Mark E. McKinnon Mark.McKinnon@dentons.com

D 703.336.8708

Dentons US LLP

1676 International Drive • Penthouse McLean, VA 22102
United States

T 703.336.8800

F 703.336.8750 Salans FMC SNR Denton

McK enna Long

dentons.com

August 25, 2015

U.S. Department of Transportation
Docket Management System
1200 New Jersey Ave., SE
Washington DC 20590

Re: Petition of The St. Louis Rams, LLC for Grant of Exemption Pursuant to Section

333 of the FAA Modernization and Reform Act of 201 2

To Whom it May Concern :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 14 C.F.R. Part 11, The St. Louis Rams, LLC (The Rams) hereby applies for a Grant of Exemption from the Federal Aviation Regulations (FARs) i dentified below, to operate small unmanned aerial vehicles ( i.e., small unmanned aircraft systems or UAS) for the purpose of conducting aerial data collection in support of its professional sports activities , as well as closed set motion picture and televis ion production. I n particular, The Rams seeks permission to operate the DJI Phantom III. The Rams respectfully submits that this Petition for Exemption qualifies for expedited approval, as the Federal Aviation Administration (FAA) has previously issued g rants of exemption in circumstances similar in all material respects to those presented

herein.

In addition to this Petition for Exemption, The Rams will also submit the following operating documents under separate cover:

 The Rams Motion Picture and Te levision Operations Manual

The Rams submit this manual as a confidential document under separate cover pursuant to 14 C.F.R. § 11.35(b), as it contains confidential commercial and proprietary information that is not generally made available to the public. As a result, the information is also protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

For your convenience, this Petition is organized as follows:U.S. Department of Transportation August 25, 2015 Page 2 Salans F MC SNR Denton
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T ABLE OF C ONTENTS

Page

I. B ACKGROUND & D ESCRIPTION OF P ETITIONER

................................ ................................ .... 3

II. D ESCRIPTION OF P ROPOSED O PERATION

................................ ................................ ............... 3

III. R ELEVANT S TATUTORY A UTHORITY

................................ ................................ .................... 4

IV. THE RAMS ' P ROPOSED UAS O PERATIONS M EET THE R EQUIREMENTS OF S ECTION
333 OF THE R EFORM A CT

................................ ................................ ................................ ...... 4

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

................................ ................................ ............................. 4

B. Approval is Warranted Based on the Operational Restrictions in THE

RAMS ' Operating Documents

................................ ................................ ................. 5

V. R EGULATIONS F ROM W HICH E XEMPTION I S S OUGHT

................................ ........................... 5

A. 91.9(c), 45.23(b) and 45.27(a): Aircr aft Marking and Identification Requirements

................................ ................................ ................................ ........... 6

B. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

................................ ................................ .......................... 7

C. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.3 15: Private, Recreational and Sport Pilot Medical Certificate, Privileges and

Limitations

................................ ................................ ................................ ............... 8

D. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ....... 8

E. 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft a nd 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

................................ ..... 8

F. 91.103: Preflight Action

................................ ................................ ......................... 10

G. 91.109(a): Flight Instruction

................................ ................................ .................. 10

H. 91.119(c): Minim um Safe Altitudes Over Other Than Congested Areas

.............. 10

I. 91.121: Altimeter Settings

................................ ................................ ..................... 11

J. 91.151(a): Fuel Requirements for Flight in VFR Conditions

................................ 12

VI. D RUG AND A LC OHOL P ROGRAM

................................ ................................ ......................... 12

VII. P UBLIC I NTEREST

................................ ................................ ................................ ................ 12

VIII. P RIVACY

................................ ................................ ................................ ............................. 13

IX. F EDERAL R EGISTER S UMMARY

................................ ................................ ........................... 13

X. C ONCLUSION

................................ ................................ ................................ ....................... 13U.S. Department of Transportation August 25, 2015 Page 3 Salans F MC SNR Denton
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I. B ACKGROUND & D ESCRIPTION OF P ETITIONER

The Rams are a professional football team located in Saint Louis, Missouri . Founded in 1936, the team is continuing its strong commitment to local communities and is dedicated to conducting its UAS operations in a safe environment.

In accordance with 14 C.F.R. § 11.81(a), The Rams provides the following information in support of its Petition for Exemption.

