in a controlled area. The risks associated with the use of a UAS are far lessthan similar commercial aircraftoperations.Ryan Media Lab, Inc.

-Section 333 Exemption Petition P a g e | **3**

**14 CFR**  **91.7 (a)** **-** Since the UAS will not carry a pilot or passengers there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard exists for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist prior to each flight, an equivalent level of safety will be provided. All flights will be in accordance with thesafetyand maintenance recommendationsfound in the DJI Phantom 3 attachments. **14 CFR**  **91.9 (b)**  **(2) -**  Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level ofsafetywill be maintained by keeping the flight manual atthe ground station where the UAS pilotwill have immediate accessto it. **14 CFR**  **91.103 (b)**  **(2) -**  As no FAA approved flight manuals will be provided for the aircraft an exemption is needed. Alternate procedures including but not limited to reviewing weather conditions, checking flight battery requirements, checking takeoff and landing distances along with those found in the attached "DJI Pilot Training" will be implemented. These actions will provide an equivalent or higher level ofsafety. **14 CFR**  **91.109 -**  UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. An equivalent level of safety will be achieved using the real time ground station data and given the UASwill carry neither a pilot nor passengers. **14 CFR**  **91.119 (c)**  **-** The UAS will never be operated at an altitude higher than 400 feet AGL. The UAS will operate in safe areas away from public and traffic and only with permission of the property and structure owners. The UAS will also be restricted by the flight controller to a maximum vertical height of 400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher level ofsafetywill be achieved. **14 CFR**  **91.121 -**  As the UAS may not have a barometric altimeter, but instead a GPS barometric sensor for altitude information an exemption may be required. An equivalent level of safety will be achieved using a ground station which links to a telemetry data link. This will provide the pilot with live flight data monitoring, confirming the altitude ofthe launch siteshown on the GPS altitude indicator priorto flight. **14 CFR**  **91.151 (a)**  **-** The UAS has a limited range and will be limited to operations in a controlled environment. The battery power the UAS provides approximately 23 minutes of flight time. The UAS is unable to meet the 30 minute reserve requirement and therefore requires an exemption. An equivalent level of safety will be achieved by monitoring the battery through the ground station and landing with a minimumof30 percent battery power remaining. **14 CFR 91.203**  **(a) &**  **(b) -**  Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground station where the UAS pilotwill have immediate accessto it.Ryan Media Lab, Inc.

-Section 333 Exemption Petition P a g e | **4**

Given the following sections only apply to aircraft with an airworthiness certificate; these sections do not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and ensure UAS is inworking condition before initiatingeach flight: 14CFR 91.405 (a) 14CFR 91.407 (a) (1) 14CFR 91.409 (a) (l)& (a) (2) 14CFR 91.417 (a)& (b) **Equivalent Level**  **of Safety**  In addition to the safety standards mentioned abovethe UASwilladhereto thefollowing additional guidelines: 1. The UASwill not beoperated within5 miles ofanairport unless priorcontactto AirTraffic Control has beenestablished. 2. Flights will not exceed an airspeed of36 mph (31.3 knots) 3. Flights will beoperated at or below an altitude never exceeding400feetAGL. 4. The PIC and VO will communicateverbally at all times. 5. UASoperations will not be conducted during night. 6. All operationswill be conducted undervisual meteorological conditions. 7. The UAS will land with a minimum 30 percent battery reserve remaining. 8. The UAS will only be piloted within visual line ofsight. 9. The UAS will utilize an internal flight safetyfeature thatwill return to a preprogrammed positionand land ifcommunicationwith the remote control is lost. 10. Preflight inspections and protocol will be followed priorto all operations. 11. The UASwillabortflight in the event of unpredictable obstacles oremergencies. **Public Interest**  I, Mark A. Ryan, of Ryan Media Lab, Inc., believe the use of a UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact compared to similar operations conducted with a manned aircraft carrying a crew and flammable fuel. The use of a UAS in the real estate industry provides both the buyer and seller with a higher level of marketing and service. The UAS is able to provide a view which encompasses the entire property in a single photo or short video clip. When compared to similar operations, utilizing a UAS poses much less of asafety concern forthe general public with lessfuel, time, noise and other resources. **Privacy** All flights will occur over private or controlled areas with the owner's consent. Capturing people in images will rarely occur. If a person is captured in a collected image they will have consented prior to filmingorotherwise have agreed to being in thearea priorto thefilmingtaking place. Sincerely, Mark A. Ryan Ryan Media Lab, Inc.