John Baer September 17, 2015

PDM Pictures, Inc. 25 Banbury Ct.

Trenton, NJ 08691

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

**Re: Petition of Ex emption Pursuant to Section 333 of the FAA Modernization** 

**and Reform Act of 2012**

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, John Baer, owner PDM Pictures, Inc., pr ivate pilot and owner/operator of small unmanned aircraft systems hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the DJI Phantom 2 and the DJI 550 for the following: (1) Aer ial photography and/or video for use in real estate, construction and architecture: (2) Aerial photography and/or video for television, public events, cinematography and news gathering; (3) Aerial video to provide live video assistance with law enforcement and search & rescue operations only when the local authorities or government has requested it by contract or donation. (4) Training persons in the safe use and operations of a small unmanned aerial systems.

Thank you,

John Baer

President
PDM Pictures, Inc.**I. DESCRIPTION OF PETITIONER** 

PDM Pictures, Inc.

John Baer

-

President 25 Banbury Ct.

Trenton, NJ 08691

Phone: 609

- 947

- 7205 Email: exnikon@aol.com

John Baer, President of PDM Pictures, Inc., is a professional photographer for over 25

years, a private pilot for over 15 years and a remote control pilot for over 7 years. PDM Pictures, Inc. primarily provides photographic and video services to the construction and real estate industry.

**II. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED** 

PDM Picture s, Inc. requests an exemption from the following regulations:

- 14 C.F.R. Part 21, Subpart H and 14 C.F.R. § 91.203

- 14 C.F.R. Part 27

- 14 C.F.R. § 45.23(b), 45.27(a) and 91.9(c)

- 14 C.F.R. § 61.113

- 14 C.F.R. § 91.9(b)(2)

- 14 C.F.R. §§ 91. 203(a) and (b)

- 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b)

- 14 C.F.R § 91.7(a)

- 14 C.F.R. § 91.103

- 14 C.F.R. § 91.109(a)

- 14 C.F.R § 91.119;

- 14 C.F.R § 91.121;

- 14 C.F.R. § 91.151(a

**III. STATUTORY AUTHORITY FOR R**  **EQUESTED EXEMPTIONS**

This petition for exemption is submitted in accordance with Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (Reform Act). Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.” Pursuant to the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft system (UAS) where it does not create a hazard to users of the National Airspace System (NAS) or the public or pose a threat to national security based on the following considerations: (1) The size, weight, speed and operational capability of the UAS; (2) Operation of the UAS in proximity to airports and populated areas; and (3) Operation o f the UAS within visual line of sight of the operator.Furthermore, the Reform Act grants the FAA Administrator general authority to grant

exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a requested exem ption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules. See 14 C.P.R. § 11.81.

**IV. DESCRIPTION OF PROPOSED OPERATIONS OF PDM PICTURES, INC.** 

PDM Pictures, Inc. intends to fly the DJI Phantom 2 and DJI 550. These UAS's will be flown with strict adherence to all operating and safety manuals.

A. DJI PHANTON 2 1) DJI is a world leader in innovation and manufacturing of UAS. DJI has a well

known commitment for creating small, safe, easy to operate and efficient lightweight multi

- rotor battery powered aircraft. 2) Specifications of the DJI Pha ntom 2: a) 350mm inches (diagonal

- motor to motor) b) Maximum weight (including payload): 3.1 lbs. c) Maximum horizontal Speed 29 Knots: (15 m/s) d) Maximum flight time: 20 minutes e) RF control range: 1,000 meters f) Quad

- rotor electric propulsion system g) Safety rotor guards h) Power source is a removable/rechargeable battery system i) Red and green LED navigation/information lights beneath the aircraft that differentiate front/rear and alert the operator of loss of GP S signal j) DJI Naza

- M V2 intelligent flight control system k) Global positioning system (GPS) l) Digital compass m) 2.4 GHz (flight controller) n) 5.8 GHz (video and data communication) o) All RF components are FCC certified p) Digital camer

a and camera gimbal 3) DJI Phantom 2 Safety Features: a) Equipped with safety rotor guards to prevent/reduce injury/damage in the event of accidental impact with persons or property. b) Onboard DJI Naza