The contact information for Petitioner is as follows:

Todd Davis

V ice President

- Legal Affairs

St. Loui s Rams

10271 W. Pico Blvd. Los Angeles, CA 90064

F: 310

- 201

- 0967

Ph: 310

- 277

- 4517

II. D ESCRIPTION OF P ROPOSED O PERATION

The Rams seeks an exemption pursuant to Section 333 of the Reform Act to use the DJI

Phantom 3 s eries of UAS for aerial data collection and closed set motion picture and television production in support of its professional sports activities . For example, The Rams will utilize the

vehicles for capturing images of its practices to analyze player and team performance as well as for promotio nal purposes.

The Rams is committed to maintaining the highest standards of flight safety. All UAS operations will be performed in accordance with the accompanying The Rams operating documents, and in accordance with the requirements of an applicabl e C ertificate of Authorization ("C OA ") . Among other things, and as detailed in the operating documents, all UAS operations will occur in uncontrolled airspace, within visual line

- of

- sight (VLOS) of the pilot and visual observer, and will be limited to dayt ime VFR conditions. Moreover, The Rams ' operating documents incorporate redundant safeguards to enhance safety. The proposed operations in this Petition for Exemption are not new or novel to the FAA. The FAA has previously issued grants of exemption to use small UAS for aerial data collection in support of similar inspection, survey and aerial imaging activities: See e.g.

,

Exemption No. 1 2477 to VizTools , LLC for closed set filming and special event filming
(Docket No. FAA

- 201 5

- 0 605 );

Exemption No. 12496 360 Dela ware Orbit Tours LLC for closed set filming and special
event filming, (Docket No. FAA

– 2015

– 0705 );U.S. Department of Transportation August 25, 2015 Page 4 Salans F MC SNR Denton
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The low

- risk UAS operations proposed by The Rams in this Petition for Exemption fall squarely within the category of aerial data collection that has been subject to previous approval.

III. R ELEVANT S TATUTORY A UTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil

unmanned aircr aft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS where it is safe to do so based on the following considerations:

 The UAS's size, w eight, speed and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant e xemptions 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) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exem ptions from §§ 44701(a), (b) and §§ 44702

– 44716, et seq. ). 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.F.R. § 11.81 (petitions for exemption).

IV. T HE R AMS ' P ROPOSED UAS O PERATIONS M EET THE R EQUIREMENTS OF S ECTION 333

OF THE R EFORM A CT

The Rams ' proposed operations in this Petition for Exemption qualify for expedited approval under Section 333 of the Reform Act, as each of the statutory criteria and relevant factors are satisfied and the FAA has previously issued grants of exemption in circumstances similar to those presented in this Petition for Exemption.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

The Rams seek permission to operate the DJI Phantom III series of aircraft. The FAA is familiar with and has already determined that the Phantom III meets the requir ements of Section

333 of the Reform Act due to its weight, speed and operational capabilitie s. See e.g., Exemption No. 11783 to Precision Design and Drafting, Inc.; Exemption No. 11788 to Birds Eye Aerial Photography, Inc.; Exemption No. 11696 to Midwest UAV Imagining; Exemption No. 11335A to Voler, Inc.; Exemption No. 11267A to ETAK Systems, Inc.; Exemption No. 11306A to Hawk Aerial, LLC . Accordingly, the petition should be granted.U.S. Department of Transportation August 25, 2015 Page 5 Salans F MC SNR Denton
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B. Approval is Warranted Based on the Operational Restrictions in The Ra ms ' Operating Documents

The operating documents for the selected UAS contain all the procedures and limitations necessary to safely and successfully perform the proposed operations. To expedite the FAA's safety

assessment of The Rams ' proposed UAS operat ions, The Rams has tailored its operating documents to comply with the conditions and limitations imposed on similarly situated petitioners seeking to

use small UAS for aerial data collection. See e.g., Grant of Exemption No. 11761 issued to Dronair

Soluti ons, Docket No. FAA

- 2015

- 0648. In particular, the operating documents contain systems and procedures to permit The Rams to comply with the conditions and limitations in the FAA's Grant of Exemption. Id.

