July 22, 2015

Exemption No. 12117 Regulatory Docket No. FAA

– 20 15

– 1079

Mr. Gregory S. Walden Akin Gump Strauss Hauer & Feld LLP Counsel for InterMedia Development Corp d/b/a AERO Robert S. Strauss Building 1333 New Hampshire Avenue, NW. Washington, DC 20036

- 1564

Dear Mr. Walden :
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter dated April 13, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of InterMedia Development Corp d/b/a AERO ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial c inematography services, news gathering services, aerial sensor data collection, aerial surveying and photogrammetry, aerial communications services (Wi

- fi hotspot, FM radio transmission, VHF radio repeater, cellular), and airborne emergency services suppor t (reconnaissance and communications)

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.2

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom, DJI S800, DJI S900, DJI S1000, Arris hexacopter and Tarot quadcopter

. The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secre tary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21
, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates
, and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision
You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or

cre w, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.
Having reviewed your reasons f or requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, InterMedia Development Corp d/b/a AERO is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)
, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collectio n

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, InterMedia Development Corp d/b/a AERO is hereafter referred to as the operator.
Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom, DJI S800, DJI S900, DJI S1000, Arris hexac opter and Tarot quadcopter when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.
2. Operations for the purpose of closed

- set motion picture and tel evision filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certifi cate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VLOS4
capability. The VO and PIC must be able to communicate verbally at all times ;
e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designa tion for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also pre sent updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petit ion for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure th at it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.
, inoperab le components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition fo r safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.5

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and main taining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (trai ni ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operat ions may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual f light rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport sym bo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If t he UAS loses communications or loses its GPS sign al, the UA must return to a pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.6

20. The PIC is prohibit ed from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by t he manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to con duct operations that cannot be conducted under the terms of the attached COA

.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) mar kings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.7

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phon e number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to th e inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential t o accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.
Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8
This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded.
Sincerely,

/ s/ John S. Duncan Director, Flight Standards Service

EnclosuresApril13, 2015

United States Department of Transportation Federal Aviation Administration Docket Management System 1200 New Jersey Avenue, NE Washington, DC 20590

Filed in www.regulations.gov 

# AkinGump

STRAUSS HAUER & FELD LLP

GREGORY 5. WALDEN
+1 202.887.4213/fax: +1 202.887.4288 gswalden@akingump.com

Re: Petition for Exemption oflnterMedia Development Corp, d/b/a AERO, under Section 333 of the FAA Modernization and Reform Act, 49 U.S.C. 44701(f), and 14 C.F.R. Part 11

On behalf oflnterMedia Development Corp ("IDC"), d/b/a AERO, we hereby seek an exemption from certain Federal Aviation Regulations enumerated below, as authorized by Section 333 of the FAA Modernization and Reform Act ("Section 333"), Subsection 44701(f) of the Federal Aviation Act, and pursuant to the procedures set forth in Part 11 of the Federal Aviation Regulations, to allow IDC to operate the Inspire 1 quadcopter, the Phantom quadcopter, and the S800, S900, and S 1000 hexacopters, all manufactured by DJI; and two vehicles assembled by IDC

- both with DJI flight controllers

- the Arris hexacopter and the Tarot quadcopter, to provide:

• Aerial cinematography services

• News gathering services

• Aerial sensor data collection

• Aerial surveying and photogrammetry

• Aerial communications services (Wi-fi hotspot, FM radio transmission, VHF radio repeater, cellular)

• Airborne emergency services support (reconnaissance and communications)

Except in two respects as explained below, IDC will comply with the same conditions and limitations as provided in numerous section 333 exemptions granted recently. Accordingly, we respectfully ask the FAA to grant this petition in summary fashion, and obviate Federal Register publication and public comment.

IDC provides television and digital media production services, communications systems design and engineering, and mobile app development services to government and commercial

RobertS. Strauss Building 11333 New Hampshire Avenue, N.W. 1 Washington, D.C. 20036-1564 1202.887.4000 1 fax 202.887.4288 I akingump.comInterMedia Development Corporation Petition for Exemption April13, 2015 Page 2 of7

organizations. The company was founded in 1996, as a documentary television producer, and later expanded into defense contracting to provide mission-critical technical (SME) support to DOD agencies: USSOCOM, USASOC, Army PSYOP, CENTCOM, NAVAIR, USAF and other organizations. The company's focus is on integrating emerging technologies to fill existing requirements of our clients and sponsors, while forging new opportunities borne of innovation and collaborative partnerships.