- M V2 Intelligent Flight Control System with b uilt

- in GPS providing accurate position information. c) Real

- time flight telemetry date to include: altitude, flight speed,

distance from the pilot, number of GPS satellites in view and battery level power for flight. d) When the battery leve l is reduced to below 25% the DJI Phantom 2 will begin an automatic descent and landing. Upon landing the motors willstop, the Phantom 2 will not crash upon inadvertent exhaustion of its

power source. e) An on

- screen display provides real time l ocation, heading relative to the pilot, altitude and power level to the PIC. f) The intelligent Flight Control System coupled with the GPS position information onboard the DJI Phantom 2 provides the ability for the pilot

to auto

- hover in positio n with compensation for wind and drift and at the discretion of the pilot. g) The intelligent Flight Control System coupled with the GPS position information onboard the DJI Phantom 2 provides the ability for the pilot

to command the UAS to auto matically return to its point of departure. h) The DJI Phantom 2 will return to its point of departure, land and shut down the motors automatically in the event of a loss of RF control.

B. DJI 550 1) DJI is a world leader in innovation and manufact uring of UAS. DJI has a well

known commitment for creating small, safe, easy to operate and efficient lightweight multi

- rotor battery powered aircraft. 2) Specifications of the DJI 550: a) 550 mm (diagonal

-

motor to motor) b) Maximum weight (includ ing payload): 5.4 lbs. c) Maximum horizontal Speed 29 Knots: (15 m/s) d) Maximum flight time: 8 minutes e) RF control range: 1,000 meters f) Hex

- rotor electric propulsion system g) Power source is a removable/rechargeable battery system h) Blue and white LED navigation lights that differentiate front/rear i) DJI Naza

- M V2 intelligent flight control system j) Global positioning system (GPS) k) Digital compass l) 2.4 GHz (flight controller) m) 5.8 GHz (video and data communication) n) All RF components are FCC certified o) Digital camera and camera gimbal 3) DJI 550 Safety Features: a) On board DJI Naza

- M V2 Intelligent Flight Control System with built

- in GPS providing accurate position information. b) Real

- time flight telemet ry date to include: altitude, flight speed,

distance from the pilot, number of GPS satellites in view and battery level power for flight. c) When the battery level is reduced to below 25% the DJI 550 will begin an automatic descent and landing. Upon landing the motors will stop, the DJI 550 will not crash upon inadvertent exhaustion of its power source. e) An on screen display provides real

- time location, heading relative tothe pilot, altitude and power level to the pilot/operator. f) The intelligent Flight Control System coupled with the GPS position information onboard the DJI 550 provides the ability for the pilot to auto

hover in position with compensation for wind and drift and at the discretion of the pilot. g) The int elligent Flight Control System coupled with the GPS position information onboard the DJI 550 provides the ability for the pilot to command the UAS to automatically return to its point of departure. h) The DJI 550 will return to its point of departu re, land and shut down the motors automatically in the event of a loss of radio control.

These two UAS's are extremely similar in operation, both run on Naza

- M V2 Intelligent Flight Control System and both are controlled by the same radio transmitter, t he only

real difference is the additional two motors in the DJI 550 which allows for an extra 2.3 lbs of payload. The highly advanced control systems, electronics and engineering will allow the UAS to safely operated in the NAS and will not create a hazard to the public.

C. OPERATIONS OF THE DJI PHANTOM 2 & DJI 550 1. Prior to each flight, the pilot in command (PIC) will inspect the UAS to ensure it's in a condition for safe flight. If the inspection reveals a condition that affects the safe operatio n of the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The remote control radio will be included in the preflight inspection.

2. The PI C will have a private pilot's license and current 3rd Class medical certificate and will have sufficient experience and training to safely fly the UAS 3. Flights will be operated at or below 200 feet AGL. 4. The UAS will weigh less than 10 lbs.

5. The UAS flight speed will not exceed a speed of 29 knots. 6. The UAS will be operated within Visual Line of Sight (VLOS) of the PIC at all times. This requires the PIC to use human vision unaided by any device other

than corrective lenses.

