Ronnie Harrison July 1, 2015

1705 NW 15th Terrace

OKC OK, 73013

Cell (806)559-2605

Email: Ronnierharrison@yahoo.com 

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 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 LLC 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 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 in support of local fire departments 

and related emergency service agencies, focusing 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 only 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 systems 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 by the petitioner are drawn from references 1-3. 
The	FARs	

 The petitioner 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 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 consent of the local municipality or their 

designated agent 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

25 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 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 2 vision plus and Phantom 3 Advanced is a highly successful 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 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 can be limited by the onboard flight controller and 

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to 

approximately 25 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 failure prone components. These 

documents will be made available to the FAA and SoT to assist in future implementation of 

safety standards and regulations. The petitioner will only operate the UAS over 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 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, 

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 already set in place and with the 

knowledge gained through years of research and the last 8 years doing videoagraphy. Aerial 

surveying and inspections can increase planning efficiency, improve resource estimations, and 

reduce risks to personnel and property. 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 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”. 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 already in place for safety and 

providing services for weddings and other artistic ways that video has ever been shot. Petitioner'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 generally 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 years of experience in the radio control model aircraft hobby. 

Respectfully submitted Ronnie Harrison