Scott Kramer (UAVKC)

2618 Somerset Drive

Prai rie Village, KS 66206

913

- 424

- 6155 scott@uavkc.com

Section 333 Exemption Petition

December 1, 2015

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 t he Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Ma’am,

I

, Scott Kramer (UAVKC) , am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Scott

Kramer (UAVKC) , an owner and operator of small unmanned aircraft, be exempted from

the Fe deral Aviation Regulations (“FARs”) listed below so that I, Scott Kramer (UAVKC)

, may operate my small ultra lightweight unmanned aircraft system (“UAS”) commercially in regulated airspace by the Federal Aviation Administration (“FAA”).

Following exempt ion and approval by the FAA, I, Scott Kramer (UAVKC) , will primarily use my professionally built DJI Inspire 1, DJI Phantom 3, and Custom built RSD X8 and RSD Y6 UAS equipped with cameras for the following applications: Closed

- Set Film Operations on Film a nd Television Productions, as well as Aerial Videography/ Cinematography to safely enhance Films and commercials; augmentation of real estate listing videos; and the creation of visual and topography layout videos for search and rescue (SAR) missions for s tate and local agencies, education, agricultural inspections and building and construction zone inspections.

My, Scott Kramer (UAVKC) ’ s, exemption request would permit the operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS ’ s fo r the development of community and government use videos, permissible within property boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehi cular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. Furthermore, it is my intent to assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific video and photography usage by sharing information with the FAA as I, Scott Kramer (UAVKC) , record flight data and other pertinent information gained through permitted flight operations.2

2 In ad dition, granting my, Scott Kramer (UAVKC) ’s, exemption request will comply with the Secretary of Transportation ’ s (FAA Administrator ’ s) instructions to not only integrate UAS's into the national airspace system, but to “...establish requirements for the sa fe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/realtor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultur al field monitoring, film/video productions, closed

- set motion picture film operations and television, and structure inspections, to aid state and local agency ’ s.

Further I, Scott Kramer (UAVKC) , will conduct my operations in compliance with the protoco ls described herein or as otherwise established by the FAA. For the reasons stated below, I, Scott Kramer (UAVKC) , respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS ’ s to aid academic community

aw areness, to benefit/stimulate attraction to the Honolulu, Hawaii area and to enhance personal and public video feeds. A grant that will ultimately allow UAS ’ s to play a more positive role in our local community by increasing employment opportunities, heigh tening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel

- a potential public hazard in and

of itself.

I. Contact Information:

Scott Kramer

2618 Somerset Driv e Prairie Village, KS 66206

913

- 424

- 6155 scott@uavkc.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which

Scott Kramer (UAVKC) Requests Exemption are:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manua ls and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my, Scott Kr amer (UAVKC) ’ s, UAS’ permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under bo th the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to are as such as airports and dense populations. My, Scott

Kramer (UAVKC) ’ s, current and projected UAS meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate.

As no such certificate wil l be applicable in the form contemplated by the FARs, this Regulation is inapplicable.3

3 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regul ation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9 299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing”

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifica tions and registrations by me, Scott Kramer (UAVKC)

.

B. 14 C.F.R. § 45.23: Marking of The Aircraft

. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS can be marked with the appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, Scott Kramer (UAVKC) , The sUAS Pilot in C ommand must possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

D. 14 C. F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 300 ft AGL; safely below the standard of 400 AGL. I, Scott

Kramer (UAVKC) , will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe

altitudes. Given th e size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other th ings, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Scott Kramer (UAVKC) 's, UAS. However, as a safety precaution I inspect my UAS before and after each flight.4

4 III . The Extent of relief Scott Kramer (UAVKC) Seeks and the Reason He Seeks Such

Relief:

I, Scott Kramer (UAVKC) , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, Scott Kramer (UAVKC) , conducting commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our nationa l airspace system as it is in the public ’ s interest to do so. My, Scott Kramer (UAVKC) ’ s, ultra lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expres sly contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby,

p roviding direct experience and valuable information f or formal regulation that can be

a dministered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a).

Each of these items reflect in favor of an exemption for me, Scott Kramer (UAVKC) . My

UAS ’ s utilize eight (8) or less rotating propellers for balance, control and stability. My UAS ’ s are equipped with the following via video and data telemetry:

1) Altimeter 2) Attitude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery Left with approximate time. 11) Loiter and circle mod e. 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology.

Each UAS weighing less than thirty (35) pounds (far below the maximum 55 pound limit); Including camera(s) with or without gimbal (a camera stabilizer). I, Scott Kramer (UAVKC)

, considers safety as foremost with each flight. My small unmanned aircraft s are designed to hover in place, circle in a specific place or loiter via GPS, and can be operated in winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financia l loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released.5

5 With three (3) modes to choose from, I will fly with the modes safest to complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed slowly descen d to point of takeoff and or to land at point of launch after ascending to a pre

- set altitude to ensure the UAS will clear any obstacles that may be between the takeoff point and the current position of the UAS. This failsafe altitude

will not be set more than 200ft and is determined before each flight.

I, Scott Kramer (UAVKC) , will not operate my UAS near airports, hospitals nor police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending o n location, conditions and weather. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS ’ s are capable of vertical and horizontal operations, and is flown only within my line of sight, as the remote control pilot. My UAS's are also flown with a second operator who aids in watching for any obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than c ombustible fuels, flights generally last between three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (150) feet. (3 )Sma rt Mode includes, position hold, self

- leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter

and UAS.

I, Scott Kramer (UAVKC) , utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; preferring to r emain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement

for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist

si mulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills an d response reflex time. All for the sake of safety.

I, Scott Kramer (UAVKC) , am extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L . 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress ’ s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Scott

Kramer (UAVKC) ’ s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How Scott Kramer (UAVKC) ’s Request Will Benefit the Public as a Whole:

Aerial videography for geographical awar eness, education, search and rescue, land management, structure inspections and for real estate marketing has been around for a long6

6 time through manned fixed wing aircraft and helicopters. For small budget companies, average homeowners and property owners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense; depriving non

- luxury owners and lower budget companies from a valuable marketing tool. Manned ai rcraft pose a threat to the public through potential

crashes that the United States has experienced in the past with military aircraft, touring helicopters, and news helicopters crashes. Many of them resulting in loss of life.

Each aircraft has combusti ble fuel that burns on imp act adding to the already present danger in the event of a crash. My, Scott Kramer (UAVKC) 's, UAS poses no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already pro claimed that it is in the public ’ s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act.

Granting my, Scott Kramer (UAVKC) ’ s, exemption request furthers the public interest through academi c/visual awareness of the geographical benefits in and around the Honolulu area. My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra light weight UAS crashing is far less than a

f ull size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause devastation to the public. The public ’ s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight UAS's.

Permitting me, Scott Kramer (UAVKC) , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Honolulu and the surro unding community for companies looking to relocate or build around Honolulu as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which s erve as a stimulus to the community.

V. Reasons Wh y Scott Kramer (UAVKC) ’ s Exemption W ill Not Adversely Affect Safety

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Scott Kramer (UAVKC) ’ s, exemption will not adversely affect safety. Quite the contrary, for the r easons stated permitting me, Scott Kramer (UAVKC) , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protoco ls for realtors, land, and structure owners. For development in cooperation

with the FAA.

In addition I, Scott Kramer (UAVKC) , submit the following representations of enhancements to current aerial videography and photography: My UAS ’ s weigh between 6

- 34 lbs. complete with batteries and cameras; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); My UAS only operate for 8

- 30 minutes per flight; I land my UAS prior to manu facturer recommended minimum level of battery power; I pilot my UAS through remote control only by line of sight; and have live video feed for a secondary pilot to monitor video recording; I receive a live telemetry feed from my UAS during all flights whic h include remaining battery voltage, distance, altitude, and any anomalies that may occur during flight; My UAS ’ s Command and Control utilizes spread spectrum 2.4Ghz

- 2.485Ghz frequencies in7

7 accordance with CFR 47, Part 15 for model aircraft use; My UAS ’ s c amera system utilizes

5.725Ghz

- 5.875Ghz frequencies in accordance with CFR 47, Part 15; My UAS ’ s have a GPS controlled flight controller

- a flight safety feature whereby it hovers or circles and then lands at the GPS takeoff point if communication with the remote control pilot is lost; The DJI Inspire 1 and DJI phantom 3 UAS feature a flight controller app that actively records and analyzes flight data through that can be used to update and enhance safety protocols; I only operate in reasonably safe environ ments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocols during which safety carries the utmost importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger.