7. Before conduc

ting any flight operations, the radio transmitter will be inspected to comply with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 8. The PIC will ensure that no persons in open areas are allowed wi thin 100 feet of the aircraft except those consenting to be involved and are necessary for the aerial photography operations. 9. UAS operation will be completed prior to battery levels reaching 25% capacity. 10. The UAS will remain clear and yield the right of way to all other manned operations and activities at all times. 11. No night time UAS operations will be conducted. 12. All operations will be conducted under visual meteorological conditions (VMC). No flight will be authorized under special v isual flight rules (SVFR).13. The UAS will not be operated from any moving device or vehicle. 14. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS will not operate within five nautical miles of the g eographic center 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. The letter of agreement with the airport management

will be made available to the Administrator upon request. 15. A briefing will be conducted in regard to the planned operation prior to each flight. It will be mandatory that all personnel who will be performing duties with in the boundaries of the safety perimeter be present for t his briefing and it will include a comprehensive flight plan and safety information regarding the flight.

16. Contingency plans will be in place to safely terminate flight if there is a loss of communication between the PIC and the observer(s).

17. E ach flight will be recorded in the PIC's Pilot Log Book.

**V. SPECIFIC REGULATIONS FROM WHICH EXEMPTION IS REQUESTE** 

PDM Pictures, Inc. seeks an exemption from several provisions of 14 C.F.R. Parts 21, 27, 45, 61, and 91 for purposes of conducting the reque sted operations using the DJI Phantom 2 and the DJI 550. Listed below are the specific sections for which exemption is sought, and the operating procedures and safeguards that will be followed by PDM Pictures, Inc. to ensure a level of safety at or better than the rules from which exemption is sought.

**A) 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)** The FAA has stated that no exemption is needed from this section if a finding is made

under the Reform Act that the U AS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met, and therefore no exemption is needed. If, however, the FAA determines that there are some

characteristics of the ch osen UAS that fail to meet the requirements of the Reform Act, then an exemption is requested. **Equivalent Level of Safety:** The UAS's listed in Section IV (A and B) are safe when taking into account its size, weight, speed, and operational capability. Both UAS's weigh less than 10lbs pounds and will be flown at speeds of less than 29 knots, in visual line of sight of the operator, and outside controlled airspace. Additionally, they do not carry pilots, passengers, explosive materials, or flammable liquid f uels and will not pose a threat to national security. PDM Pictures, Inc. will also provide the FAA with advance notice of all operations via Notice to Airman (NOTAM) in coordination with the local Flight Standards District Office (FSDO). The proposed opera tions will be at least as safe as, or safer than, conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

**B) 14 C.F.R. Part 27 Airworthiness Standards: Normal Categor y Rotorcraft**  14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certificationof normal category rotorcraft. To the extent the UAS's listed in Section IV (B and C)

would otherwise require certification under Part 27, PDM Pictures, I nc. seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

**C) 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requiremen**  **ts** 14 C.F.R. §45.23(b), when marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also dis play on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport, “experimental,” or “provisional,” as applicable. 14 C.F.R. § 4 5.27(a) states: Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. 14 C.F.R. § 91.9(c) states: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft, “have identification (N

- Num ber) markings in accordance with 14 CFR part 45, Subpart C if the markings are as large as practicable.” **Equivalent Level of Safety:** PDM Pictures, Inc. will mark their UAS's with an assigned N

number in a prominent area on the UAS with markings that are a s large as practicable.

**D) 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations** PDM Pictures, Inc. seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if the pilot is carrying passengers or cargo for hire. Whi le the DJI Phantom or DJI 550 will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA

- 2014

- 0352, the FAA determined that the unique characteristics of UAS operation outsid e of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot certificate and a Class II medical certificate. The FAA has also determined that the required knowledge for a commerci al pilot covers the same fundamental principles as a private pilot. The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanshi p skills acquired through UAS

- specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing.” **Equivalent Level of Safety** : The restrictions PDM Pictures, Inc. has placed on its operations meet or e xceed the restrictions similarly imposed on Astraeus Aerial in FAA

Docket No. FAA

- 2014

- 0352. PDM Pictures, Inc. will operate in areas away from people and property who are not involved in the UAS flight operation. The aircraft will be flownwith VLOS at or below 200 feet AGL and in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. The PDM Pictures, Inc. 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. PDM Pictures, Inc. also adheres to the Academy of Model Aeronautics (AMA) National Model Aircraft Safety Code. All PDM
Pictures, Inc. pilots and visual observers are trained on the standards of this safety code.

