Private and Confidential

Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , Las Vegas, Nevada

- Section 333 Exemption Petition

DATE :3/ 9 /2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave

SE Washington, DC 20 590

Re : Exemption Request Section 333 of the FAA Reform Act of the 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); 9 1.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam, I

, Doron Benbenisty owner of CRI Counter Terrorism Training School

, Inc.

, 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, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. am the owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Doron Benbenisty and CRI
Counter Ter rorism Training School, Inc. , may operate my small ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal Aviation Administration (“FAA”).

Following exemption and approval by the FAA, I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , will primarily use my professionally built DJI phantom 3 , DJI inspire

1 ,2,3 X CRAFT X PlusOne

, Yuneec Typhoon and Yuneec Tornado series UAS equipped with cameras for the following applications , However not limited to: Cl osed

- Set Film Operations on Film and 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 Searc h and Rescue (SAR) missions for state and local agency’s, education, agricultural inspections and building ,construction zone inspections. UAS Flight education, recreational events, higher education, competitions and instructions. Surveillance, UAS training for government agencies, military, law enforcement, federal, security

, bodyguard personnel, m ar i ti m e s ecurity, corporate security, life saving UAS operations, commercial UAS applications and other uses.2

2 I

, Doron Benbenisty and CRI Counter Terrorism Trai ning School, Inc. ’s exemption request would permit the operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS’s
for the development of community and government use videos as well as UAS flight and commercial

use instructions and tra ining 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 vehicular traffic. Currently, similar lightweight, remo te 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 fo r specific video and photography usage by sharing information with the FAA as I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc.

, record flight data and other pertinent information gained through permitted flight operations.

W e intend to add a UAS flight programs for our Nevada Commission on Post Secondary Education approved vocational school. As a licensed and approved vocational school , w e ask to be authorized to conduct UAS flight trainin g for our students t o ensure compliance with FAA regulations and codes . We recognize the great importance that a UAS pilot comprehend the field of aviation and the various risks that UAS’s po se

. This is why we intend to offer our training programs in the following manner: UAS flight operation s P athway f or FAA approved ground school an d test preparation

P athway for sport pilot certification (through a third

- party company)

W e believe that , in this manner, our students will understand and will be prepared properly as commercial UAS pilots and operators acco rding to UAS FAA regulations.

In ad dition, granting me

, Doron Benbenisty and CRI Counter Terrorism Training School, Inc.

, an 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 safe 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, UAS flight training, Search and Rescue, land/trusts inspections, agricultural 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, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below, I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s to aid academic community awareness, to benefit/stimulate

attraction to the greater M etro Las Vegas ar ea a nd 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, heightening 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.3

3 Contact Information: Doron Benbenisty, CEO CRI Counter Terrorism Training School, Inc. Las Vegas, NV 89030
Phone: 702

– 222

– 3489
Email: CRI@CRItraining.com

II. The Specific Sections of Title 14 of t he Code of Federal Regulations f rom w hich Doron Benbenisty and CRI Counter Terrorism Training School, Inc. r equest e xemption s are:
1 4 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Doron Benbenisty and CRI Counter Terrorism Training School, Inc.

s eeks and the reason he seeks such relief : I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , 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, Doron Benbenisty or CRI Counter Terrorism Training School, Inc. , contemplated 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 national airspace system as it is in th e public’s

interest to do so. I

, Doron Benbenisty and CRI Counter Terrorism Training School, Inc.

, understand that ultra lightweight UAS meets the definition of “small unmanned aircraft” as

d efined in Section 331 and therefore the integration of my ultra light weight UAS is expressly 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 r ules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered 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, w hether the
UAS will be operated by line of sight. 112 P.L. 95 § 333 (a).4

4 Each of these items reflect in favor of an exemption for me, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. My UAS’s utilize eight (8) or less rotating propellers for balance,

co ntrol 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 indicat or 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and battery left with approximate time 11) Loiter and circle mode. 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, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , consider safety paramount with each flight. My small
unmanned aircraft i s 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 financial 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.