My, Scott Kramer (UAVKC) ’ s, safety protocols provide a level of safety equal to or exceeding existing rules. It is import ant to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness real estate, structured inspections, land management and search and rescu e. While the safety record of such helicopters is remarkably astounding, there have been local incidents involving loss of life as well as extensive property damage; it is far safer to operate a battery powered lightweight UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third,

the smal l size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects th ey are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

VI. A Su mmary The FAA May Publish in the Federal Register

In summary, Scott Kramer (UAVKC) seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C. F.R. §§ 91.417 (a) & (b) to commercially operate my, Scott

Kramer (UAVKC) ’ s, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural inspection land management, search and rescue and real estate operations , and to develop economic platforms for the aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate

and to find in the Honolulu area.

VII. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and equipment8

8 2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL.

4. The UAS must be operated within vi sual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's state driver ’s license.

5. All operations must utilize a visual observe r (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. If a discrepancy exists between these limitations and any procedure outl ined elsewhere in this operations manual, the conditions and limitations herein take precedence and must

be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condi tion that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if
utilized, must be includ ed in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manu facturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements

must be established and identifi ed in the operator's manual. At a minimum, the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control9

9 i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a

current state driver ’ s license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

11. Prior to operations conducted for the purpose of mo tion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UA S pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be co nducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered non

participants, and the PIC must operate the UAS with appropriate distance from non

participants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experienc e

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building,

and take

- off and landing currency flights, a ll persons not essential for flight operations are

considered non

- participants, and the PIC must operate the UAS with appropriate distance

from non

- participants in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this gran t of exemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator ’ s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture fil ming (or similar operations), a flight demonstration, administered by an operator

- approved and

- qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the kn owledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduc t these tests in accordance with the operator ’ s manual.

15. The UAS may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property

on the surface in the event of a UAS failure or emergency.10

10 16. Regarding the distance from participating persons, the operator ’ s manual has safety mitigations for authorized and consenting production personnel. At all times, those persons

must be essential to the closed

- set film op erations. Because these procedures are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petitioner ’ s manuals. This is

consistent with the manned air craft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television Filming

.

17. Regarding distance from non

- participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent l evel of safety may be determined by an aviation safety inspector ’ s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect non

- participating persons (observers, the public , news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the secur ity perimeter and land or be recovered in accordance with the operator ’ s manual. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the security perimeter and land or be recovered in accordan ce with the operator ’ s manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator ’ s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery p ower remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the ope rator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance wit h 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS maintenance, preven tative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator ’ s manual.

24. Each UAS operated under this exemption must comply with all manufacture r Safety

Bulletins.11

11 25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator ’ s manual.

26. The preflight inspection section in the operator ’ s manual must be amended to include the following require ment: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator ’ s manual.

27. Before conducting operations, the radio frequency s pectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affecte d by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the foll owing: a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming production under this grant of exemption c. Name and phone number of the person responsible for the on

- scene operation of the

UAS.

d. Make, model and serial or N

- number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming production event

f. A statement that the operator has obtained permission from property owners and/or local

officials to co nduct the filming production event; the list of those who gave permission must be made available to the inspector upon request. g. Signature of exemption

- holder or representative

h. A description of the flight activity, including maps or diagrams of a ny area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation

29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC at the ground control station o f the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

30. The UAS must remain clear and yield the right of way to all other manned operations

and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under v isual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.12

12 34. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 miles of the geographic ce nter of a non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport ’ s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator ’ s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to

the Federal Aviation Administration ’ s (FAA) UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB Web sit e: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided.

VIII. Conclusion

Currently, the aforementioned aerial videography/ph otography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting

my, Scott Kramer (UAVKC) ’ s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft d o not contain potentially e xplosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time.

Further, I operate at lower altitudes and in controlled airspace eliminating potential publ ic risk flying to and from established airfields. I, Scott Kramer (UAVKC) , have been informally analyzing and recording flight information and will compile safety protocols and the implementation of a flight operations manual for usage that exceeds current ly accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on bo ard my, Scott Kramer (UAVKC) ’ s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Scott Kramer (UAVKC) ’ s, operation of my UAS, weighing less than forty (40) pounds and traveling at lower speeds within limit ed areas low to the ground will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Scott

Kramer (UAVKC) , respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,



# Scott Kramer13

13 Scott Kramer (UAVKC)

2618 Somerset Drive
Prairie Village, KS 66206

913

- 424

- 6155
scott@uavkc.com

Appendix A



### List of Aircraft

No. Make and Model Description Serial No. Registration

No.