V. R EGULATIONS F ROM W HICH E XEMPTION I S S OUGHT

The Fede ral Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, including UAS, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 1

The Rams seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 45, 61 and 91 for purposes of conducting the requested operations using small UA S, including:

FAR Description

91.9(c); 45.23(b) and
45.27(a) Aircraft Marking and Identification Requirements

91.405(a); 91.407(a)(1);
91.409(a)(1) and (2);
91.417(a) and (b) Maintenance and Inspection Requirements

61.23(a) and (c); 61.113;
61.101( e)(4) and (5); 61.315 Private, Recreational and Sport Pilot Medical Certificate
Privileges and Limitations

91.7(a) Civil Aircraft Airworthiness

91.9(b)(2); 91.203(a) and
(b) Carrying Aircraft Flight Manual, Certification and Registration in

the Aircraf

t

1 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed
pursuant to Sections 44701(a) and (b) and Sections 44702

- 447 16).U.S. Department of Transportation August 25, 2015 Page 6 Salans F MC SNR Denton
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91.103 Preflight Action

91.109(a) Flight Instruction

91.119(c) Minimum Safe Altitudes Over Other than Congested Areas

91.121 Altimeter Settings

91.151(a) Fuel Requirements for Flight in VFR Conditions

Listed below are the specific sections of 1 4 C.F.R. for which an exemption is sought, and the operating procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. 2

A. 91.9(c), 45.23(b) and 45.27(a): Ai rcraft Marking and Identification Requirements

The Rams seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and P lacard Requirements, provides that:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Ro man 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, 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. § 45.27(a), Rotorcraft, states:

Each operator of a rotorc raft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

2 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek exemption.U.S. Department of Transportation August 25, 2015 Page 7 Salans F MC SNR Denton
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In prior grants of exemption under Section 333 of the Reform Act, the FAA determined that exemption from these requirem ents was warranted provided that the aircraft "have identification (N

- Number) markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." 3 All UAS flown by The Rams will bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 4

B. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

The Rams seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91. 405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. 5 An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS to be operated under this grant of exemption will not have.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the operating d ocuments and any required manufacturer Safety or Service Bulletins. Further, as required by the operating documents, the Pilot in Command (PIC) will conduct a pre

- flight inspection of the UAS and all associated equipment to account for all discrepancies an d/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation of the UAS and no flights will occur unless, and until, all flight critical components of the UAS have been found to be ai rworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement of any flight

- critical components. As required by the operating documents, the PIC who conducts the functional test flight will make an entr y in the UAS aircraft records of the flight.

The operating documents also include requirements to follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. Moreove r, the operating documents also include 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 Petitioner's UAS. As a

whol e, the maintenance and inspection procedures required by Petitioner's operating documents ensure that an equivalent or higher level of safety will be achieved.

3 FAA Docket No. FAA

- 2014

- 0352.

4 See, e.g., FAA Docket No. FAA

- 2014

- 0352, at 14.

5 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 s ubpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter.").U.S. Department of Transportation August 25, 2015 Page 8 Salans F MC SNR Denton
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C. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport Pilot Me dical Certificate, Privileges and Limitations

The Rams seeks exemption from these sections, which restricts private, recreational or sport pilot certificate holders from flying aircraft for compensation or hire, and would also require a Class II Medical Ce rtificate. 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 private pilot is carrying passengers or cargo for hire. In this case

, while the UAS will be operated as part of a commercial operation, it carries neither passengers

nor cargo.

In the Grant of Exemption No. 11062 to Astraeus Aerial 6 , the FAA determined that the unique characteristics of UAS operation outside of controlle d airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved.

More recently, the FAA determined that holders of recreational and sport pilot certificates would also have adequate aeronautical knowledge to pilo t a UAS. Accordingly, because these individuals would also be subject to security screening by the Department of Homeland Security (DHS), the FAA determined that holders of recreational and sport pilot certificates would be qualified to serve as the PIC fo r UAS operations. 7

D. 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UAS, The Rams seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy condition t o be operated. While Petitioner’s UAS will not have an airworthiness certificate, the FAA has determined that for the purposes of this exemption the pilot may determine the aircraft is in an airworthy condition prior to flight. The operating documents

cont ain procedures, which allow the PIC to determine whether the aircraft is in a condition safe for flight, and an exemption from § 91.7(a) is therefore warranted.

