6/15/15
June 15th, 2015 by/for: Michael J Germond Owner/MGRM Orlando Stead icam LLC dba: Orlando Drones Contact Information: Phone: 616
-581-2274 Page 1 of 9

Email: mike@orlandosteadicam

.com www
.OrlandoSteadicam

.com Request for Section 333 Exemption Purpose: Closed set filming of motion pictures, music videos, web videos, corporate videos, television programs and commercials, and still photography This document constitutes an exemption Request under Section 333 ofthe FAA Modernization and Reform Act of 2012 for Aviation Unmanned to perform closed set filming of motion pictures, music videos, web videos, corporate videos, television programs and commercials, and still photography by/for Michael J Germond of Orlando Steadicam LLC , dba Orlando Drones

. The main use ofthis UAS would be for aerial photography/videography and photogrammetry

. The UAS systems that I plan to use include a DJIInspire 1 Quadcopter and a Kraken K130 Octocopter referenced in this document and also in the attached user manuals.

BACKGROUND AND COMPANY DESCRIPTION Orlando Steadicam LLC was established on 1/3/13 in the State of Florida. M ichael 

### J Germond is the sole Owner and Manager/Member ofthis company, and has been operating this company as a Sole Proprietor since 2008. The purpose ofthis company is to provide Stabilized Camera Support equipment to the Motion Picture and Television industry to be used in the production of Film, Television , Commercials, Music Videos, Corporate Events, and to enhance listings in the Real Estate industry

. Orlando Drones (dba) is the name under which Orlando Steadicam LLC wishes to operate our Aerial Photography and V ideography business to expand upon our long tradition of providing safe, expert camera stabilization to enhance the Motion Picture and Television industry

. Orlando Drones seeks to provide high quality imagery, dynamic footage previously unattainable due to size and dangers ofworking with full sized rotorcraft, and an exceptionally safe working environment for Film and Television productions in the United States

. Our clients may include but are not limited to Golf Courses, Real Estate agents, Automotive Manufacturers and Dealerships, Theme Parks, Hotels, Film Production Studios, and a variety of Commercial and Corporate clients. We believe that UAS is the safest and most economical method of obtaining photo and video for these clients who have previously used heavy rotorcraft or fixed wing containing explosive fuel and carrying civilians

. The6/15/15 Page 2 of 9 exemptions described herein would allow us to provide similar or better quality photo and video with the best Public Interest in mind.

THE UNMANNED AIRCRAFT (UA) DJIInspire 1 Quadcopter DJIInspire 1 airframe o Professional grade Carbon Fiber airframe o Dimensions: 43.8cm x 45

.1em x 30

.1cm o All Up Weight (AUW) : under 3.2 kg o Motors: 4 DJI 3510 350KV motors • Max thrust: 8.4 kg o Retractable landing gear o Support for (1) 5700mAh Lithium Polymer battery o Average Flight Time : 18 min DJI Inspire Flight Controller (FC) o Max Angular Velocity • Pitch: 300 deg/s • Yaw: 150 deg/s o Max Ascent Speed: 5 m/s o Max Descent Speed: 4 m/s o Max Ground Speed: 22 m/s o Built in DJI Lightbridge 2.4ghz Video/Remote Control wireless link (FCC licensed) Safety Features o Global Positioning System (GPS) • GPS Hovering Accuracy • Vertical: 0

.5 m • Horizontal: 2.5 m • Records GPS Home Point upon takeoff o Vision Positioning System (VPS) • Utilizes sonic waves to hold aircraft position close to the ground • Automatically deploys landing gear close to the ground during normal flight or in the event one ofthe FaiiSafes is triggered o Go-Hom

. e button • PIC can manually trigger "Return to Home" where the aircraft will ascend to a safe pre determined altitude and return to the launch point to land • VPS will deploy landing gear and automatically land the aircraft o Low Voltage FailSafe • Calculates remaining battery life based on current motor loads and computes time required to fly home and land before battery depletion

