November 11 , 2015

U.S. Department of Transportation Docket Operations, M
- 30 1200 New Jersey

Avenue, SE Room W12

- 140, West Building Ground Floor Washington, DC 20590

- 0001 Re: **Petition of Jet Stream Video**  **for an Exemption Pursuant to Section 333 of the FAA**  **Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System** Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Jet Stream Video hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the DJ I PHANTOM 3 (“the PHANTOM”) and the INSPIRE I (“the INSPIRE”) which are manufactured by DJ I Innovations. Additionally the Trimble UX5 (“ UX5 ”) manufactured by Trimble . Where all equipment is being referenced they will be referenced as (“THE EQUIPMENT”). **I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED**  Jet Stream Video requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;  14 C.F.R Part 27;  14 C.F.R § 45.23(b);  14 C.F.R. § 45.27(a);  14 C.F.R § 61.113;  14 C.F.R § 91.7(a);  14 C.F.R § 91.9(b)(2);  14 C.F.R § 91.9(c);  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);  14 C.F.R § 91.203 (a) & (b);  14 C.F.R § 91.405(a);  14 C.F.R § 91.407(a)(l);  14 C.F.R § 91.409(a)(2);  14 C.F.R § 91.417 (a) & (b).**II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS** 

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft sy stems into the national airspace sy stem.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft s ys tem 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:

 The size, weight, speed and operational capability ;  Operation in prox imity to airports and populated areas; and  Operation within visual line of sight of the operator. Furthermore, the Federal Aviation 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 exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701

- 44716, et seq. A party requesting an exemption must explain the reasons wh y 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. 14 C.F.R. § 11.81. **III. DESCRIPTION OF**  **JET STREAM VIDEO AND ITS SERVICES**  Jet
- Stream Video is a “Veteran

- Owned” Small Business that produces High Resolution Aerial Images. Our compan y focuses on high resolution digital photography and videograph y for a variety of applications

– including, but not limited to, precision surveying, residential and commercial real estate development, construction sit es, architects, insurance assessments and agriculture. The contact information for the petitioner, Jet Stream Video is as follows: Tim Croswhite Chief Pilot Jet
- Stream Video 4420 Brookwood Rd Charlotte, NC 28215 www.jet

- streamvideo.com **IV. DESCRIPTION OF PROPOSED OPERATIONS**  Jet Stream Video is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to perform aerial photograph y and videograph y, aerial mapping, precision surveying, inspection of above ground structures and infrastructure, agriculture, real estate, insurance assessment needs , and training for UAS p ilots, o perators & c rew .**A. The**  **Aircraft**

Jet Stream Video will operate the DJ I PHANTOM 3 (the “ PHANTOM ”) or the DJ I INSPIRE 1 (the “INSPIRE”) manufactured by DJ I Innovations and the Trimble UX5 (“ UX5 ”) manufactured by Trimble. **The PHANTOM**  is a battery operated quad copter with a maximum flight time of 25 minutes. The vehicle weighs approximately 2.75 pounds with a maximum takeoff weight of approximately 2.75 pounds. It has fixed landing gear, vibration dampers, small frame air incline and minimalized gimbal mount, wh ich allows for a 110 degree of view from the camera. Although the vehicle’s ground speed has a maximum of 2 5 mph, it will be operated between 2 and 2 5 miles per hour, and i t will operate at or below 4 0 0 feet AGL. **The INSPIRE** is a battery operated quadcopter with a maximum flight time of 18 minutes. Th e vehicle weighs approximately 5.3 pounds with a maximum t akeoff weight of approximately 7.5 pounds. It has retractable landing gear, vibration dampers, small frame air incline and minimalized gimbal mount which allows for a 94 degrees of view from the camera. Although the vehicle’s ground speed has a maximum of 49 mph, it will be operated between 2 and 2 5 miles per hour, and it will operate at or below 400 feet AGL. The PHA NTOM ’s and INPIRE’s manufacturer’s specifications are shown in the Appendix of the Quick Start Guide and the USER Manuals for each airframe. The inherent safety features, sophistication, programmability , GPS navigation, return home capability , airport vic inity no - fly feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the purp oses of this petition. These are radio controlled UAV s that has the capacity for software upgrades. They are light, less than 3 and 8 pounds respectivel y including battery and camera. Incorporated into the programming of the PHANTOM and INSPIRE is an automatic return home feature that automatically