**E) 14 C.F.R. § 91.7(a): Civil Aircr aft Airworthiness**  PDM Pictures, Inc. seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, PDM Pictures, Inc. requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H.

**F) 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. §§**  **91.203(a) and (b): Carrying Civil Aircraft Certification and Registration** Pursuant to 14 C.F.R. § 91.9(b)(2): (b) No person may operate a U.S.

- registered civil

aircraft

- ... (2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1)An appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) o f this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

PDM Pictures, Inc. does not request an exemption from this section but instead notifies

the FAA that the UAS flight manual, registration certificate and other documentation will be kept with the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitutes full compliance.

**G) 14 C.F.R. § 91.103: Preflight Action**  PDM Pictures, Inc. seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information

contained in the FAA

- approved Flight Manual on board the air craft. While the aircraft will not have a Flight Manual on board, the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an

FAA

- approved Flight manual is required. **Equivalent Level of Safety**  : An equivalent level of safety will be provided by following the flight Manuals provided by the manufacturer. The PIC will take all required preflightactions

- including performing all required checklists and reviewing weather, flight requireme nts, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas

- before initiation of flight. The Manuals will be kept at the ground station with the operator at all times

**H) 14 C.F.R. § 91.109(a): Flight Ins truction**  PDM Pictures, Inc. seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.” UAS and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of the DJI Naza

- M V2 that

communicates with the aircraft via radio communications. **Equivalent Level of Safety:**  Given the size and speed of the UAS being used by PDM Pictures, Inc., an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are on board the UAS, and all persons will be a

safe distanc

e away in the event that the UAS experiences any difficulties during flight instruction. These training flights will primarily be conducted in a training facility which provides a secure perimeter with out public access. In addition, all training flights w ill be conducted by an experienced FAA certified Private Pilot with a current Class 3 medical

certificate.

**I) 14 C.F.R. § 91.119(c): Minimum Safe Altitudes** PDM Pictures, Inc. requests an exemption from the minimum safe altitude requirements

of 14 C.F.R. § 91.119. Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure in non

- congested areas. Section 91.119(d) allows for a helicopter to operate at less than those minimum

altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." **Equivalent Level of Safety:** Comp ared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with

conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS's, as well as the locations where it is operated. In order to avoid any risk to aircraft, flight operations will be restricted to at or below 200 feet AGL.

As set for th in the Manuals and herein, the UAS will be operated in areas away from persons or structures not involved in the operation.

**J) 14 C.F.R. § 91.121: Altimeter Settings** PDM Pictures, Inc. requests an exemption from 14 C.F.R. § 91.121, which requires a

p erson operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is requested to the extent that the UAS does not have a barome tric

altimeter, but rather a GPS altitude read out.**Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety can be

achieved if the aircraft will be operated at or below 200 feet AGL and within visual line

of

- sight. This will be ac

complished as the altitude of the aircraft is monitored by the PIC and by the visual observer, in addition, the PIC will have GPS based altitude information relayed in real time to the ground station.

**K) 14 C.F.R. § 91.151(a): Fuel Requirements for Flig ht in VFR Conditions**  PDM Pictures, Inc. requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minu tes. The technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. PDM Pictures, Inc. proposes that the UAS will be safely landed with no less than 25% battery li fe remaining. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety is provided if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still availabl e. The UAS Operations Manual conforms to this limit, providing an equivalent level of safety.

**L) 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections**  PDM Pictures, Inc. seeks an exemption from the maintenance i nspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulat ions is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS's

will not have. **Equivalent Level of Safety:** An equivalent level of safety will be achieved because PDM Pictures, Inc. requires its P IC to conduct a through preflight flight and post flight inspection of the UAS to ensure it's flight worthiness. Each UAS is flown in compliance with the applicable manufactures manual to include maintenance, overhaul, replacement, and inspection requireme nts for the aircraft and procedures to document and maintain maintenance records for the aircraft. PDM Pictures, Inc. maintains log

books for the UAS's which include all maintenance and/or alterations.