### 6/15/15 Page 3 of9

• Aircraft will follow the RTH procedures detailed above in the event of a Low Voltage warning o Remote Control lost-link FailSafe • Aircraft will follow the RTH procedures detailed above in the event of aRC Link Loss o Data logging • On board data logging system records flight details for aircraft diagnostics o Dynamic Home Point • GPS in the PIC's Remote Control can be used for the RTH procedure in the event that the landing location moves (ie

. filming with boats or cars) Kraken K130 Octocopter K130 Custom Airframe o Heavy duty Aluminum and Carbon Fiber frame o Dimensions: 179cm x 179cm x 64cm o Maximum All Up Weight (AUW) : 20 kg o Motors: 8 T-Motor U7 420KV motors • Max Thrust: 30 kg • Waterproof, Dirt Resistant o Retractable landing gear o Support for (2) 16,000mAh Lithium Polymer batteries o Average Flight Time: 12 min DJI A2 Professional Flight Controller (FC) o Max Angular Velocity: 150 deg/s o Ascent/Descent: 6 m/s o Max Ground Speed : 22 m/s o Bu ilt in 2.4ghz FASST Remote Control receiver (FCC licensed) o 

### 1

.2ghz Wireless Video transm itter (FCC licensed) Safety Features o Global Positioning System (GPS) • GPS Hovering Accuracy • Vertical: 0.5 m • Horizontal : 1.5 m • Records GPS Home Point upon startup o Go-Home button • PIC can manually trigger "Return to Home" where the aircraft will ascend to a safe pre determined altitude and return to the launch point to land • FC will deploy landing gear and automatically land the aircraft in the event a FailSafe is triggered o Low Voltage FailSafe • Dual level Low Voltage FailSafe alerts the PIC of a 30% battery remaining condition6/15/15 Page 4 of 9

• When the FC determines 10% battery remaining , the Aircraft will follow the RTH procedures detailed above o Remote Control lost-link FailSafe • Aircraft will follow the RTH procedures detailed above in the event of aRC Link Loss o Data logging • On board data logging system records flight details for aircraft diagnostics

GROUND STATION EQUIPMENT

- The OJ I Inspire 1 ground station is comprised of 2 Remote Controls via the 2.4ghz (FCC licensed) combined Video/RC wireless link o Primary controller is for the Pilot in Command (PIC) • Operates the Aircraft pitch, roll , yaw, and altitude • iPad Mini 2 on controller displays 4k HD video camera output shared with Camera Operator (CO) • Telemetry overlay displays speed, altitude, pitch/roll/yaw, GPS location, Home Point location, GPS satellites connected, battery life, strength of RC Link, strength of H D video link o Secondary controller (optional) is for the Camera Operator (CO) • Operates the camera gimbal and does not affect aircraft control • iPad Mini 2 on controller displays 4k HD video camera output • Telemetry overlay displays camera information as well as duplicates all PIC information

- The Kraken K130 ground station is comprised of 2 Remote Controls o Primary controller is for the Pilot in Command (PIC) • 2.4ghz (FCC licensed) frequency • Operates the Aircraft pitch, roll, yaw, and altitude • 1.2ghzVideo Receiver displays 480i Standard Definition (SO) video with Telemetry overlay from the First Person View (FPV) camera locked on the nose ofthe Aircraft • Telemetry displayed includes speed, altitude, pitch/roll/yaw, GPS location, Home Point location, GPS satell ites connected, battery life o Secondary controller (optional) is for the Camera Operator (CO) • 2.4ghz (FCC licensed) frequency • Operates the camera gimbal and does not affect aircraft control • 5ghz Video Receiver displays 1 080P High Definition (HD) video from the Movie Camera6/15/15 Page 5 of9 GROUND CREW Pilot in Command (PIC) Camera Operator (optional). The Camera operator controls the camera onboard the aircraft for photography and videography missions o For photogrammetry missions, the camera is locked in a fixed position and the Camera Operator is not necessary

- Visual Observer (VO). The visual observer will provide additional situational awareness during flight operations

OPERATIONAL PARAMETERS 1

. Neither UAS will exceed 551bs 2. Flights will be operated within visual line of sight ofthe PIC and VO 3

