Ryan Media Lab, Inc. - Section 333 Exemption Petition

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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

Dear Sir or 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 under the conditions

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 for commercial 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.com
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Regulations from which the exemption is requested:

14 CFR 21, Subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103 (b) (2)

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (l)

14 CFR 91.409 (a) (l) & (a) (2)

14 CFR 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 relief from 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 nor flammable 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 of the 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 others working with the UAS will see the identification of the 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 less than similar commercial aircraft operations.
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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

the safety and maintenance recommendations found 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 of safety will be maintained by keeping the flight manual at the ground station where

the UAS pilot will have immediate access to 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 UAS will 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 of safety will 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 of the launch site shown on the GPS altitude indicator prior to 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

minimum of 30 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 pilot will have immediate access to it.
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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 in working condition before initiating each flight:

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (l) & (a) (2)

14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following additional

guidelines:

1. The UAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic Control has

been established.

2. Flights will not exceed an airspeed of 36 mph (31.3 knots)

3. Flights will be operated at or below an altitude never exceeding 400 feet AGL.

4. The PIC and VO will communicate verbally at all times.

5. UAS operations will not be conducted during night.

6. All operations will be conducted under visual 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 safety feature that will return to a preprogrammed position and

land if communication with the remote control is lost.

10. Preflight inspections and protocol will be followed prior to all operations.

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies.

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 a safety concern for the general public with less fuel, 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

filming or otherwise have agreed to being in the area prior to the filming taking place.

Sincerely,

Mark A. Ryan 

Ryan Media Lab, Inc.