**VI. PUBLIC INTEREST**

Granting the exemption request o f PDM Pictures, Inc. furthers the public interest.National policy set by Congress favors early integration of the UAS into the NAS in

controlled, safe working environments such as those proposed in this petition. In addition, the public also has an intere st in reducing the hazards and emissions associated with alternate use of helicopters to conduct similar operations. The UAS proposed for the exemptions are very light, with a total gross weight of less than 10 lbs. They do not carry any flammable liquid f uel, further reducing the risk from any potential

accident.

Additionally, PDM Pictures, Inc. has the knowledge and expertise to safely and effectively photograph from within the NAS, whereby typical larger manned aircraft may be a hindrance to the public, noisy and not accessible. PDM Pictures, Inc. will have the capability to effectively dispatch in minutes a UAS that in most cases will go unnoticed by the general public, fall well below the typical noise signature of manned aircraft

without the use of tra ditional petroleum based fuels. PDM Pictures, Inc. also encourages demonstrations and seminars relating to safe and effective UAS operation. As a former First Responder, it has become apparent that using a UAS in emergency operations is an

efficient and us

eful tool, and in certain circumstances will be able to provide faster services and information than a tradition manned aircraft, all while providing a safe working environment. When requested, and in coordination with federal, state and local governments after a disaster, PDM Pictures, Inc. can provide valuable information to first responders and government agencies to help coordinate the response that may not be obtainable with traditional manned aircraft. Finally, PDM Pictures, Inc. is willing to

donate its time to assist the FAA or any other government or public agency that wishes to educate the general public on the integration of UAS in NAS.

**VII. PRIVACY**

All flights will occur over private property or over controlled

- access property, these flights w ill be conducted with the property owner’s consent and knowledge prior to the flight operation. Any photography will be of people who have consented to being photographed or otherwise have agreed to be in the area where the aerial photography operations wi ll take place. All operations will be compliant with applicable federal, state and local laws. The Applicant’s request satisfies the criteria set forth in Section 333 of the Reform Act. The size, weight, speed, operating capabilities of the UAS, the limit s on operations proximate to airports and populated areas, and the operation within VLOS do not create a hazard to users of the national airspace system and do not pose any national security threats or concerns.

**VIII. SUMMARY FOR FEDERAL REGISTRY**

Pursuan t to 14 C.F .R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed PDM Pictures, Inc. seeks an exemption from the following rules: 14 CPR Part 21, Subpart H; 14 CPR Part 27 ; 14 CPR 45.23(b); 14 CPR§ 61.113; 14 CPR 91.7(a); 14 CPR 91.9(b)(2); 14 CPR 91.103; 14CPR 91.109(a); 14 CPR 91.119; 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 91.203 (a) & (b);

14 CPR 91.405(a); 14 CPR 91.407(a)(l); 14 CPR 91.409(a)(2); 14 CPR 91.417 (a) & (b). The exemption, as requested by PDM Pictures, Inc., will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent work with conventional aircraft and rotorcraft.

**IX. ATTACHMENTS** 

1) Pilot Logbook

2) DJI Phantom 2 Manual

3) DJI 550 Manual

**X. CONCLUSION**

Satisfaction of the criteria provided in Section 333 of the Reform Act

- size, weight, speed, operating capabilities, proximity to airports and populated areas, operati on within visual line of sight, and national security considerations

- provides more than adequate justification for the grant of the requested exemptions to permit PDM Pictures, Inc. to operate the DJI Phantom 2 and DJI 550 for use in aerial photography

a nd video.

Granting the requested exemption will benefit the public interest as a whole in many ways: (1) significantly improving safety and reducing risk by alleviating human exposure to danger; and (2) improving the quality of services and decreasing ope rating costs associated with conventional flight operations.

Respectfully submitted,

John Baer
PDM Pictures, Inc.