U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) Phantom 3 User Manual 2 ) Flight Log example 3 ) Pre

- flight /flight Checklist

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Do cket No. FAA

– 2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I Richard L. Knight Jr.

, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulat ions §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administ ration (FAA) for the purposes of aerial photography, cinematography, videography, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as com pared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of
the beneficial uses of small unmanned air systems.

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. The conditions
identified and proposed by the petitioner are drawn from references 1

- 3.

The F ARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;Page 2

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with the addition of a trained observer. All pre

- flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civil UAS operation in the National Airspace System.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted
closer than 500 feet to the ground may require that the UA be operated closer than 500
feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning
the terms “ congested areas” and “densely populated”. The petitioner requests waiver for
this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.

The petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be operated over designated properties with the owner’s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in development of regul ations for commercial operations in low

- risk, controlled environments.

91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the
UAS does not have an altimeter and instead utilizes electronic GPS with a barometric
sensor for altitu de information.

91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, simi lar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime,
VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 20 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the
limita tions on proposed operations and the location of those proposed operations, ThePage 3

FAA found that a reduced minimum power reserve for flight in daytime VFR conditions
was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

As discussed i n Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating
documents and the condi tions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS

The DJI Phantom UAVs are highly successful consumer grade small roto rcraft s in the quadcopter configuration with an advertised weight of less than 45 Ounces (12 80 g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 32 knots (1 6 m/s) and a maximum climb rate of less t han 1 000 feet per minute ( 5 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positionin g system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude is limited by the onboard flight contro ller at a maximum altitude of 500
feet . Battery life limits flight times to approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination o f flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last
less than 12 minutes. More information is available in attachment 1.

Risk mitigation

The petitioner has reviewed FA A exemptions reference’s 1

- 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be
utilized in order to manage and mitigate risk and ensure public safety. A preflight
checklist will be developed an d employed to ensure that the UA airworthiness will be
verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time onPage 4

failure prone components. T hese documents will be made available to the FAA and SoT to assist in future implementation of s afety standards and regulations . Flight plans will be predetermined to limit the UASs flight time and limit safety concerns. The petitioner
will take into accou nt distance from persons and potential flight obstacles prior to operating the UAS. UAS operation will always be within VLOS of the PIC and the
observer.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the
enviro nmental impact as compared to similar operations conducted with manned aircraft
of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS
in order to facilitate commerce could lead to economic growth. Operations for this peti tion will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aeria l photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provid e clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA
via traditional means or other means as required.

Conclusion The petitioner i s requesting this exemption for the purposes of “aerial photography, cinematography, videography, inspections and other flight operations”. Specifically, I will use UASs which are equipped with cameras and sensors, in order to engage in the following com mercial activities:

(a) Video filming by air and photographing for public and private purposes, including: television, cinematography, advertising or promotions. Filming and Photography will only be conducted with permission and under contract with regis tered owners or with any local government authority and only when safe to
do so. (b) Video filming by air and photographing to support professional operations in engineering, land surveying and development, architecture, real estate and other related prof essional activities. Filming and Photography will only be conductedPage 5

with permission and under contract with registered owners or with any local government authority and only when safe to do so. (c) Inspection by air of infrastructure such as bridges, high ways, and pipelines. These inspections will only be done under contract and permission with any registered owners or with any local government authority and only when safe to
do so. (d) Inspection by air of land and residential, commercial and industrial structures, only under contract and permission with any registered owners or with any local government authority and only when safe to do so. (e) Support provided to search and rescue operations and reconnaissance in cases of need, emergency or natural di sasters only when government authorities have requested it by contract or donation and only when safe to do so.

The petitioner's business model is based on the idea of offering ad hoc small UAS
services to individuals companies and government entities, which wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capabili ty to offer those services while remaining in compliance. The petitioner has over 30 years of news videography/photography experience working with law enforcement and government officials. The petitioner now teaches broadcast journalism at Lancaster High School.

Respectfully Submitted,

Richard L. Knight

1272 Foxfire Dr.

Lancaster SC 29720
knightlynews@comporium.net