directs th e craft back to point of take

- off should communication with the transmitter be lost. The Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight time is 25 minutes. Gross weight is 2 .75 pounds. The Inspire has a cruising speed of 15 knots, with a maximum speed of 42 knots. Maximum flight time is 18 minutes. Gross weight is 7 .4 9 pounds. The PHANTOM and IN SPIRE have a communication link b etween the camera and aircraft a llowing the operator or Pilot in Command (PI C) to moni tor battery level, altitude (AGL), distance from PIC, camera imagery , and also control camera angle. The software for the PHANTOM and INSPIRE allows the operator or PI C to set maximum altitude AGL for each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL is by default programmed into the UAV's software pre

flight to insure compliance with FAA standards a dding to the safety capabilities of this UAV. This UAV is programmed to remain in positi on when controls are released, m aintaining altitude and GPS location.The PHANTOM and IN SPIRE have an altitude and radar monitoring function that allows the

operator more precise determination of height, direction of flight and distanc e from the operator/PIC. The operator/PI C can monitor GPS lock status while the UAV is in flight, with the ability to anticipate loss o f GPS locking so the operator/PI C can land the UAV as a precaution. **The Trimble UX5**  The Trimble UX5 aerial imaging rov er follows a pre - programmed path where takeoff, flight, and landing require minimal human intervention. If required, the crew operating the aircraft from the ground can intervene to change the flight path or to land. In some cases, such as communications f ailure or loss of GPS signal, a pre

- programmed intervention is automatically activated to re

establish signal loss or to terminate the flight early and complete a safe landing. The UX5 aerial imaging rover holds a camera that takes aerial images over the defined area. The UX5 is a fixed

- wing aircraft, weighs less than 6 pounds fully loaded, flies at a maximum speed of no more than 74.5 knots indicated airspeed (KIAS), and a cruise speed of 49 KIAS, carries neither a pilot nor passenger, carries no flammable fuels, and operates exclusively within a pre - disclosed area. In addition, the UX5 has a semi

- autonomous navigation and control s ys tem comprised of a Ground Control Station (GCS) and auto

- pilot sy stem. All flights are pre

programmed with precise g lobal positioning s ys tem (GPS) guidance and do not require human intervention **Hardware** Ty pe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Fixed wing Weight. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.5 kg (5.51 lb) Wingspan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 m (3.28 ft) Wing area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 dm Dimensions . . . . . . . . . . . . 100 cm x 65 cm X 10.5 cm (39.37 in x 25.59 in x 4.13 in) Material. . . . . . . . . . . . . . . . EPP foam; Carbon frame structure; Composite elements Propulsion. . . . . . . . . . . . . . . . . . . . Electric pusher propeller; brushless 700 W motor Battery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14.8 V, 6000 mAh Camera. . . . . . . . . . . . . . . . . . . . . . 24 MP mi rrorless APSC with custom 15 mm lens Controller. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Trimble Tablet Rugged PC **Operation** Endurance

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 minutes Range . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 km (37.28 mi) Cruise speed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 kmh (50 mph) Maximum ceiling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5000 m (16,404 ft) Pre
- flight s ys tem setup time. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 minutes Take off Ty

pe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Catapult launch Angle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 degrees Landing Ty

pe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Bell y landing Angle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 degrees Landing space (L x W)Ty pical . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 m x 6 m (66 ft x 20 ft) Recommended. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 m x 30 m (164 ft x 98 ft) Weather limit . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 kmh (40.39 mph) and light rain Communication & control frequency . . . . . . . . . . . . . . . . . . . . . . . . . 2.4 GHz (FHSS) Communication & control range. . . . . . . . . . . . . . . . . . . . . . . . Up to 5 km (3.10 mi) Considering the programmability and safety features of these UAVs , it serves as the best option to protect the Public and NAS for the purposes of this petition. Jet Stream Video is using a UAV that has the capability for taking of

f and landing at a single point . There are no runways nor routes that need to be flown to areas being aerial video recorded or photographed. Allowing a reduced and more confined area of flight. The motors, rotors, propellers, body /frame, etc. for the UAV s utilized in this petition are not complicated. Engineering and design allows lay man maintenance. P re - flight inspection s for cracks, damage or other phy sical conditions that could hamper safe flight will be conducted prior to any and all missions

. P ost fli ght inspection s will also be conducted in order to aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. Thorough inspection of the UAV shall be conducted and flight response tested should a hard landing or crash occur i nsuring that the UAV can operate in a safe manner before conducting any further missions

. Petitioner Jet Stream Video requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition of flight in con gested areas. Petitioner Jet Stream Video requests waiver for this condition to allow reasonable and responsible videograph y in congested areas of s ubdivisions and neighborhoods. In compliance with Section 90.151 (a) the EQUIPMENT is a battery operated UAV/UAS with battery level monitoring capability . Full y charged battery flight time is rated at 18