E. 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 91.203(a) and (b): Carrying Ci vil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry

airworthiness documents and other aircraft manuals onboard the aircraft.

6 FAA Docket No. FAA

- 2014

- 0352.

7 See Grant of Exemption No. 11213 to Aeryon Labs, Inc. (Docket No. FAA

- 2014

- 0642 at pgs. 8

- 9).U.S. Department of Transportation August 25, 2015 Page 9 Salans F MC SNR Denton
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Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may o perate 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 mate rial, 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 airworthin ess 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 l egible to passengers or crew.

Given the small size and configuration of the UAS, it would be impossible to keep airworthiness documents and other aircraft manuals on board the UAS because there is simply no room and the UAS has no cabin or cockpit.

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the U AS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 8 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot h as access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS. 9

8 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA

- 2014

- 0352 at 16

- 18.

9 See also Exemption No. 11213 to A eryon Labs, Inc. at pg. 11:

The petitioner requested relief from 14 CFR § 91.9(b)(2): Civil aircraft flight manual, marking, and
placard requirements and § 91.203(a) and (b): Civil aircraft: Certifications required. The FAA has
previously determined that r elief from these sections is not necessary. See Exemption No. 11062.
Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations.U.S. Department of Transportation August 25, 2015 Page 10 Salans F MC SNR Denton
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F. 91.103: Preflight Action

Petitioner 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 aircraft. While 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.

Adherence to the requirements in the operating documents will ensure that the UAS is in

an airw orthy condition prior to flight. The PIC will perform a series of checklists designed to identify any defects or inoperable components, which cover pre

- flight, take

- off, landing and

post

- flight procedures. The PIC will also be required to review weather, f light requirements, battery charge, landing and takeoff distance, UA performance data, and contingency landing

areas

— before initiation of flight. Petitioner's operating documents will be kept at the ground

control station and will be accessible to the PIC at all times while operating the UAS.

G. 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part 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." UAS and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a device that communicate s with the aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Given the size and speed of the UAS that Petitioner intends to use, an equivalent level of

safe trai ning can still be achieved without dual controls because no pilot or passengers are aboard the UAS, and as required by the operating documents, all persons will be a safe distance away in the event that the UAS experiences any difficulties during flight in struction. Moreover, all flight training will be conducted in controlled and sterile environment. As a whole, the procedures provided for in the operating documents ensure that UAS flight instruction can be performed safely.

H. 91.119(c): Minimum Safe Altitud es Over Other Than Congested Areas

The Rams requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 10 Section 91.119 prescribes the minimum safe altitudes under which aircraft

10 Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be

necessary. S ee e.g ., Grant of Exemption No. 11157 to Slugwear, Inc., dba Likeonatree Aerial at pg. 15 (Docket No.

FAA

- 2014

- 0534 ).U.S. Department of Transportation August 25, 2015 Page 11 Salans F MC SNR Denton
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may not operate, including 500 feet above the surface and away from any person, vessel, vehicle,

or structure in non

- congested areas. See 14 C.F.R. § 91.119(c).

An exemption is required because the proposed UAS operations will normally need to occur below 400 feet AGL. Additionally, due to the natur e of the proposed operations, the PIC and/or Observers may need to be less than 500 feet away from the UAS. Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel with the UAS, 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, as well the controlled location where t he operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to below 400 feet AGL. As set forth in the operating documents, the UAS will be operated in a controlled environment, and all flights will

occur a t a lateral distance of at least 500 feet from nonparticipating persons, unless that person is in a position where he or she is shielded from the UAS and any possible debris resulting from UAS failure. Procedures will be in place to ensure flight operation s can be safely terminated if a nonparticipating person within 500 feet of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller has granted permissio n and the PIC has made a safety assessment of the risk of operating closer to those objects, and operations near the PIC or Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in The Rams ' operating documents

will en sure the proposed operations can be conducted without compromising safety to persons or property on the ground.

I. 91.121: Altimeter Settings

To the extent necessary for The Rams to conduct the proposed operations, Petitioner requests 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 or barometric pressure.