The name of the applicant is InterMedia Development Corp d/b/a AERO. The primary IDC
contact is Mr. Joel Ratner, 4000 Legato Road, Suite 1100, Fairfax, Virginia 22033. Telephone is 703-896-7722. His email isjoel@idc-tv.com and IDC's web address is www.idc-tv.com.
Exemptions requested

14 C.F.R. Part 21 (airworthiness certification) 14 C.F.R. Part 27 (normal category rotorcraft) 14 C.F.R. 61.113 (a) and (b) (pilot certification and qualification) 14 C.F.R. 91.7(a) (airworthiness) 14 C.F.R. 91.119(b) and (c) (minimum safe altitudes) 14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions) 14 C.F.R. 91.405 (a) and (b) (maintenance) 14 C.F.R. 91.407(a)(1) (approval for return to service) 14 C.F.R. 91.409(a) (annual and airworthiness certification inspection) 14 C.F.R. 91.417(a) and (b) (maintenance records)

Safety equivalence or no adverse effect on safety

Unmanned Aerial Vehicles and Systems

The DJI flight controller, the common control platform in the listed devices, has a number of technological capabilities to demonstrate its airworthiness. In the event of a loss of GPS signal, the UA V will lock in its position and automatically go to ATTI mode and remain stable. Loss of connection to the remote control transmitter (or software navigation controller) causes the vehicle to immediately achieve a preset altitude, and then return to its home point and land in a controlled way.

All of the UAVs intended for use contain a power storage monitoring system and fail-safe modes
to force controlled landing before the power supply drops below operational levels. Should there be a loss of power, the aircraft are designed to perform a vertical hard landing with propellers providing stabilizing resistance during descent.

If the UA V encounters an unexpected obstacle, the pilot will either divert the flight or maintain the UA V in a safe hover position away from the obstacle.InterMedia Development Corporation Petition for Exemption April 13, 2015 Page 3 of7

Given its small size, operational capabilities, and restricted area in which the UAV will operate,

an exemption from Part 21, Subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted, as IDC's UAV satisfies the equivalent level of safety as compared with manned aircraft and meets the criteria in section 333. Operating the UAV without an airworthiness certificate in the restricted environment over vacant private property under the conditions proposed will be safer than operating a manned helicopter operating with an airworthiness certificate and not subject to such conditions.

Each UA V (with payload) is less than 55 pounds, carry no explosive materials or flammable liquid fuels, and would operate outside controlled airspace, with no passengers or crew on board. As the FAA has found in granting an exemption to Clayco, Exemption No. 11109, at page 10:

The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident. The risk
to an onboard pilot and crew during an incident or accident is eliminated with the use of a U A V for the aerial operations.

For the reasons outlined above, IDC also seeks an exemption from the certification requirements for normal category rotorcraft in Part 27.

In support of IDC's request for an exemption from 14 C.F.R. 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), IDC will adhere to the following inspection and maintenance program: IDC will inspect the UAV before and after each operation, as well as perform daily, weekly, monthly, and annual inspections, as set forth in its operations manual. Before each flight, the pilot in command will inspect the UAV to ensure it is in a safe condition for flight. The preflight inspection will account for any discrepancy, such as an inoperable component, item, or equipment. IDC will not initiate a flight if the inspection reveals a condition that adversely affects the safety of operations, and will not operate that UAV until it is found to be in a safe condition. Any UA V that has undergone maintenance or an alteration that affects the UAV's operation or flight characteristics will undergo a functional flight test before return to service.

IDC will follow the manufacturer's UAV requirements relating to components, maintenance, overhaul, replacement, inspection and life limits. IDC will record all maintenance, alterations, and the functional flight test in the UA V logbook, including total flight hours, description of work accomplished, and the signature of the UAV technician who returned the UAV to service. 1

IDC's UAVs are equipped with an altimeter that provides the pilot with a constant digital display of altitude. Moreover, the UAVs will be operated within the visual line of sight of the pilot in command and observer and below 400 feet AGL. 

