**Private and Confidential**

**Sean T.**  **Graham (Soaring Services, LLC**  of Florida **)**

- Section 333 Exemption Petition U. S. Department of Transportation

& Federal Aviation Administration (FAA)

11/15/2015 U. S. Department of Transportation , Docket Operations Management System We st Building Ground Floor, Room W 12

- 140 1200 New Jersey Ave, SE Wa shington, DC 20590

**Re** : Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61 .113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) Dear Sir or Madam, **Soaring Services, LLC** ( of Florida ) , is writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that , **Soaring Services, LLC** , an owner and business operat ion of small unmanned aircraft, be exempted (for a length as long as possible/authorized) from t he Federal Aviation Regulatio ns ( “FARs”) listed below so that , **Soaring Services, LLC** , and those working for/under the company may operate small ultra

- lightweight unmanned aircraft system s (“UAS”) in commercially regulated airspace by the Federal Aviation Administration (“FAA”).
Following exempt ion and approval by the FAA, **Soaring Services, LLC** , will primarily use professionally built DJI Phantom 3 ( UAS ) , DJI Phantom X (UAS), DJI Inspire (UAS), and Yuneec Typhoon Q500 (UAS) equipped with cameras for the following applications: Clo sed

- Set Film Operations on Film and Television Productions; aerial v ideography/cinematography to safely enhance films and commercials; augmentation of real estate listings pictures and videos; the creation of visual and topography layout videos for Search and Rescue (SAR) operations and other missions for state and local agencies ; education; 3D mapping; agricultural inspections ; and building/construction zone inspections.2

2 Our, **Soaring Services, LLC** , exemption request would permit the operation of ultra

- lightweight , unmanned (i.e. piloted by remote control) UAS’s for the development of community and government use videos, permissible within property boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to preven t catastrophe. Furthermore, it is my intent to assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific video and photography usage by sharing information with the FAA as, **Soaring Services, LLC** , record flight data and other pertinent information gained through permitted flight operations. In addition, granting our company’s, **Soaring Services, LLC** , exemption request will comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Real tor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, closed

- set motion picture fil m operations and television, structure inspections, and to aid state and local agencies

. Further, **Soaring Services, LLC** , will conduct operations in compliance with the protocols described herein or as otherwise established by the FAA. F or the reasons stated below, we , **Soaring Services, LLC** , respectfully request the g rant of an exemption allowing us to operate ultra

- lightweight , remote controlled UAS’s to aid academic community awareness, to benefit/stimulate attraction to the State of Florida and to enhance personal and public video feeds. A grant that will ultimately allow UAS’s to play a more po sitive role in our local community by increasing employment opportunities, heightening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel

- a potential public hazard in and of itself.3

3 I. Contact Information: **Sean T.**  **Graham (Soaring Services, LLC)**  1275 US Highway 1 P O Box 321 Suite #2 Vero Beach, FL 32960 *P O boxed used due to privacy protection requirements meet* Phone: 321

-446

- 3998 Email: ST G31885@yahoo.com II. The Specific Sections of Title 14 of the Code of Federal Regulations From Wh ich **Soaring Services, LLC**  Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). III. The Extent of relief **Soaring Services, LLC** s eeks and the Reason He Seeks Such Relief: I, **Sean T.**  **Graham (Soaring Services, LLC)**  , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicabl e FARs operating to prevent **Soaring Services, LLC** contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for s uch integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. **Soaring Services, LLC** ultra

- lightweight UAS ’s meet/will meet the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra

- lightweight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra

- lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may o perate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of si ght. 112 P.L. 95 § 333 (a).4

4 Each of these items reflect i n favor of an exemption for **Soaring Services, LLC**

. Most of m y UAS’s utilize four (4) rotating propellers for balance, control and stability. Most of m y UAS’s are equipped with the followi ng via video and data telemetry: 1) Altimeter 2) Attitude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery Left with approximate time. 11) Loiter and circle mode. 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology. Each UAS weighs less than the maximum 55 pound limit; including camera(s) with or withou t g imbal (a camera stabilizer). **Soaring Services, LLC** considers safety as foremost with each flight. Our small unmanned aircraft are designed to hover in place, circle in a specific place or loiter via GPS and can be operated in high winds ; however for safety, stability , and fear of financial loss I will not fly in winds excee ding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released or lost