- 50 minutes. Operator or PI C is war

ned when battery

level is low. Petitioner Jet Stream Video requests waiver/exemption from Section 91.203 (a) since the UAV/UAS that should not require an airworthiness certificat e . Posting of special flight authorization would not be possible since the EQUIPMENT h a s no cabin and is not large enough to carry a certificate. However, a special flight auth orization can be maintained by the operator to make available upon request. **B. Jet Stream Video**  **Proposed Operations Demonstrate an Equivalent Level of Safety**  **1. General Description of Proposed Flight Operations**  Jet Stream Video proposes to operate within the limitations and performance specifications listed in the aircraft USER MANUAL S which are summarized below. These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory structure because the proposed operations represent a safety enhancement to the protocols.The proposed operations do not create an y hazard to users of the national airspace s ys tem or pose

a threat to national security . The EQUIPMENT is battery ope rated with a maximum flight time of 18

- 5 0 minutes. The vehicle weighs approximately 3

- 8 pounds

. The vehicle’s ground speed has a maximum of 2 5
- 49 mph but it will be operated between 2 and 3 5 miles per hour, and it will operate at or below 2 00 feet AGL. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The EQUIPMENT carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft , the unmanned aircraft being operated b y the petitioner reduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditions, and design safety features of the EQUIPMENT
. The FAA has determine d that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology , is mitigated b y placing limits on altitude, requiring stand

- off distance from clouds, permitting day time o perations onl y, requiring that the aircraft be operated within visual line of sight , and requiring EQUIPMENT yi eld right of way to all other manned operations. Additionally , the operator will request a NOTAM prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 13

. The petitioner’s aircraft has the capability to operate safely

after experiencing certain in

- flight failures, as specified in the USER MANUAL regarding Return to Home (RTH) specifically lo w battery RTH and failsafe RTH . The aircraft is also able to respond to a lost

- link event with a pre coordinated, predictable, automated flight maneuver. **2. Reasons why the exemption would not adversely affect safety or how the**  **exemption would provide a level of safety at least equal to the existing rule.** Given the small size involved, the restricted environment within which they will operate, the procedures listed below, and pilot certification requirements, Jet Stream Video proposed operations using the EQUIPMENT would “not create a hazard to users of the national airspace sy stem or the public or pose a threat to national security .” Reform Act Section 333(b ) ( 1). 1. The aircraft will be identified by serial number, registered with the FAA, and have identification (N

-Number) markings as large as practicable. 2. Flights will be operated within visual line of sight of the pilot in command (PI C). 3. Prior to each flight , a zero altitude initiation point will be established and confirmed for accuracy

by PI C. 4. Maximum flight time for each operational flight will be approximately 15

- 20 minutes. 5. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. 6. The aircraft will be operated during daylight and in VFR conditions.7. Flights will be operated at a lateral dis tance of at least 50 feet from an y persons or property not associated with the operation who have not given prior permission. 8. Flights will be limited to a groundspeed of 5

- 25 mph. 9. Minimum crew for each flight will consist of a PIC and an Observer. 10. The PI C will possess at least a sport pilot certificate and a valid state driver’s license. 11. Any designee from Jet Stream Video will have completed a Basic Operator Course for the EQUIPMENT

. 12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 13. The flight operations will yield the right of way to other manned aircraft operations. 14. All persons who are not involved with flight operations w ill be required to stay 5 0 feet from the edge of the flight operation perimeter. 15. Jet Stream Video will provide NOTAM details to the FAA 24 hours prior to each flight. 16. All required permissions and permits will be obtained from territory , state, county or city jurisdictions prior to flight. 17. Prior to commencing operations, Jet Stream Video will obtain a Certificate of Waiver or Authorization (COA) from the FAA if flying above 200 feet AGL. 18. If the aircraft loses communications, it will have the capability to return to a pre determined location within the operational area and land. 19. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational area and land. 20. The flight will be aborted in case of unpredicted obstacles or emergencies. 21. Each flight will be recorded in an Operations L og Book. 24. Maintenance on the aircraft will be recorded in a Maintenance Lo g Book. **3. Flight Recovery, Lost Communications, and Lost GPS Procedures**  The flight recovery , lost communications, and lost GPS procedures are fu lly documented in the attached User Manuals. **V. SPECIFIC FAR EXEMPTIONS REQUESTED**  Jet Stream Video seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the request ed operations using the EQUIPMENT