### In addition, the flight controllers are programmed not to allow the aircraft to exceed the 400 feet ceiling, even if the pilot command

1 Manufacturer and operating manuals will be provided separately.InterMedia Development Corporation Petition for Exemption Aprill3, 2015 Page 4 of7

input is in-conflict, or if communication with the remote control transmitter fails. Accordingly, IDC does not believe an exemption from 14 C.P.R. 91.121 is required.

In support ofiDC's request for an exemption from fuel requirements in 14 C.P.R. 91.151(a) and (b), IDC notes that its UA V is battery-powered and is operated for brief periods of time, within the battery capacity of the U A V.

The remote control transmitter/receiver combinations will work within the 2.4 GHz and 5.8 Ghz FCC-approved ranges.

UA V and UAS Operator Qualifications and Training

In support of IDC's request for an exemption from the pilot certification and qualifications requirements in 14 C.P.R. 61.113(a) and (a), IDC asserts that an equivalent level of safety is achieved by the UA V -specific experience of its Pilots. Each IDC pilot will receive a commercial UAS training course and then receive flight training using the DJI Phantom, Inspire 1, S800, S900, SlOOO, Tarot and/or Arris UAS.

IDC recognizes the FAA's position that section 333 does not allow the FAA to waive the requirement of a U A V operator to hold an airman certificate, relying on section 44 711. Section 333 is a more recent enactment and provides explicit authority to the FAA to exempt a UA V operator from any certification requirement. Section 333 instructs the FAA to consider whether to require airworthiness certificates, certificates of waiver, and certificates of authorization, "at a minimum." Thus, Congress vested FAA with discretion to waive certificate requirements other than an airworthiness certificate, including an airman and medical certificates.

Even if the pilot certification requirement is not waived, FAA has exemption authority under section 44 701 (f) to exempt UA V operators from the particular requirements of Parts 61 and 67

- such as the requirement to conduct flight training on board an aircraft

- and develop airman certification requirements specifically designed for small UA V operations. Applying manned aircraft pilot certification requirements to small UAVs is not necessary as a matter of safety, and does not make sense as a matter of public policy.

IDC believes that FAA's determination in the Astraeus Aerial and other exemptions that a commercial pilot certificate is not required for the operators of UAVs for closed set filming, set forth below (emphasis added), applies equally to the nature of its UAS operations:
[T]he experience obtained beyond a private pilot certificate in pursuit of a commercial pilot certificate in manned flight does not necessarily aid a pilot in the operational environment proposed by the petitioner; the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through VAS-specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing.InterMedia Development Corporation Petition for Exemption April 13, 2015 Page 5 of7

IDC believes this reasoning supports a UAVIUAS-focused training and experience regimen that should obviate not only a commercial pilot certificate but also a private pilot certificate because
any training will be focused on the particular skills of operating the particular small U A V and the particular nature ofUAS operations.

IDC notes that the FAA has proposed in its recent sUAS Notice of Proposed Rulemaking that a small UAS operator would be required to successfully complete an aeronautical knowledge test, but would not be required to obtain a commercial or private pilot certificate. Also, medical certification would be obviated by a pilot's self-certification before flight that the pilot is physically and mentally fit to operate the UAS.
Accordingly, the FAA should grant appropriate exemption relief to permit IDC to use pilots who have successfully completed commercial UAS training and have also gained flying experience using the DJI Phantom, Inspire 1, S800, Arris, or Tarot UAV. In the event the FAA does not grant such relief, IDC will employ a suitably certificated private pilot.

UA V and UAS Operating Parameters

IDC will operate its UA V s in full compliance with any local permit or safety ordinance, in accordance with its manual. IDC's typical flight will be operated under 400 feet AGL and within 2 km of the operator.