. Wi th multiple modes to choose from, **Soaring Services, LLC** will fly with the modes safest to complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. Wh en pilot commun ication from the radio control is lost our UAS ’s are designed to slowly descend to the point of takeoff and/or to land at point of launch after ascending to a pre

- set altitude to ensure the UAS will clear any obstacles that may be between the takeoff point and the c urrent position of the UAS. The failsafe altitude will not be set more than 200ft and is determined before each flight.5

5 **Soaring Services, LLC** will not operate UAS’s near airports, hospitals nor police heliports, and will not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on locati on, conditions and weather. I will be constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect a manned aircraft m ay approach near my location. Our UAS’s are capable of vertical a nd horizontal operations, and are flown within the pilots line of sight. Our UAS’ s are also flown with a second operator who aids in watching for any obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flig hts generally last from ten (1 0 ) to twenty ( 20 ) minutes , with an altitude under two
- hundred ( 200) feet. Smart Mode includes, position hold, self

- leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. **Soaring Services, LLC** will utilize a fresh fully charged battery with each flight as a safety precaution. W e will not operate our UAS ’s at or below manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS ’s to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for suffi cient safe level of operation. W e (I) do not believe in taki ng risk that may cause a crash thus creating a potential hazard to the public/property/manned aircraft . In addition, I do not want to lose our (my) investments (UAV’s )

. Our pilot(s) and I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of these specific UAS' s performance s under different temperature and weather conditions. This will also be completed for all future purchases of UAV’s prior to utilizing for commercial purposes. We(I) have practice d computerized simulated flights to maintain adequate skills an d response reflex time. All for the sake of safety. We , **Soaring Services, LLC,** will be extremely cautious when operating UAS ’s/ultra

lightweight unmanned aircraft ’s and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls we ll within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. **Soaring Services, LLC**  UAS ’s will demonstrate an excellent safety record prior to flight so as not to pose any threat to the general public or national security. IV. How **Soaring Se rvices, LLC**  Request W ill Benefit the Public As A Wh ole: Aerial videography for geographical awareness, education, search and rescue, land management, structure inspections , and for real estate marketing have all bee n around for a long time via manned fixed wing aircraft and helicopters. For small budget companies, average homeowners , and property owners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expens e; depriving non

- luxury owners and lower budget companies from a valuable marketing tool. Manned aircraft pose a threat to the public through a potential catastrophic crash that6

6 communities have experienced in the past with military aircraft, medical helicopters, and news helicopters crashes. Each resulting in loss of life. Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard l andings

. **Soari ng Services, LLC**  UAS ’s pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national ai rspace system, hence the passing of the Reform Act. Granting **Soaring Services, LLC**  exemption request furthers the public interest through academic/visual awareness of the geographical b enefits in and around the area. Our ultra

- lightweight UAS ’s are all battery powered and create no emissions that can harm the environment. The consequence of our ultra

- lightweight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel , and can cause catastrophic devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra

- lightweight UAS's. Permitting us **Soaring Services, LLC**  to immediately fly wit hin national air space furth ers economic growth. Granting our exemption request substantially fu rthers the economic impact of my area and the surrounding community for companies looking to relocate or build around my area as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community. V. Reasons W hy **Soaring Services, LLC** Exemption Wi ll Not Adversely Affect Safety Or How The Exemption Wi ll Provide a Level of S afety At Least Eq ual To Existing Rule: Our , **Soaring Services, LLC** exemption will not adversely affect safety. Quite the contrary, for th e reasons stated permitting **Soaring Services, LLC** to log more flight time in FAA controlled airspace, with communica tion with the FAA, will allow us to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors, land , and structured owners. For development in cooperation with the FAA. In addition **Soaring Services, LLC**  submit the following representations of enhancements to current aerial videography and photography: Our UAS’s total weigh t is less than the maximum 55 pound limit. Weonly operate our UAS ’s below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); Our UAS ’s only operate for 3

