Cody Anderson

April 28, 2015 

20215 12th Ave NW 

Shoreline, WA 98177

Cell (206) 708 3382

Home (206) 542 4558

Email: andersoncody@outlook.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 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. FAA-2014-0355 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 Cody Anderson, 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, mapping, crop surveying, inspections 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;

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, 

who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption 

would be required to comply with any conditions as set forth and in a similar fashion to the 

previously granted exemptions.

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.
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 Quanum Nova is a consumer grade small rotorcraft in the quadcopter configuration with an 

advertised weight of less than 875g 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 information is transmitted back to a ground 
control station allowing the operator and/or 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 15 minutes. The onboard flight controller will warn the pilot 

via external lighting and audio 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 10 minutes. This quadcopter is based 

on the DJI phantom and shares many characteristics. More information is available at this link, 

and in the manual (attachment 1)

http://www.hobbyking.com/hobbyking/store/__55108__Quanum_Nova_FPV_GPS_Waypoint_

QuadCopter_w_out_Battery_Mode_2_Ready_to_Fly_.html?gclid=CjwKEAjw3_ypBRCwoKqK

w5P9wgsSJAAbi2K9NSkysI55OVgNVctbHxh94_f5qrL1_FXNz5E_p4clyhoCHJ3w_wcB

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1­3 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.

The petitioner request that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without written 

approval from the FAA. The UA may not operate within 5 nautical miles of the 

geographic center of a nontowered 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.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is 

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption(s) should the need arise. Operations within class B airspace are not requested due to 

the lack of mode C transponder.

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. Crop 

surveying applications could lead to decreased use of pesticides and fertilizer and conservation 

of water as well as increased crop yields and decreased costs. 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. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. 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, e.g. 

COA Monthly Reports, or other means as required.

Conclusion
The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations”. 

The reason for such a general and broad based request is that the petitioner wishes to utilize a 

business strategy of horizontal integration and maximize economies of scope in order to 

capitalize on opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions The petitioner's business model is based on the idea of 

offering ad hoc small UAS services to individuals or companies who wish to employ these 

services as a safe, effective, and legal option to enhance their business or hobby. The petitioner’s 

own market research shows pent up demand for these services currently exists in the real estate 

market and other markets are just beginning to emerge. Although videography and photography 

are included in the request, the primary objective will be aerial survey of farm crops for precision 

agriculture. The petitioner has identified universities and other agencies that could benefit from 

the operation requested in this application.

A quick internet search will show that many are currently operating similar UAS in 

exactly this fashion without, it is assumed, FAA authorization. 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 8

years of experience in the radio control model aircraft hobby.

Respectfully submitted,

Cody Anderson