With three (3) modes to choose from, I will fly with in the safest modes in order to complete the videos for aerial videography/photography . I will ch oose the safest, most reliable and
stable mode in order to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed to slowly descend to point of takeoff and / or to land at point of
launch after as cending 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, Doron Be nbenisty and CRI Counter Terrorism Training School, Inc. , will not operate the 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 on location, condit ions 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 m ay 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, includi ng manned aircraft, within the flight zone of the UAS. Utilizing battery5

5 power rather than combustible fuels, flights generally last between three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (150) feet. (3 )Smart 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, Doron Benbenisty and CRI Counter Terrorism Training School, I nc. will 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 remain 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 re placement 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 simulating 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 and response reflex time. All for the sake of safety.

I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , a re extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft and will not “creat e 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. Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s UAS, will
be used in hobby flight, ha ve a demonstrable safety record and does not pose any threat to the general public or national se curity.

IV. How Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s r equest will benefit the public as a whole : Aerial videography for geographical awareness, education and flight training , search and rescue, land management, structure ins pections and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. Our vocational school graduates will be able to pursue an exciting career and therefore will increase employment in our country. In a ddition 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 o wners and lower budget companies from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that the Las Vegas community has experienced in the past with military aircraft, medical helicopters, and

news helicopters crashes within the C ity of Las Vegas Each resulting in loss of life. Each with combustible fuel that exploded and burned on impact , p olice helicopters have made emergency hard landings within city limits. I

, Doron Benbenisty and CRI Counter Te rrorism Training School,

Inc. 's, UAS poses no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to6

6 integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting m e
, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefit s in and around the metro Las Vegas 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 full size helicopter or fixed wing air craft; which are heavy, contain combustible fuel and can cause catastrophic 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

, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the m etro Las Vegas and surrounding community for companies looking to relocate or build around the Las Vegas metro area as well as individuals looking to relocate for career advancement through academic and geographical
awareness. Both of which serve as a stim ulus to the community.

V. Reasons Why Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , 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 protocols for Realtors, land and structured owners. For development in cooperation with the

FAA. In addition I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. , submit the following representations of enhancements to current aerial videography and photography: My UAS’s weigh less than 7 pound s complete with a an integrated ultra

- light w eight camera 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 3

- 30 minutes per flight; I land my UAS prior to manufacturer recommended minimum l evel 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 which include remaining battery vo ltage, distance, altitude, and any anomalies that may occur during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz

- 2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725G hz

- 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 pilot7

7 is lost; I actively record and analyze flight data through the DJI Inspire 1 and DJI phantom 3 flight controller app to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from p ower lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary 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. Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note tha t 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 rescue. While
the sa fety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra lightweight UAS. First, the potential loss of life is di minished 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 small 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 they are focu sed 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 Summary The F AA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness cer tificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’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 both 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 areas such as airports and dense populations. Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s current and projected UAS's 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 will be applicable in the form contemplated by the FARs, this Regula tion is inapplicable.

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 Regulation is inapplicable. An8

8 equivalent level of safety will be achi eved 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, 9299, 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 ai rcraft 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 certifications and registrations by

me, Doron Benbenisty and CRI Counter T errorism Training School, Inc.

.

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” nu mber has been given.

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

- commercial operations. I, Doron Benbenisty
and CRI Counter Terrorism Training School, I nc.
, t he UAS Pilot in Command 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 alt itude greater than 300fclose AGL; safely below the standard of 400 AGL. I, Doron Benbenisty and CRI Counter Terrorism Training School, Inc.

, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equiva lent to or below those in relation to minimum safe altitudes. Given the 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): Maintena nce Inspections.1,2,
Manual
The above

- cited Regulations require, amongst other things, 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 pa ragraph (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 our
, Doron Benbenisty and CRI
Counter Te rrorism Training School, Inc. 's, UAS. However, as a safety precaution I inspect my UAS before and after each flight.9

9 A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals 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 UAS permits exemption from Part 21 because our
, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness
certificate re quirement under both 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 areas such as airports and dense populations. My UAS meets or exceeds 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 will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equiv alent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates a nd curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. 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 our
, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. '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
reloca te, rebuild, reevaluate and to find in the metro Las Vegas area.