- 25 minutes per flight; we land our UAS ’s prior to manufacturer recommended minimum level of battery power; we pilot our UAS ’s through remote control only by line of sight; and have live video feed fo r monitoring video recording; we receive a live telemetry feed from our UAS ’s during all flights wh ich include remaining battery voltage, distance, altitude, and any anomali es that may occur during flight.
Our UAS’s Command and Control utilize 5.8 GHz for its control frequency in accordance with CFR 47, Part 15 for model aircraft use. Our UAS’s camera system utilizes 2.4 GHz to supply the video feed in accordance with CFR 47, Part 15. Our UAS’s have a GPS contro lled flight controller

- a flight safety feature whereby it hovers and then lands at the GPS takeoff point if communication with the remote control pilot7

7 is lost; we actively record and analyze flight data through the flight controller app lication (s) to co nstantly update and enhance safety protocols; we only operate in reasonably safe environments ; we conduct extensive preflight inspections and protocol, during which safe ty carries primary importance; we always obtain all necessary permissions prior to operation; and, we have procedures in place to abort flights in the event of safety breaches or potential danger. **Soaring Services, LLC** safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS ’s into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness real estate, structured inspections, land management and search and rescue. W hile the safety record of such helicopters is remarkably astounding, t here has been incidents involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

- lightweight UAS. First, the potential loss of life is diminished because UAS' s carry no people on board and we only operate our UAS ’s in specific areas away from mass populations. Second, there is no fuel on board our UAS ’s and thus the potential for fire or explosio ns is greatly diminished. Third, the small size a nd extreme maneuverability of our UAS ’s allow us to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enou gh to capture amazing images, o ur UAS ’s need not be so close to the objects they are focused on through the technology and use of post editing sof tware allowi ng pan and zoom. Accordingly, our UAS ’s has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. VI. A Summary The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of our , **Soaring Services, LLC** , UAS ’s permits exemption from Part 21 because our UAS ’s meet (and exceed ) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of l egislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as ai rports and dense populations. Our , **Soaring Services, LLC** , current and pro

jected UAS's meet/will meet or exceed each of the elements.
14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined.8

8 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 rega rding altimeter settin gs is inapplicable insofar as our UAS ’s utilize electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by **Soaring Services, LLC**

. B. 14 C.F.R. § 45.23: Marking of th e Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked accordi ng to certain specifications. Our UAS ’s can be marked with the appropriate “N” number once this “N” number has been given. C. 14 C.F.R. § 61.113: Private Pilot Privile ges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non - commercial operations. **Soaring Services, LLC**  members (employees and/or contractors) who are the PIC will possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61. D. 14 C.F.R. 91.119 : Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 300fclose AGL; safely below the standard of 400 AGL. **Soaring Services, LLC** will opera te our UAS ’s in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS ’s , an equivalent or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2, Manual

The above

- cited Regulations require, amongst other thi ngs, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to our , **Soaring Services, LLC** UAS ’s

. H owever, as a safety precaution we inspect our UAS ’s before and after each flight. If th is regulation should be required in the future then we will abide by set regulations. A Summary ; The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, ent itled9

9 Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because our , **Soar ing Services, LLC**  , UAS ’s meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as ai rports and dense populations. Our UAS ’s meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91. 9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previo usly issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safe ty will be achieved. In summary, **Soaring Services, LLC** , seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C. F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate our , **Soaring Services, LLC ,**  small unmanned vehicle/lightweight unmanned aircraft vehicle s in community awareness, education, structural inspection land management, search and rescue and real estate operations, and to develop economic pl atforms for the aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate and to find in our area s
.

**F. A dditional FAA** 

**Required Operating Conditions and Limitations**

Wh en not covered elsewhere in this Operations Manual, the following conditions and limitations apply:

1. The UAS must weigh less than 55 pounds (25kg), including energy source(s) and equipment 2. The UAS may not be flown at a speed exceeding a ground speed of 85 knots.10

10 3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL. 4. The UAS 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 state driver’s license. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. If a discrepancy exists between these limitations and any procedure outlined elsewhere in this operations manual, the conditions and limitations herein take precedence and must be followed. 7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safeoperation 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 for safe flight. The Ground Control Station, if utilized, must be included in the preflight insp ection. All maintenance and alterations must be properly documented in the aircraft records. 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 in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. 9. The operator must follow the manufacturer's UAS aircraft/co mponent, maintenance, overhaul, replacement, inspection, and life limit requirements. W hen unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manua l. At a minimum, the following must be included in the operator's manual: a. Actuators / Servos b. Transmission (single rotor)

c. Powerplant (motors) d. Propellers e. Electronic speed controller11

11 f. Batteries g. Mechanical dynamic components (single rotor) h. Remote command and control i. Ground control station (if used) j. Any other components as determined by the operator 10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a curren t state driver’s license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 11. Prior to operations conducted for the purpose of motion picture filming ( or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a simila r UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered non - participants, and the PIC must operate the UAS with appropriate distance from non

participants in accordance with 14 CFR § 91.119. 12. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CF R § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off and landing currency flights, all persons not essent ial for flight operations are considered non

participants, and the PIC must operate the UAS with appropriate distance from non

- participants in accordance with 14 CFR § 91.119.12

12 13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request. 14. Prior to operations conducted for the purpose of motion picture filming (or similar ope rations), a flight demonstration, administered by an operator

- approved and

- qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmansh ip test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual. 15. The UAS may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency. 16. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting production personnel. At all times, those persons must be essential to the closed

- set film operations. Because th ese procedures are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent with the manned aircraft procedures des cribed in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television Filming

. 17. Regarding distance from non

- participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may b e determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers,13

13 etc. Such barriers may protect non

- participating persons (observers, the public, news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UAS must return to a pre
- determined location within the security perimeter and lan d or be recovered in accordance with the operator’s manual. 18. If the UAS loses communications or loses its GPS signal, the UAS must return to a pre
determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. 19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 20. Each UAS operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first. 21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the o perator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance wi th 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. The operator must develop procedures to document and maintain a record of the UAS maintenance, preven tative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator’s manual. 24. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual. 26. The preflight inspection section in the operator’s manual must be amended to include the following requirem ent: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual.14

14 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. At least three days before schedu led filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area 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 phone number of the person responsible for the UAS filming production under this grant of exemption c. Name and phone number of the person responsible for the on

- scene operation of the UAS. d. Make, model and serial or N

- number of the UAS to be used e. Name and certificate number of the UAS PIC's involved in the filming production event 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 the inspector upon request. g. Signature of exemption

- holder or representative h. A description of the fl ight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation 29. The documents required under 14 CFR § 91.9 and § 91.203 must be avail able 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. 30. The UAS must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 31. 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 flight rules (SVFR) are not authorized.15

15 32. The UAS cannot be operated by the PIC from any moving device or vehicle. 33. The UAS may not be op erated 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. 34. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 miles of the geographic center of a non

-towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a N OTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the Federal Aviation Administration’s (FAA) 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 W eb site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting our , **Soaring Services, LLC** , requests for exemption will reduce current risk levels and thereby enhance safety. Our UAS ’s craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with m uch less flight time. Further, we operate at lower altitude s and in controlled airspace eliminating potential public risk flying to a nd from established airfields. W e , **Soaring Services, LLC** , have been informally analyzing and recording flight information and will compile safety protocols and the implementation of a flight operations manual for usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with t he FAA Modernization and Reform Act of 2012. Th ere are no personnel on board our , **Soaring Services, LLC** , UAS ’s and therefore the likelihood of death or serious bodily injury is significantly diminished. Our , **Soaring Services, LLC**  , operation of UAS ’s , weighing less than fo rty (40) pounds and traveling at lower speeds within limited areas low to the ground will provide an equivalent level of safety as that achieved und er current FARs. Accordingly W e , **Soaring Services, LLC** , respectful ly request that the FAA grant our exempt ion requests and we are willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.16

16 Respectfully submitted, **Sean T.**  **Graham (Soaring Services, LLC)**  1275 US Highway 1 P O Box 321 Suite #2 Vero Beach, FL 32960 Phone: 321

-446

- 3998 Email: STG31885@yahoo.com17

17 **Soaring Services, LLC** 1275 US Highway 1 P O Box 321 Suite #2 Vero Beach, FL 32960 Phone: 321

-446

- 3998 Email: STG31885@yahoo.com Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre

-flight pre paration and during flight. Pre

- Fl ight Protocol: Check batteries with voltage meter to insure fully charged and ready for use. Inspect batteries for damage or leakage that may affect proper operation. Inspect propellers for cracks, chips or damage that may cause sudden loss of propul sion or unmanageable/uncontrolled flight. Check all GPS and Telemetry connections prior to flight. Check weather forecasts for wind advisory or other conditions that my impact flight. Consult Sky Vector aeronautical Charts (Skyvector.com) fo r airport vicinity and flight paths of possible air traffic. Contact respective airport to advice of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information. **Inspect flight area for** Vicinity of publi c safety helipads/heliports Vicinity of medical helipads/heliports Vicinity of light poles vicinity or utility wires Vicinity of trees flocks of birds that may cause interference and potential flight impact Vicinity of any elevated obstructions that may pose potential flight hazard Vicinity of roadways with moderate to heavy traffic that can be distracted public Gatherings that may attract viewer’s optional point of control for best visual site of UAS wh ile in flight Emergency landing areas
**Takeoff and landing** Inspect area for best and safest point of takeoff and landing18

18 If in a subdivision or area that is within 150 feet of a residential street, post warning Sign(s)/stand(s) "Attention Aerial Photography In Progress

- Remain Back 150 Feet " **Flight Protocol:** takeof f and land from same location ( have alternate landing areas in case of emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to minimal elevation sufficient to acquire desired results remained prepared for emergency landing at all times pay attention to flight time

– warning meter for low voltage. Set voltage meter alarm for low voltage an d flight timer as a safety alert land UAS and shut down propulsion immediately following landing

– priority of disconnecting batteries **Post flight:** 1. a) Disconnect battery to prevent accidental activation of propulsion system 2. b) Secure UAS in a s afe location c) Remove all warning signs from public access areas Emergency or Suspected Hazard: Immediate land UAS at safest and closet ground location in the event Manned aircraft is heard or seen in vicinity of flight There is a public gathering within established safety boundary wanting to observe flight Pilot is being distracted from focusing on flight and safety Sudden change in weather (wind bursts) Sudden increase in vehicular traffic in vicinity of flight Birds enter into proximity of flight Any sudden unsafe event that can cause collision, distraction or interruption of control Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. Ma intaining a record of safe flight for FAA request and for determining the future UAS ’s safety protocols are imperative.19

19 Date:____________________Location:____________________

________________________ Pre

-flight Inspection: o Yes o No Comment: _________________________________________________ Elements Proximity to airport: _________________ (see attached map pinpointing approximate location of flight) Airport notified: No Yes Date:_______________ Time: ______________ Phone Number: _______________________ Contact Name:___________________________________ Nearest major intersection:

______________________________________________________________ Proximity to medium traffic road:

______________________________________ ___________________ Proximity to heavily traveled roadway road:

_________________________________________________ Proximity to congested population:

________________________________________________________ Approx. Takeoff Time : GMT: We ather Good Fair Poor Comment : Visibility Good Fair Poor Comment : Wi nd Speed ___mph ___Gusts/MPH ___avg/MPH Comment : Approx. Landing Time: GMT: Estimated Elevation Ground level: Safety Concerns: Additional Comments: S ea level:20

20 

### Aircraft Manuals Please see UAS ’s manufacturer's user manuals, maintenance instructions, and illustrated parts catalogs. All of which are available online and can also be provided directly to the FAA upon request from **Soaring Services, LLC** along with any other information required.

1. DJI Phantom 3 (UAS) 2. DJI Phantom X (UAS) 3. DJI Inspire (UAS) 4. Yuneec Typhoon Q500 (UAS)

- Registration pending

**Soaring Services, LLC** will make sure any UAV’s used for our business are registered. In the event that future UAV(s) in addition to the above are purchased for use by the company , the FAA will be notified and the UAV(s) will then be registered.

Thank you for your time and consideration in this matter. For more information or questions please contact:

**Soaring Services, LLC** 1275 US Highway 1 P O Box 321 Suite #2 Vero Beach, FL 32960 *P O boxed used due to privacy protection requirements meet*

Phone: 321

-446

- 3998 Email: STG31885@yahoo.com