1 DJI InspireONE Electric powered, 4 rotor, small
unmanned multirotor helicopter W13DCI05

040587 Pending



### 2 DJI S1000 Electric powered, 8 rotor small
unmanned multirotor helicopter Ordered,

Awaitin g arrival, will
update Pending

Aircraft 1: DJI INSPIRE ONE:
The operation of the DJI INSPIRE ONE (the flight controller operation manual is NOT explained
in this letter but can be found in Appendix C, Section 1).

1. Build Materials

I. Plastic

I I. Aluminum

III. Carbon Fiber

2. Motor Configuration

I. The DJI I nspire ONE achieves flight in a 4 motor quadcopter setup.

3. Payload
I. The DJI INSPIRE ONE flies it’s own light

- weight integrated camera.

II. Maximum All

- up weight

- 6lbs

4. Maintainin g the DJI INSPIRE ONE
I. Before each flight:
1. Check all hardware to ensure it is securely tightened.14

14 2. Check that the motor is level and locked in place.
3. Check the propeller to ensure it is tight and there are no visible signs of

cracks, stress.

4. C heck all wiring to motors, motor controllers, batteries, and flight controller for
signs of stress or frays.
5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mount s for signs of wear and tear.
Replace as necessary.
2. Remove motor controllers and visually inspect and check for damage. Replace

as necessary. 3. Remove flight controllers and visually inspect and check for damage. Replace
as necessary, and/or chips. R eplace the propeller if questionable.
4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix
before flying.
5. Check for updates to flight controller firmware. If available, install and perform
a minimum of 15 test flights before co nducting commercial work.

Aircraft 2: DJI S1000:
The operation of the DJI S1000 multirotor system are as follows (the flight controller operation
manual is NOT explained in this letter but can be found in Appendix C, Section 5).

1. Build Materials

I. Carbon Fiber

II. ABS Plastic

III. Stainless Steel Hardware

2. Motor Configuration
I. S1000 configuration utilizing 8 motors. The motors are configured with 1 motors per

arm, and a total of 8 arms.

II. In this configuration the DJI S1000 can handle up to two ( 2 ) motors failing and still be
able to fly.

3. Payload
I. The DJI S1000 will carry the Freefly Systems MoVI M5, M10, or M15 camera gimbal.

II. The cameras that will be flown on the DJI S1000 include, but are not limited to, Canon

5DMKIII, Canon 1D

- C, RED Epic, RED Dragon, and Sony FS700.

III. Maximum All

- up Weight

- 34lbs

4. Maintaining the DJI S1000
I. Before each flight:15

15 1. Check all hardware to ensure it is securely tightened.
2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of

cracks, stress.
4. Check all wiring to motors, motor controllers, batteries, and flight controller for
signs of stress or frays.
5. Check all navigational lighting to ensure it is properl y working.

II. After 45 hours of flight
1. Check all hardware to ensure it is securely tightened.
2. Check that all motors are level and locked in place.
3. Check all propellers to ensure they are tight and there are no visible signs of

cracks, stress, an d/or chips. Replace if any propeller is questionable.
4. Check all wiring to motors, motor controllers, batteries, and flight controller for
signs of cuts, fraying, cracks, and/or loose/cold solder connections. Fix before
flying.
5. Check all navigational lighting to ensure it is properly working.
6. Remove and check all motors and motor mounts for signs of wear and tear.
Replace as necessary.
7. Remove motor controllers and visually inspect and check for damage. Replace

as necessary. 8. Remove flight cont rollers and visually inspect and check for damage. Replace
as necessary. Check for updates to flight controller firmware. If available, install
and perform a minimum of 15 test flights before conducting commercial work.16

16 Appendix B

Personal Protocols/Controls/Flight Manual

Protocols and Controls

Scott Kramer (UAVKC) , Belton, Missouri.

Safety for public on the ground as well as manned aircraft above is an essential and utmost
consideration for aerial videos and photography. A s such, safety protocols and controls must be
implemented through pre

- flight preparation and during flight. Pre

- Flight Protocol:

- Check batteries with voltage meter to insure fully charged and ready for use.

- Inspect batteries for damage or leakage tha t may affect proper operation.

- Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or
unmanageable/uncontrolled flight.

- Check all GPS and Telemetry connections prior to flight.

- Check weather forecasts for wind advisory or other conditions that my impact flight.

- Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of
possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight du ration, estimated
elevation of flight, and any other pertinent information.

Inspect flight area for
Vicinity of public safety helipads/heliports
Vicinity of medical helipads/heliports
Vicinity of light poles vicinity or utility wires
Vicinity of trees flocks of birds that may cause interference and potential flight impact
Vicinity of any elevated obstructions that may pose potential flight hazard
Vicinity of roadways with moderate to heavy traffic that can distract the public
Gatherings that may attr act viewers optional point of control for best visual site of UAS
while in flight17

17 Emergency landing areas

Takeoff and landing

Inspect area for best and safest point of takeoff and landing

If in a subdivision or area that is within 150 feet of a res idential street, post warning
Sign(s)/stand(s) "Attention Aerial Photography In Progress, Remain Back 150 Feet "

Flight Protocol: takeoff and land from same location have alternate landing areas in case of
emergencies) remain alert to birds, sound or ai rcraft, curious public, and approaching vehicles
do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to
minimal elevation sufficient to acquire desired results remained prepared for emergency landing

at all ti mes pay attention to flight time

– warning meter for low voltage.

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut
down propulsion immediately following landing

– priority of disconnecting batteries

Post flig ht:

1. Disconnect battery to prevent accidental activation of propulsion system

2. Secure UAS in a safe location

3. Remove all warning signs from public access areas

4. Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

Manned aircraft is heard or seen in vicinity of flight
There is a public gathering within established safety boundary wanting to observe flight
Pilot is being distracted from focusing on flight and safety
Sudden change in weathe r (wind bursts)
Sudden increase in vehicular traffic in vicinity of flight
Birds enter into proximity of flight
Any sudden unsafe event that can cause collision, distraction or interruption of control

Safety for public on the ground as well as manned aircraft above is an essential and utmost
consideration for aerial videos and photography.

Maintaining a record of safe flight for FAA request and for determining future UAS safety
protocols is imperative.18

18 Sample Flight Log Recorded:

Date:________ ____________ Time: ______________

Location:___________________________________________________

Pre

- flight Inspection: ____ Yes _____ No

Comment: _________________________________________________

Elements

Proximity to airport: _____________ __ (attached map pinpointing approximate location of flight)

Airport notified: ____ Yes _____ No Phone Number: _______________________

Contact Name:___________________________________

Nearest major intersection: __________________

____________________________________

Proximity to medium traffic road: __________________________________________________

Proximity to heavily traveled roadway road: _________________________________________

Proximity to congested population: ________

________________________________________

Approx. Local Takeoff Time: ______________ GMT: __________

Weather Good Fair Poor Comment: _______________________________________________

Visibility Good Fair Poor Comment: _____________________________________

__________

Wind Speed: ___mph ___Gusts/MPH ___avg/MPH Comment : _________________________

Approx. Landing Time: ______________ GMT: __________

Estimated Elevation Ground level: ____________ Elevation Above Sea Level: _____________19

19 Safety Concerns: ____

__________________________________________________________

Additional Comments: __________________________________________________________

Scott Kramer (UAVKC) , Belton, Missouri.

Appendix C



### Aircraft Manuals

This Appendix includes UAS manufacturer's us er manuals, maintenance instructions, and illustrated parts catalogs. These manuals may be attached to the docket when submitted. Information regarding design, aircraft performance, fail

- safe features, operating limitations, normal and emergency procedures , and maintenance and inspection procedures is contained within the manuals and supplemental information documents listed below:

1. DJI Inspire Manual V1. 8 https://www.dji.com/product/inspire

- 1/download

2. Inspire 1 Maintenance Manual v1.0 https://www.dji.com/product/inspire

- 1/download

3. Intelligent Flight Battery Safety Guidelines v1.4 https://www.dji.com/product/inspire

- 1 /download

4. Inspire 1 Safety Guidelines https://www.dji.com/product/inspire

- 1/download

5. DJI S1000 Professional Manual V1.0 http://dl.djicdn.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf

For more information or questions about any of t he above listed information and manuals please

contact:

Scott Kramer

2618 Somerset Drive
Prairie Village, KS 66206

913

- 424

- 6155
scott@uavkc.com