F. 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 wei gh less than 55 pounds (25kg), including energy source(s)

and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.10

10 3. Flights must be operated at an altitude of no more than 500 feet above ground level
(AGL), as indica ted 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 visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unai ded by any device other
than corrective lenses, as specified on the PIC's state driver’s license.

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

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere

in this operations manual, the conditions and limitations herein take precedence and

must be fo llowed.
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 condition 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 included in the preflight inspection. All

maintenance and alterations must be properly documented in the aircraft rec ords.
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 P IC who conducts
the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements. W hen unavailable, aircraft
maintenance/component/overhaul, replacement, and inspection/maintenance

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

a. Actuator s / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries11

11 g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if us ed)

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 1 4 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 motion picture filming (or similar
operations), the PIC must have accumulated and logged, in a manner consistent with 14
CFR § 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 UAS 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 conducted under this grant of exemption to
accomplish the required flight cycles and flight time. During training, pr oficiency, 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 o perations conducted for the purpose of motion picture filming (or similar
operations), the PIC must have accumulated and logged, in a manner consistent with

14 CFR § 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, experience

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

- participants, and the PIC must operate the UAS

wi th appropriate distance from non

- participants in accordance with 14 CFR § 91.119.12

12 13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual

observer (VO) must have successfully completed a qualification process, as outl ined 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 mus t be documented and made

available to the Administrator upon request.

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

- approved and

- qualified pilot

mu st be successfully completed and documented. This documentation must be available for

review upon request by the Administrator. Because the knowledge and airmanship test
qualifications have been developed by the operator, and there are no established pract ical
test standards that support a jurisdictional FAA FSDO evaluation and approval of company

designated examiners, the petitioner will conduct 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.

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 operations. Because these procedures are specific to
participating persons, no further FSDO or Aviation Safety Inspe ctor (ASI) approval is
necessary for reductions to the distances specified in the petitioner’s manuals. This is

consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1

Issue a Certificate of Waiver for Motion Picture and Te levision 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 b e reduced to no less than 200 feet

if it would not adversely affect safety and the Administrator has approved it. For example, an
equivalent level of safety may be determined by an aviation safety inspector’s evaluation of
the filming production area to no te terrain features, obstructions, buildings, safety barriers,13

13 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 security 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 accordance with

the operator’s manual.

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

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

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certific ate of Waiver or
Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator 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 with 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings mus t be as

large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS

maintenance, preventative 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 manufacturer Safety

Bulletins.

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 requirement: The preflight inspection must account for all discrepancies, i.e.

inoperable components, items, or equipment, not co vered in the relevant preflight inspection

sections of the operator’s manual.14

14 27. Before conducting operations, the radio frequency spectrum used for operation and
control of the UAS must comply with the Federal Communications Commission (FCC) or

other app ropriate government oversight agency requirements.
28. At least three days before scheduled filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction

over the area of proposed f ilming. The 3

- day notification may be waived with the
concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming

produc tion 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 conduct the filming production event; the

list of those who gave permission must be made available to the

inspector upon reque st.
g. Signature of exemption

- holder or representative

h. A description of the flight activity, including maps or diagrams of any 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 of the UAS any time the aircraft is operating. These

documents must be made available to the Administrator or any law enforcem ent 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 visual meteorological conditions (VMC). Flights
under special visual flight rules (SVFR) are not authorized.15

15 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.

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 center of a non

- towered

airport as denoted on a current FAA

- published aeronautical chart unless a letter of

agreement with that air port’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 site: 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.