. Listed below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedures and safeguards that Jet Stream Video has established which will ensure a level of safety

better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e). **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 UAS selected provides an equivalent level of safety when compared to aircraft normall y used for the same application. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. F AA 2014

- 0352 at 13

- 14, 22. If, however, the FAA determines that there are some characteristics of the PHANTOM that fail to meet the requirements of the Reform Act, an exemption is requested. **Equivalent Level of Safety:** The EQUIPMENT are safe when taking into account its size, weight, speed, and operational capability . The PHANTOM weighs approximately 2.75 pounds the INSPIRE weighs approximately 7.5 pounds and either wil l be flown at speeds of 5
- 3 5 miles per hour, and in visua l line of si ght of the operator

. The UX5 weighs approximately 6 pounds and will be flown at speeds of 5

- 35 miles per hour. The EQUIPMENT do es not carry pilots, passengers, explosive materials, or flammable liquid fuels. The EQUIPMENT will be operated within the parameters of the User Manuals. Jet Stream Video will also provide the FAA with advance notice of all operations via a NOTAM and coordination with the local Flight Standards District Office ( FSDO ) . The proposed operations will be at least as safe as, or s afer than, conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

**B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft**  14 C.F.R. Part 27 sets forth the procedural requi rements for airworthiness certification of normal category rotorcraft. To the extent the EQUIPMENT would otherwise require certification under Part 27, Jet Stream Video seeks an exemption from Part 27’s airworthiness standards for the same reasons identifi ed 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 Requirements** 14 C.F.R. §45.23(b), Markings of the Aircraft states: 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 display on that aircraft near each entrance to the cabin, coc kpit, 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. § 45.27(a) states: **Rotorcraft.** Each operator of a rotorcraf t must display

on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 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

-Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 14. **Equivalent Level of Safety:** Jet Stream Video will mark all PHANTOMs and INSPIREs with their N

- Number in a prominent spot on the fuselage with markings that are as large as practicable. **D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations**  Jet Stream Video seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also re quire 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 carryi ng passengers or cargo for hire. While the EQUIPMENT will be operated as part of a commercial operation, they carry 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 outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PI C to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The PI C will possess at least a sport pilot certificate, a third class medical certificate or valid state issued driver’s license , and w ill have completed a Basic Operator Course for the EQUIPMENT
. The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA con siders the overriding safety

factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS

- specific flight cycles, flight time, and specific make and model experience, culminating in verification through test ing.” See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 18. The proposed operations can achieve an equivalent level of safety b y requiring the knowledge and experience in EQUIPMENT operations described above. The restrictions Jet Stream Video has p laced on its EQUIPMENT operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial in FAA Docket No. FAA

- 2014

- 0352. Jet Stream Video will operate in restricted areas (the s ites) away from persons and property not involved in the operati on. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to accommodate flight operations on specified s ites. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.**E. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft Airworthiness** 

Jet Stream Video seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y 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. Accordingl y, Jet Stream Video requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

**F. 14 C.F.R.**  **§ 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 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 the reof. 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) of 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. Jet Stream Video does n ot request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PI C during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19

- 20, and Grant of Exemption No. 8607.

**G. 14 C.F.R.**  **§ 91.103: Preflight Action**  Jet Stream Video 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 b oard the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Under these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption No. 11062, p. 20. 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 User

Manuals. The PIC will take all required preflight actions

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

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

**H. 14 C.F.R.**  **§ 91.109(a): Flight Instruction**  Jet Stream Video seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 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.” UASs and remotely pilote d aircraft, b y their design, do not have functional dual controls. Instead, flight control is accomplished through the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with the aircraft via radio communications. **Equivalen t Level of Safety:**  When flight instruction is performed, no pilots will be on the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed of the EQUIPMENT , an equivalent level of saf e training can still be performed without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the event that the aircraft experiences any difficulties during flight instruction. These flight s will comply with the provisions in the User Manuals. Accordingl y, Jet Stream Video proposed method of operation provides superior levels of safety.

**I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas**  Jet Stream Video requests an exemptio n from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. The FAA has already determined that relief from Sec tion 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by Jet Stream Video

. See Grant of Exemption No. 11062, p. 20

- 21. **Equivalent Level of Safety:** Compared to flight operations with rotorcraf t 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 presentl y exist with conventional aircraft. An equivalent level of safety will be achi eved given the size, weight, and speed of the EQUIPMENT , as well as the locati ons where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 4 00 feet AGL or below. As set forth in the User Manuals and herein, the EQUIPMENT will be operated at s ites, away from persons or structures not involved in the operation. All persons who are not involved with Jet Stream Video operations wi ll be required to be at least 5 0 feet from the flight operation perimeter.