. Maximum total flight time for both UAS shall not exceed 30 minutes flight time 4. Flights for both UAS will be manually terminated at 30% battery remaining by the PIC, although FaiiSafes are in place to prevent batteries from being depleted in the event of an emergency 5. Flights will be operated at an al titude of no more than 400 feet Above Ground Level (AGL) 6. Minimum crew for each operation will consist ofthe PIC and the VO 7. The PIC for all missions shall be Michael 

### J Germond , Owner/MGRM of the company requesting exemption (Orlando Stead icam LLC) 8. The PIC shall have logged at minimum 50flight hours with each ofthe UAS Aircraft requested in this exemption 9. The PIC and VO shall be in Vocal or Radio Communication range of each other any time the UAS is in the air 10. The UAS will only be operated during daytime hours in VFR weather conditions 11

.Written and/or oral permission will be obtained from the property owner 12

.AII "No Fly Zones" shall be observed and avoided unless expressly granted by a COA 

### a. 5 nautical miles (NM) from an airport having an operational control tower; or b. 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or c
. 2 NM from an airport without a published instrument flight procedure or an operational tower; or d. 2 NM from a heliport with a published instrument flight procedure 13

. Maximum ground speed of 50mph PRE-FLIGHT CHECKLIST 1. Weather conditions are suitable for VFR flight and wind is 15mph or less 2. Measure battery voltage of Aircraft and UAS to make sure batteries are sufficiently charged before takeoff6/15/15 Page 6 of9
3. Ensure all motor arms are extended and locked in their flight position 4. Attach all propellers and check that they are secure, free from dirt, cracks, and chips 5. Verify all wiring connections are tight on the UAS and Groundstation 6. Power up all Groundstation equipment 7. Power up the RC Transmitters and ensure all switches are in their takeoff positions 

### a. K130: all switches down b. Inspire 1: all switches to the right 8. Install main UAS battery and check balance 9. Power up the UAS and allow automated startup calibrations to complete 10. Perform a manual Compass Calibration at takeoff location 11. Check the OSD Telemetry display to ensure the Flight Controller reads GPS mode for takeoff a
. Takeoff will be held until the GPS unit connects to a minimum of 10 GPS satellites as indicated by the OSD Telemetry 12

.Announce intention to take off by vocalizing "TAKING OFF"

DOCUMENTATION The following documents are attached and provided to support this petition OJI Inspire 1 User Manual v1.2 DJIInspire 1 Safety Guidelines v1

.0 Kraken K130 Manual v2 DJI A2 Flight Controller Quick Start Guide v1

.22 Motion Picture and Television Flight Operation Manual

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN EXEMPTION 

### A 14 C.F.R. Part 21 Certification Procedures for Products and Parts, Subpart H
- Airworthiness Certificates a
. Establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR§ 91

.203(a)(1 ). b

. Given the size and limited operating area associated with the UAS , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Seciton 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C. § 44701(f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt an Aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capabil ity, and proximity to airports and populated areas ofthe particular UAS

. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or6/15/15 Page 7 of 9 safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate under the same conditions. B

. 14 C.F.R. 

### §§ 61

. 113(a) and (b) Private pilot privileges and limitations 

### a. An exemption is requested from the limitation that a private pilot may not engage in compensation or hire operations. The UAS is remotely controlled by a ground-based operator, and all flights are planned and coordinated in advance

. The level of safety exceeds that provided by a sing le individual holding a commercial pilots certificate operating a conventional aircraft. The risks associated with the use of a UAS are so diminished from the risks associated with commercial operations so that an equivalent level of safety can be achieved by allowing UAS use by a private pilot. C

. 14 C

.F.R. 

### § 91. 7(a) Civil Aircraft Airworthiness a. While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart H, the airworthy condition ofthe UAS will be the responsibility ofthe PIC in accordance with 14 C.F.R. 

### § 91.7(b). D

. 14 C

. F

.R. 

### § 91.103(b)(2) General Operating and Flight Rules, Subpart B
- Flight Rules, Preflight action 

### a. Subpart B ofthis regulation states that the PIC, before beginning a flight, shall become familiar with runway lengths at airports of intended use b. As the UAS will not be flown at airports unless specifically granted under a COA, and has a vertical takeoff requiring zero runway distance, exemption from this rule is requested 

### E. 14 C.F

.R. 