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

Granting my, Doron Be nbenisty and CRI Counter Terrorism Training School, Inc. ’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventiona l video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. I, Doron Benbenisty and CRI Counter Terrorism Traini ng School, Inc. , 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 currently accepted means and methods for safe flight. Formal col lection 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 board my, Doron Benbenisty and CRI Counter Terrorism Trai ning School, Inc. ’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Doron Benbenisty and CRI Counter Terrorism Training School, Inc. ’s, operation of my UAS, weighing less than forty (40) pounds and trave ling at lower speeds within limited areas low to the ground will provide an equivalent level of safety as that achieved under current FARs. Accordingly

, I Doron Benbenisty
and CRI Counter Terrorism Training School, Inc. , respectfully request that the FAA g rant my16

16 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,

Doron Benbenisty and CRI Counter Terrorism Training School, Inc. 1727, Stocker St., North Las Vegas, Nevada, 8903017

17 10

Appendix A



### List of Aircraft

No. Make and Model Description Serial No. Registration
No.
1 DJI inspire 1 Electric powered, eight rotor’s or less

small unmanned multi

- rotor helicopter 

### Pending Pending

2 DJI phantom 3 Electric powered, eight rotor’s or
less small unmanned multi

- rotor helicopter 

### Pending Pending

3 CineChopper Rpid Pro
X Electric powered, eight rotor’s or
less small unmanned multi

- rotor helicopter 

### Pending Pending

4 X CRAFT X PlusOne Electric powered, 3 rotor’s small
unmanned multi

- rotor helicopter 

### Pending Pending

5 Yuneec Typhoon, Electric powered, four rotor’s small
unmanned multi

- rotor helicopter 

### Pending Pending

6 Yuneec Tornado Electric powered, six rotor’s or less

sm all unmanned multi

- rotor helicopter 

### Pending Pending

DJI inspire 1 The operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials
I. Plastic
II. Aluminum

2. Motor Configuration I. The DJI INSPIRE ONE flight in a 4 motor quadcopte r setup

.,

3. Payload

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

- weight integrated camera.

II. Maximum All

- up weight

- 6lbs18

18 4. Maintaining the DJI INSPIRE ONE I. Before each flight: 1. Check all hardware to ensure it is securely tightened.
2. Check that the m otor 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 5. Check all navigational li ghting to ensure it is properly working.

II. After 45 hours of flight 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 2. Remove motor controllers and visually inspect and check for damage. Replace as nece ssary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.
5. Chec k for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.

Appendix B

2. DJI phantom 3 The operation of the DJI Phantom 3 system is as follows.

1. Build Materials

I. Plastic
II. Aluminum

2. Motor Configuration I. The Phantom 3 flight in a 4 motor quadcopter setup. ,

3. Payload I. The Phantom 3 it’s own integrated camera.

II. Maximum All

- up Weight

- 4lbs

4. Maintaining the Phantom 3 I. Before each flight:
1. Check a ll 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, batterie s, and flight controller for signs of 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight19

19 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 2. Remove motor con trollers 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. Replace if propeller is questionable. 4. Check for cuts, fraying, crack s, 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 conducting commercial work.

APPENDIX C CineChopper Rpid Pro X The ope ration of the CineChopper X 8 multirotor system are as follows

1 . Build Materials
I. Carbon Fiber
II. ABS Plastic
III. Stainless Steel Hardw are

2. Motor Configuration

I. X8 configuration utilizing 8 motors (KDEDirect 5215

- 435KV) which is powered by the Herkules III motor controller. The motors are configured with 2 motors per arm, one top and one bottom spinning in a counter

- rotating direct ion. We have tested this situation
and can confirm it works as described.

II. In this configuration the CineChopper x8 can handle up to four (4) motors failing and still be able to fly.

3. Payload I. The CineChopper x8 will carry the Freefly Systems MoV I M5, M10, or M15 camera gimbal. II. The cameras that will be flown on the CineChopper X8 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 CineChopper x8 I. Before each flight: 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 cra cks, stress, and/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 as20

20 necessary. 7. Remove motor controllers and visually inspect and check for damage. Replace as

necessary. 8. Remove flight controllers 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.

