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March 8, 2016
U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590 RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT Dear Sir/Madam: This petition is being submitted on our own behalf witho ut legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization & Reform Act of 2012 (the "Reform Act") and 14 C

. F

. R

. , Part 11, Giant Model Products, LLC, ("GMP"), a Missouri based limited liability company operating a Small Unman ned Aircraft System ("sUAS") with Gerry Hinshaw as the PIC, equipped to conduct aerial photography, videography, and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations ("FARs") listed below to allow operati on of our sUAS commercially in airspace regulated by the Federal Aviation Administration ("FAA") so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The req uested exemption would permit GMP to pursue its commercial interests in providing services to consumers interested aerial data capture using a small advanced sUAS in the following areas:

 Agricultural Surveying
 Aerial video/photography or providing live vi deo feed
 Closed Set Film Cinematography
 Real Estate Photography
 Product Demonstrations
 Research & Development GMP states that all sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent an d knowledge and that only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured.Page 2 of 6

GMP understands the proper roles of an observer, communication procedures, proper visual sca n techniques, operations at non

-towered airports, and appropriate sections of the Aeronautical Information Manual.
I , Gerry Hinshaw, have flown small multi

- rotors for over four years, with over 10000 hours of flight time. **Contact Information** : Company: G iant Model Products, LLC Name: Gerry Hinshaw Address: 3972 NE Breckenridge Court, Lathrop, MO 64465 Email: President@GiantModelProducts.com Cell phone: 816

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- 3634 GMP has instilled safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to video and photography usage, as GMP will record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation. This data can be logged with the DJI Pilot App. Regulations from which the exemption is requested:
14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R . 61.113 (a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 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. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)
**UNMANNED AIRCRAFT SYSTEM** We are petitioning for exemption to enable GMP to operate a Tarot S810Pro, DJI 45 O, X8 airplane, RMRC Penguin, RMRC Air Titan, equipped with three axis gimbaled camera. These sUAS al l weigh less than 25 pounds, have a built

- in capability to limit the height it flies above th e ground, to limit the radius of the distance it flies from the operator, and to exclude it from Class B, C, and D airspace, including a no fly zone feature. These sUAS named above operate in the 2.4

- 5.8 GHz frequency range, which complies with FCC regul ations. Each system also has the failsafe function of the autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger Return To Home and will land safely.Page 3 of 6

The above sp ecifications meet standards listed below, some derived in accordance with the Model Aircraft Operating Standards:

 The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that are a "sufficient distan ce" from populated areas within the sterile area described in the operators manual. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public".
 When flying sUAS within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in the proximity of full

-scale aircraft.
 Maximum flight time for each operational flight will be 60 minutes.
 Flights will be terminated at 25% battery power rese rve should that occur prior to the 60 minute limit.
 The sUAS will be programmed so that it will not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.
 The sUAS opera ted by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal).
 The sUAS will operate at speeds of no more than 55 knots.
 Given the small size of the sUAS and the restricted sterile environment within which they wil l operate, our sUAS operations adhere to the Reform Act's safety requirements.

**EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY** GMP requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAS System:
**14 C .**  **F .**  **R .**  **Part 21 :**  Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the Tarot 810 Pro, DJI 450, and said airplanes under either or all of the following provisions:
**21.191 :**  Experimental Certificates Experimental certificates are issued for the following purpo ses: (a) Research & Development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of foam, carbon fiber, and/or p lastic, we proposePage 4 of 6

that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exempti on of 14 C.F.R. Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.
**14 C.F.R. 45.23 :**  Display of Marks, General and 45.29 Size of Marks These regulat ions provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, coc kpit, or pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIME NTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO, and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inch es high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.
**14 C.F.R. 61.113**  : Private Pilot Privileges & Limitations: PIC. Pursuant to 14 C.F.R. 61.113 (a) & (b) private pilots are limited to non

- commercial operations. Further, while helpful, a pilot license will not ensure remote control piloting skills

. The risks atten ded to the operation of my UAS is far less than the risk levels inherent in the commercial activ ities outlined in 14 C. F. R. 61, et seq. Thus, allowing GMP to operate my UAS to meet and exceed current safety levels in relation to 14 C.F.R. 61.113 (a) & (b).
**14 C.F.R. 91.7:** 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:** Civil aircraft flight man ual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of the 91.9, we propose that a current, approved sUAS Flight Manual but be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.
**14 C.F.R. 91.119:** Minimum Safe Alt itudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, ve ssels, vehicles, or structures, it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown overPage 5 of 6

property or persons where permission has been obtained and careful pre

- planning has been performed. The aircraft w ill be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles, and structures is minimal compared to manned aircraft, which should be considered in granting the exception.
**14 C.F.R. 91.121 :**  Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available wit hin 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted vi a radio from the sUAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.
**14 C.F.R. 91.151:** Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an ai rplane under day

-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at last 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12

-45 minutes (depending on which sUAS) with a 20% reserve. Since the aircraft will never fly more than 1/2NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 minute reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that. **14 C.F.R. 91.203 (a) & (b):** Civil Aircraft: Certifications Required. The regulation provides that an airwort hiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew". With all of our vehicles at a maximum gross weight of 7 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalen t level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the ai rcraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information, plus the word "EXPERIMENTAL" to satisfy the requirement of 14 C.F.R. 45.23

. **14 C.F.R. Subpart E (91.401**
**- 91.417)**  : Maintenance, Preventative Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7 after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be author ized to approve the aircraft for return to service". The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and inPage 6 of 6

addition, conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PI C will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.
**R E: Exemption Request Section 333 of the FAA Reform Act**  Thank you for the opportunity to give examples as to why granting Giant Model Products, LLC, the requested exemption would be in the public interest, and how it would benefit the public as a whole. Please find the following examples supporting this exemption:
1. UAS us e as an alternative to large, manned aircraft using combustible fuel in cinema. The UAS, powered by batteries, is smaller, lighter, and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on bo ard, and will thereby reduce current risk levels to both the pilots aboard and people below, thereby enhancing safety and drastically diminishing the likelihood of death or serious bodily injury. The small weight and minimal payload allows for high quality aerial video at safety levels before unseen. 2. Public Good: Closed Set Cinematography GMP can offer the same aerial videography a production is requesting without any of the danger associated with a traditional full sized manned helicopter using combustible fuel when flying over a set. GPS stabilized stationary angles and low altitudes, predictable flight paths with full coordination between people on the ground without need for complicated communication systems, and the ability to land safely in a comp arably smaller area to a full sized aircraft all increase safety and public good. The costs of the production are drastically lowered and safety is raised. High quality aerial cinematography becomes accessible to smaller productions, facilitating market growth and public job creation. 3. UAS use in Aerial Photography UAS use in photography creates dramatic versatility never before possible. The impact of this versatility creates immediate value to small and large businesses, charity organizations, and private citizens. Small businesses would never have access to the production value of an aerial photo without great expense, usually reserved for larger corporations. Having access to this for promotion needs is a large benefit to businesses. We respectfully request exemption under Section 333 to enable Giant Model Products, LLC, to operate safe, low risk commercial sUAS operations for the activities stated. GMP at all times will respect the space and p rivacy of citizens and property, whilst keeping our skies safe. Sincerely,
Gerry Hinshaw, Owner/Director Giant Model Products, LLC President@GiantModelProducts.com www.giantmodelproducts.com