### § 91.119(c) Minimum safe altitudes over congested and other areas 

### a. This regulation establishes safe altitudes for operation of civil aircraft over areas other than congested areas
. Orlando Drones requests relief from this section with respect to persons involved in the operation as well as vehicles and structures. The UAS will not be operated above 400ft AGL altitude. It will be operated in a defined area where people and buildings will not be exposed to operations without their pre-obtained consent F. 14 C

.F.R. 

### § 91.121 Altimeter Settings a
. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting avai lable before departure. " b

. As the UAS does not have a barometric altimeter, an exemption is requested. The UAS Flight Controller utilizes GPS equipment aided by a static pressure sensor to determine and maintain altitude

. The aircraft altitude above he takeoff point is provided in the video downlink telemetry information and provides6/15/15 Page 8 of9
sufficient information for the PIC to maintain altitudes at or below the 400ft (122meter) limitations

. G

. 14 C

.F

.R. 

### § 91

. 151 (a) Fuel requirements for flight in VFR conditions a
. Section 91

. 151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to f ly to the first point of intended landing, and, assuming normal cursing speed
- (1 ) During the day to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. " b. Given that the UAS aircraft only fly for a maximum of 30 minutes and carry on average 15 minutes of batter power, an exemption is requested

. The UAS operations are always conducted within a few minutes ofthe takeoff and landing point and within a restricted area. Orlando Drones believes that terminating the flight with 30% remaining battery power provides an equivalent amount of safety that is intended by section 191

.151 (a). H

. 14 C.F

.R. 

### § 91.405(a) Maintenance Required ; a. 14 C.F.R. 

### § 91.407(a)(1) Operation after maintenance, preventative maintenance, rebuilding or alteration; b

. 14 C.F

.R. 

### §§ 91.409(a) (1) and (2) Inspections; c. 14 C

.F.R. 

### §§ 91.417(a) and (b) Maintenance Records; 1. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section have discrepancies repaired as prescribed in part 43 ofthis chapter.

.. ," and others shall inspect or maintain the aircraft in compliance with part 43. ii. Given that the sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the operator pursuant to the Owner's Manuals

. An equivalent level of safety will be achieved because these small UAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time

. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initial flight, perform required maintenance and keep a log of any maintenance performed

. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety

. The FAA issued exemption to these regulations in Exemption No. 11062

.6/15/15 Page 9 of 9 SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER Petitioner : Orlando Steadicam LLC , dba: Orlando Drones Sections of 14 

### C. F. R Affected: Part 21 , Subpart H; 

### §§ 61

. 113(a) and (b) ; 

### § 91.7(a); 

### § 91.119(c) ; 

### § 91.121; 

### § 91

.151(a); 

### § 91.405(a); 

### § 91.407(a)(1); 

### §§ 91.409(a)(1) and (2) ; 

### §§ 91.417(a) and (b) Description ofReliefSought : Orlando Steadicam LLC, dba: Orlando Drones seeks relieffrom the requirements of 14 C.F.R. Part 21 , Subpart H; 14 C

.F

.R. 

### §§ 61.113(a) and (b) ; 14 C.F

.R. 

### § 91

.7(a) ; 14 C.F

. R. 

### § 91.119(c) ; 14 C

.F.R. 

### § 91.121 ; 14 C

.F.R. 

### § 91

.151 (a) ; 14 C.F

.R. 

### § 91.405(a) ; 14 C.F.R. 

### § 91.407(a)(1 ); 14 C

.F

.R. 

### §§ 91.409(a)(1) and (2); 14 C.F

.R. 

### §§ 91.417(a) and (b) to operate small unmanned aircraft systems (UAS) for the purpose of closed set filming of motion pictures, music videos, web videos, corporate videos, television programs and commercials and still photography
Respectfully submitted,

Michael 

### J Germond Owner/MGRM Orlando Steadicam LLC dba: Orlando Drones 6550 Kings Cote Ave Apt 102 Orlando, FL 32835 Phone: 616-581-2274