**J. 14 C.F.R.**  **§ 91.121: Altimeter Settings**  This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person 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. The EQUIPMENT use both barometric pressure sensors andG PS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that the EQUIPMENT do not have a barometric altimeter setting. The altitude of the aircraft is monitored by the PI C on the ground control station and by the visual observer. **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 400 feet AGL and within visua l line

- of

- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20

- 21. As the attached User Manuals indicate, the PHANTOM or INSPIRE will be operated at or below 400 feet AGLand comp l y with the limitations in the Grant of Exemption No. 11062.

**K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  Jet Stream Video 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 fl y after that for at least 30 minutes; or 2. At night, to fly

after that for at least 45 minutes. Here, the technological limitations on EQUIPMENT battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. The aircraft is battery powered with a maximum flight time of between 18

- 25 minutes. Jet Stream Video proposes that the maximum flight time for each operational flight will be 18

- 2 5 minutes. The aircraft will be safely

landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety is provided if th e UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21

- 22. The User Manuals providing an equivalent level of safety b y s afel y landing with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and otherwise compl yi ng with the flight restrictions above.

**L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and**  **(b): Maint**  **enance Inspections** Jet Stream Video seeks an exemption from the maintenance inspection 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”). Anexemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certif icate, which the EQUIPMENT will not have. **Equivalent Level of Safety:** An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, an d inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also includes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 14

- 15. As provided in th e Manuals, flights will not be conducted unless a flight operations checklist is performed that includes all of the aircraft’s components. The Manuals also set requirements for maintenance log books and record keeping as well as routine and post
- flight mai ntenance. The Manuals set requirements for both annual maintenance and preventative maintenance. **VI. PUBLIC INTEREST**  Granting Jet Stream Video petition for exemption furthers the public interest. National policy set by Congress favors earl y integration of UA S into the NAS in controlled, safe working environments as proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 33 3 of the Reform Act. Jet Stream Video will operate in a manner that will ensure the public’s safety and will set the example for others to emulate. It is well established that UAS provide an additional tool for the filmmaking industry , adding a greater degree of flexibility , which supplements the current capabilities offered b y m anned aircraft

. **VII. PRIVACY**  All flights will be conducted in accordance with any federal, state or local laws regarding privacy

. **VIII. NATIONAL SECURITY**  Given the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue. Furthermore, the security screening conducted b y the Transportation Security Administration of certificated airmen satisfi es the statutory requirement of Section 333 for operations to not pose a threat to national security. **IX. SUMMARY FOR FEDERAL REGISTER**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be dete rmined that publication is needed: Jet Stream Video seeks an exemption from the following rules in order to provide aerial photograph y and videography, aerial mapping, precision survey ing, inspection of above groundstructures and infrastructure, agriculture, real estate, insurance assessment needs , and training for

UAS p ilots, o perators & c rew : 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7 (a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 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); 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F .R § 91.417 (a) & (b). The exemption will enhance safety b y reducing risk to the operator, the general public and property owners from the hazards associated with operating UAS through deliberate planning, risk mitigation, and flight operations. **X. ATTACHMENTS**  Attachment 1 : DJ I Phantom Pilot Training Guide v1.1 Attachment 2 : DJ I Phantom 3 Professional User Manual v1.2 Attachment 3 : DJ I Phantom 3 Quick Start Guide v1.0 Attachment 4 : DJ I Phantom 3 Safety Guidelines Disclaimer Attachment 5 : DJ I Inspire 1 User Manual v1.2 Attachment 6 : DJ I Inspire 1 Quick Start Guide v1.2 Attachment 7 : DJ I Inspire 1 Safety Guidelines Attachment 8 : DJ I Inspire 1 Maintenance Manual v1.0 Attachment 9: Trimble UX5 User Guide **XI. CONCLUSION**  Satisfaction of the criteria provided in Section 333 of the Reform Act

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

- provides more than adequate justification for the grant of the requested exemptions to permit Jet Stream Video to operate the EQUIPMENT

. Granting the requested exemption will benefit the public interest as a whole in many way s, including (1) significantly improving safety and reducing risk b y alleviating human exposure to danger; (2) improving the quality of services Jet Stream Video can provide to its customers; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraft Respectfully

submitted, By : /s/ Tim Croswhite Chief Pilot Jet Stream Video