All flights will be conducted within the visual line of sight of the pilot in command, within noncontrolled airspace, with the consent of any property owner and/or developer. Although the UAV may be operated in a metropolitan area, it will be controlled and monitored only by authorized personnel, and be flown below 400 feet AGL, except in rare occasions where a sponsoring agency or organization requires data from higher altitudes, or where the terrain below would require extreme maneuvers to comply with the altitude restriction. However, in such rare
cases, appropriate pre-flight site surveys would be undertaken (where possible) to minimize any risk of collision or any negative impact with any aircraft operations in that airspace, and in any event all such operations would be within the visual line of sight of the operator. For any operations over 400 feet AGL, IDC will coordinate with Air Traffic Control and obtain a Certificate of Authorization if required. Thus, these rare and brief operations at an altitude over 400 feet AGL will pose no risk to manned aircraft. Accordingly, IDC requests that standard term 4 be revised to permit IDC to operate its UAVs higher than 400 feet AGL when authorized by Air Traffic Control.

IDC will also notify the appropriate Flight Standards District Office "("FSDO") and Air Traffic Control for any operation within five miles of an airport.

IDC will conduct a briefing before each day's operations, which all personnel participating in the operations must attend. IDC will obtain written consent of any person who will be participating in the operations or otherwise be on the private property where operations are to take place. IDC will provide notice to any adjacent buildings or structures.InterMedia Development Corporation Petition for Exemption Aprill3, 2015 Page 6 of7

IDC will limit its operations to daytime Visual Flight Rules ("VFR").

IDC seeks an exemption from the requirement in 14 C.F.R. 91.119, subsection (b), that an aircraft must remain at least 1,000 feet above any congested area or open air assembly of
persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or
structure in an area other than populated or congested, and not closer than 500 feet to any person, vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft operations in mind. While IDC may operate its UAVs in a metropolitan area, the operations will
be carefully pre-planned to minimize risk to persons or property, avoid intrusion into unauthorized airspace, and avoid a public annoyance. Its UAVs will not be operated over a highly-congested area or open air assembly of persons.

IDC will make every reasonable effort to ensure that no unauthorized person will be on the land

over which the UAVs will be operated, and will provide notice to adjacent buildings and furnish proctors as may be necessary to ensure that unauthorized persons do not come within the narrow parameters in which the UA V s will be operated. Combined with the technological capabilities
of the UAVs and that the UAVs will be operated within the visual line of sight of the pilot and an observer, IDC submits that its operational limitations provides an equivalent level of safety to that provided in section 91.119.

For news gathering operations as well as for emergency services support, IDC seeks a revision to standard term and condition 27, which provides that "All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted." For news gathering and
emergency services support operations, it would be impractical to require advance notice and approval from private property owners. Precautions outline above will be taken by IDC to minimize any risk to persons on the ground.

Public interest

IDC's UAS operations will substantially benefit public and private organizations which have an interest in gathering critical information

- atmospheric, situational, etc.

- to support their operations. Depending on the use-case, these scenarios may include:

• aerial cinematography or photography (in support of government, commercial or nonprofit organizations)

• the gathering of sensor data to document or provide real-time awareness of potential radiologic or biohazards present in an operational area,

• traffic or construction monitoring,

• ecological, agricultural or land management surveying,

• infrastructure surveying and improvement,InterMedia Development Corporation Petition for Exemption April 13, 2015 Page 7 of7

• area-specific communications (specifically FM radio, Wi-fi, and cellular- in accordance with existing FCC guidance).
Additionally, news-gathering organizations that would normally utilize fixed cameras, mobile ground camera crews, or manned aircraft in support of their news operations, would be able to receive transmitted video via IDC's UAVs without risking air-crews during potentially hazardous situations, while minimizing intrusion into the airspace above the situation of interest.
Operating U A V s under the limitations proposed by IDC will avoid any risk of harm to pilots as well as persons and people on the ground that would be present during the operation of manned helicopters. UAS operations will also require a much smaller energy footprint than with manned helicopters.
Operations limited to the United States

IDC does not intend to operate its UAVs outside ofthe United States.
Summary for Federal Register

Should the FAA determine that publication of a summary is required, IDC submits the following
summary to be included in the Federal Register:

IDC seeks an exemption to operate the DJI Inspire 1, S800, S900, S 1000, and Phantom unmanned aircraft systems, and the Arris and Tarot unmanned aircraft systems, all with DJI flight controllers, to perform commercial and emergency services.
Sincerely,