Ronnie Harrison Jul y 1, 2015

1705 NW 15 th Terrace OKC OK, 73013 Cell (806)559

- 2605 Email: Ronnierharrison@y ahoo.com

U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) Phantom 2 Vision+ User Manual V1.6 & Phantom 3 advanced User Manual



### 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 LL C 3) FAA Exemption No. 11080 Regulatory

Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC 4) FAA Exemption No. 11437 Regulatory Docket No. FAA20150221 in the matter of the petition of MARCUS D MELHUS



### Dear FAA 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 Ronnie Harrison, 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 s ys tems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography

, cinematograph y, videography , and other flight operations that could be perform ed safel y and more cost effectivel y with the use of small UAS at low altitude within the U.S. national airspace
sy stem as compared to a manned aircraft. Operations will be in support of local fire departments and related emergency

service agencies, focusin g on pre

- incident planning and imaging that would form the basis for incident action plans in the event of a real emergency . Operations will be performed onl y at the request of and with the authorization and permission of clients (municipalities) or their authorized agents in order to improve incident pre

- planning and raise awareness of the beneficial uses of small unmanned air sy stems for use within the fire service to improve their ability

to respond in the event of a real incident. 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 b y the petitioner are drawn from references 1

- 3.

### The	FARs

The petit ioner seeks exemption from the above mentioned FARs for the following

reasons ; **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 i nspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safel y integrating civil UAS operation in the National Airspace Sy stem. **91.119(c)** As discus sed 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 consent of the local municipality or their designated agent and while maintaining a safe d istance 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 (ADV ANCED AVIATION SOLUTIONS LL C) 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. 881 1, 10808, and 10673 for day time, VFR conditions. The UAS provides battery

power remaining in percent to the PI C. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regar ding 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 propose d operations, The FAA found that a reduced minimum power reserve for flight in day time 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 document s and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safet y would not be adversely affected.

### The	UAS

The DJ I Phantom 2 vision plus and Phant om 3 Advanced is a highl y s uccessful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered b y four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with i ntegrated barometric sensor augmented with global positioning s ys tem (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 transm itted back to a ground control station allowing the operator and/or PI C 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 can be limited by the onboard flight controller and maximum altitude can be preprogrammed b y the PIC. Battery life limits flight times to approximately

25 minutes. The onboard flight controller will warn the pilot via telemetry and
ext ernal 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 inform ation 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 safet y. A preflight checklist will be developed and employ ed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight,

m aintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safet y standards and regulations. The petitioner will only operate the UAS ov er designated properties with the clients consent. 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 alway s be within VLOS of the PI C 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 airc raft of greater proportions, Using UAS to film as a low cost, compared to manned Aircraft costs. Having Creative and visual projects Using a 4 man team, observing, spotting and relaying information back to the UAS Operator can gain so much good vs bad to the consumer, therefore showing the public UAS use is safe and a good thing under the right guidelines and laws alread y set in place and with the knowledge gained through y ears of research and the last 8 y ears doing videoagraphy . Aerial
surveying and inspec tions can increase planning efficiency , improve resource estimations, and reduce risks to personnel and propert y. The petitioner will provide clients with photographic data for these purposes on a ‘ for hire ’ basis acting as an independent contractor and or L. L.C . A visual observer will be utilized. Flight data including UA flight time, Control Unit operation time,incident, accident, and details concerning an y deviations from normal operations will be

available to FAA for use in collecting data regarding th e 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

, cinematograph y, videography

, inspections and other flight operations ” . The reason for such a general and broad based request is that the petitioner wishes to provide services to The Public TO give back and Show UAS Use is safe under guidelines alread y in place for safety and providing services for weddings and other artistic way s that video has ever been shot. P etitioner's business model is based on the idea of offering ad hoc small UAS services to clients who wish to employ these services as a safe, effective, and legal option to enhance their operations. By providing this service to multiple clients, the petitioner can ensure adherence to standards and protocols and can develop and refine generall y applicable safety guidelines and processes. 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 10 ye ars of experience in the ra dio control model aircraft hobby

. Respectful ly

submitted Ronnie Harrison