1

November 4, 2015

Shayne L. Medore 201 Kathy Circle Linden, MI, 48451 Cell: 810

- 569

- 5686 Email: shayneleemedore@gmail.com

U.S. Department of Transportation , Docket Operations Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
RE: Exemption Request Section 333 of the FAA Reform Act of 2012 References: 1) FAA Exemption No. 11410, Regulatory Docket No. FAA

- 2015

- 0186 in the matter of the petition of RALPH J. APEL 2) FAA Exemption No. 1 1341, Regulat ory Docket No. FAA

–2015

–0037 in the matter of the petition of BOB SOKOLER 3) FAA Exemption No. 11728 Regulat ory Docket No. FAA

- 2015

- 0850 in the matter of the petition of ALON SICHERMAN 4) FAA Exemption No. 13040 Regulatory Docket No. FAA−2015− 2773 in the matter of the petition of Manuel P Heredia III

Dear Sir or Madam, Please accept this Section 333 exemption application for your consideration in accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 o f the FAA Modernization and Reform Act of 2012, I Shayne L. Medore, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§2

**61.113 (a) & (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1 ), 91.405(a), 91.407(a)(1), 91.409(a)(1)**  **& (2), and 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, cinemato graphy, 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 aircra ft. 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 suc h operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The petitioner seeks exemption from the above

- mentioned FARs for the following reasons; **61.113(a) & (b)** The petition er requests relief in order to facilitate the utilization of pilots, who hold a Sport 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 pre viously granted exemptions. **91.7(a)** Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow petitioner to determine that the DJI Phantom and Phantom 3 Professional UASs are in airworthy condition prior to every flight by ensuring that the UAS s are in compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI Phantom and Phantom 3 Professional Instruction Manual). Petitioner seeks the requested relief because the DJI Phantom and Phantom 3 Professional UASs do not requir e an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, petitioner will ensure that the DJI Phantom and Phantom 3 Professional UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom and Phantom 3 Professional Manual) prior to every flight, and further, determine that the aircraft is in condition for a safe flight. **91.119(c )**  The petitioner requests waiver to allow reasonable and responsible op erations in areas of subdivisions and neighborhoods if required.
**91.121** This is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric s ensor for altitude information. **91.151(a)(1)** The UAS provides ba ttery power remaining in percent to the PIC. The UA batteries provide approximately 13 minutes for Phantom and 23 Minutes for Phantom 3 Professional, of powered flight. Information provided in the operating documents discusses procedures regarding remainin g 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.3

**91.405(a); 91.407(a)(1); 91.40 9 (a)(1) & (2); 91.417(a) & (b)**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, the petitioner requests relief from these Sections because the DJI Phantom and Phantom 3 Professional UASs do not require an airworthiness certificate. The DJI Phantom and Phantom 3 Professional UASs me et the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, the petitioner will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI Phantom and Phantom 3 Professional Instruction Manual). Furthermore, the petitioner will document and maintain all maintenance records for the DJI Phantom and Phant om 3 Professional UASs.

**The UAS** The DJI Phantom 3 Professional is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 46 Ounces (1280g) designed primarily to carry aloft a high definit ion camera. It has an advertised maximum speed of less than 30 knots (16m/s) and a maximum climb rate of less than 1200 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 utilize s 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. R eal 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 fai lsafe 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 between 13

- 23 minutes depending on flight conditions. 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 10 minutes. More information is available on http://www.dji.com/product/

**Public interest** Use of the UAS in lieu of a manned aircraft would e nhance 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 econom ic 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 l evel videography/photography. Aerial photography is a valuable4

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 wat er 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 Mo nthly 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 busines s 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. In addition the petitioner is an active Licensed Private Pilot, Certificat e Number 3221316 with over 20 years flying experience as a PIC. The petitioner also has over 30 years of experience flying high powered model aircraft of all varieties but not limited to drones including instruction at his AMA local flying field. It is m y belief that with my extensive background in aviation, flying and RC experience, this exception would provide a safe, environmentally friendly, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery

.

Respectfully submitted Shayne L. Medore

**GLOSSARY OF ABBREVIATIONS** AGL Above Ground Level AMA Academy of Model Aeronautics5

AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations
COA Cert ificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link MSL Mean Sea Level NAS National Airspace System
NOTAM Notice to Airman PIC Pilot In Comma nd
Se ction 333 FAA Modernization and Reform act of 2012 (FMRA)

SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Sight VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing