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 Docket 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 Regulations §§

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 Administration (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 compared 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 FARs

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

reasons;
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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 regulations 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 altitude 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, similar 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 

limitations on proposed operations and the location of those proposed operations, The 
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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 in 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 conditions 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 rotorcrafts in the 

quadcopter configuration with an advertised weight of less than 45 Ounces (1280g) 

designed primarily to carry aloft a high definition camera. It has an advertised maximum 

speed of less than 32 knots (16m/s) and a maximum climb rate of less than 1000 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 positioning 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 controller 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 of 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 FAA 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 and 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 on 
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failure prone components. These documents will be made available to the FAA and SoT 

to assist in future implementation of safety standards and regulations. Flight plans will 

be predetermined to limit the UASs flight time and limit safety concerns. The petitioner 

will take into account 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

environmental 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 

petition 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. Aerial 

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 provide 

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 is 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 commercial 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 

registered 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 professional activities. Filming and Photography will only be conducted 
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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, highways, 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 disasters 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 capability 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