Appendix D

4. X CRAFT X PlusOne

I. The X PlusOne can take off, hover, and land like a traditional multi

- rotor, but that’s where the similarities stop. The key differentiator is this: In place of the quadcopter frame is an upward facing wing. This allows the X Plu sOne to pitch over 90 degrees and fly nose

- first at over 60 mph (100 km/h), twice as fast as a traditional quadcopter! Flight control is handled by varying motor speed to provide pitch, roll, and yaw control, even in forward flight mode. There are no
tradi tional flight control surfaces on the X PlusOne. Thereby saving weight and complexity and ensuring the overall design remains clean and efficient.

II. Speed & endurance Speed isn’t normally associated with most of the drones out there. We’ve changed that! Ever
heard of a multi

- rotor taking great aerial shots at 100 km/h? Well, now you have! What’s more? Its battery charge is approximately 20 min

III. Hover The X PlusOne is a Pro when it comes to precision stabilized hover. Its designed for the control algorithms so the craft remains rock solid, even in windy conditions.

IV. Specifications
Dimensions: 32.5 x 19 x 14 inches Flying weight: 2.9 lbs

Patent

- pending hybrid quadcopter flying wing design Speed range: hover

– 60 mph (100 kph) Flight time: Approx 20 minutes Breaks down for easy transportation Optional 2

- axis brushless gimbal for GoPro Optional fixed GoPro mount Optional fixed micro DV camera Optional GoPro Hero HD action camera

V. Maintaining the X CRAFT X PlusOne I. Before each flight:
II. After 45 hours of flight 1. Check all hardware to ensure it is securely tightened.21

21 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, and/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 controllers and visual ly 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.

Appendix E . Personal Protocols/Controls/Flight Manua l Protocols and Controls

Doron Benbenisty and CRI Counter Terrorism Training School, Inc. Las Vegas, Nevada

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As s uch, 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 that 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 duration, 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 wires22

22 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 be distracted public Gatherings that may attract view ers optional point of control for best visual site of UAS while in flight 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 residential 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 aircraft, curious public, and approaching vehicles do not allow anyone to engag e 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 times pay attention to flight time

– warning meter for low voltage.

Set volta ge 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 flight:

1. a) Disconnect battery to prevent accidental activation of propulsion system

2. b) Secure UAS in a safe location

c) Remove all warning signs from public access areas 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 fli ght 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 weather (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 an d photography.23

23 Maintaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative.24

24 Date:____________________ Location:___________

________________________________________

pre

‐ flight Inspection:
O Yes O No

Comment: _________________________________________________

Elements

Proximity to airport: _________________ (see attached map pinpointing approximate location of flight)

Airport notified: No Yes

Date: _ ______________ Time: ______________

Phone Number: _______________________
Contact Name: _

__________________________________

Nearest major intersection:

______________________________________________________________

Pr oximity to medium traffic road:

_________________________________________________________

Proximity to heavily traveled roadway road:

_________________________________________________

Proximity to congested population:

_________________________________ _______________________

Approx. Takeoff Time: GMT:

Weather Good Fair Poor Comment: Visibility Good Fair Poor Comment:

Wind Speed ___mph ___Gusts/MPH ___ A verage /MPH Comment:

Approx. Landing Time: GMT: Estimated Elevation Ground level: Safety Conce rns: Additional Comments:
Sea level:

First aid kit:25

25 Appendix ' F '

Aircraft Manuals

This Appendix includes UAS manufacturer’s, user manuals, maintenance instructions, and illustrated parts catalogs. If available by the manufacturer

, 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 suppl emental information documents listed below:

1. DJI Inspire Manual V1.0
2. Inspire 1 Maintenance Manual v1.0
3. Intelligent Flight Battery Safety Guidelines v1.4 4. Inspire 1 Safety Guidelines 5. Phantom 3 Professional Manual V1.0
6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)
7 . XCRAFT X PlusOne Manual
8

. Yuneec Typhoon ( G

, Q500 ,Q500+ )
9

. Yuneec Tornado ( CGO 4 , H 920 )

For more information or questions about this manual please contact:

CRI Counter Terrorism Tr aining School, Inc. 1727 Stocker St. N., Las Vegas, NV, 89030 phone: 702

– 222

– 3489

email: CRI@CRItraining.com