The FAA has stated that an equivalent l evel of safety to the requirements of 14 C.F.R. § 91.121 can be achieved in circumstances where: (1) the UAS will be operated 400 feet AGL or below, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the

operator at a grou nd

- based on

- screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS.

The UAS that Petitioner intends to use for performing the proposed operations meet all

these operational characteristics. Moreover, the operating documents require the PIC to calibrate the aircraft's GPS compass prior to each flight operation. As the FAA has determined in circumstances similar to this Petition for Exemption, Petitioner's UAS and the safety mitigation procedures contained in the operating documents, ensure that an equivalent level of safety will be achieved, and a grant of exemption to the requirements of § 191.121 is therefore appropriate.U.S. Department of Transportation August 25 , 2015 Page 12 Salans F MC SNR Denton
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J. 91.151(a): Fuel Requirements for Flight i n VFR Conditions

The Rams requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in Visual Flight Rules (VFR) conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (consider ing 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 lea st 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30

- minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is the refore required.

The FAA has previously granted relief from the fuel requirements of § 91.151(a) for flight in daytime VFR conditions in circumstances similar to those presented in this Petition for Exemption. 11 In Exemption No. 11213 to Aeryon Labs, Inc. 12 , the FAA determined that a requirements prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there was enough available power for UAS to operate for the intended operational time and to operate after th at for at least five minutes or with the reserve power recommended by the manufacturer if greater, would ensure an equivalent level of safety to the fuel requirements of § 91.151(a). 13 Petitioner's operating documents impose this same requirements and an ex emption from § 91.151(a)'s fuel requirements for flight in VFR conditions is therefore appropriate.

VI. D RUG AND A LCOHOL P ROGRAM

The Rams has established policies to ensure that no person may participate in UAS flight operations if they are under the influen ce of alcohol or any drug.

VII. P UBLIC I NTEREST

The public interest will be served by granting The Rams ' Petition for Exemption. Congress has established a national policy that favors early integration of UAS into the National Air Space (NAS) in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act

— the FAA Administrator's assessment of whether certain UAS may opera te safely in the NAS before completion of the statutorily required rulemaking.

11 See e.g., Exemption Nos. 8811, 10808, and 10673.

12 Docket No. FAA

- 2014

- 0642.

13 Exemption No. 11213 at pg. 12.U.S. Department of Transportation August 25, 2015 Page 13 Salans F MC SNR Denton
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The proposed UAS operations in this Petition for Exemption significantly improve safety and reduce risk by alleviating the public's exposure to danger associated with tradition al aerial data collection methods, namely, full size fixed

- wing aircraft and rotorcraft. The UAS that The

Rams intends to use are light weight, are battery powered, and create no emissions. Moreover, in the unlikely event that one of Petitioner's UAS cras h, there is no fuel to ignite and explode. Any accident involving Petitioner's small lightweight UAS will present significantly less danger to the pilot and other individuals on the ground than one involving a full size helicopter.

VIII. P RIVACY

The proposed o perations will be conducted in accordance with applicable federal, state, or local laws regarding privacy. The Rams will not conduct flight operations over property that it does not own or control without the prior consent and knowledge of the property own er.

IX. F EDERAL R EGISTER S UMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

F EDERAL R EGISTER , should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 1 4 of the Code of Federal Regulations:

45.23(b); 45.27(a); 61.23(a) and (c); 61.113; 61.101(e)(4) and (5); 61.315; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(b); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with using conventional fixed

- wing aircraft or

rotorcraft for aerial data collection.

X. C ONCLUSION

Th e proposed operations in this Petition for Exemption satisfy the criteria articulated in Section 333 of the Reform Act and the FAA has issued grants of exemption in circumstances similar in all respects to those presented by The Rams in this Petition for E xemption. In consideration of the foregoing, this Petition for Exemption provides the FAA with all the necessary justification for granting the requested exemptions allowing The Rams to operate small UAS for the purpose of aerial data collection.

We t hank you for your prompt consideration of our requested exemptions. Should you have any questions, or if you need additional information to support the requested exemptions, please do not hesitate to contact us

.

Very Truly Yours,U.S. Department of Transportation August 25, 2015 Page 14 Salans F MC SNR Denton
McKenna Long

dentons.com

Mark E. McKinnon
Counsel for The Saint Louis Rams, LLC

Attachments