Mr. Ryan Salcido

Drone Aviation Rental Training and Service (DARTS)

PO Box 30855

Honolulu, HI 96820

July 27, 2015

U. S. Department of Transportation Docket

Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: FOR A SUMMARY GRANT EXEMPTION SEEKING RELIEF FROM THE

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21,

SUBPART H AND SECTIONS , 45.23(b), 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a),

61.315(a), 91.7(a), 91.9(b)(2), 91.103, 91.119(c), 91.121, 91.203 (a) & (b), 91.151(a)(1),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) AND 91.417(a) & (b) CONCERNING

COMMERCIAL OPERATION OF ALL DJI PHANTOM 2 AND PHANTOM 3 MODELS, DJI

S1000, DJI S900, AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112­95)

1. SUMMARY

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11, Drone Aviation Rental Training and Services an operator of Unmanned

Aircraft Systems (“UASs”) for aerial data collection and flight training, hereby applies for an

exemption from the

Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs.

Drone Aviation Rental Training and Services’ request, as described in greater detail below, the

requested exemption would permit the operation of a sUAS at or below 400 feet AGL, under

controlled conditions in airspace that (1) is limited; (2) is predetermined; (3) is controlled as to
access; and (4) provides safe operations. No operations will be conducted over restricted airspace

or over congested areas. Approval of this exemption would enhance safety, promote industry

growth and fair competition through increased affordability of aerial photography and

videography, and would fulfill the Secretary of Transportation’s responsibilities to establish

requirements for the safe operation of such aircraft systems in the NAS pursuant to Section 333

of FMRA.

2. INTRODUCTION

The name and address of the applicant is:

Drone Aviation Rental Training and Service (DARTS)

Mr. Ryan Salcido

PO Box 30855

Honolulu, HI 96820

salcidojones@gmail.com

808­375­8525 or 808­353­3937

Drone Aviation Rental Training and Services’ (DARTS) objective is to collect aerial data and

flight demonstrations by conducting aerial photography and videography in order to provide high

quality digital imaging and video content to its clients, and to promote the safe use of sUAS’s by

being an educator on the subject. More specifically, the purpose of this exemption would be to

allow DARTS to provide commercial aerial video and photography operations in the following

areas: Aerial photography and videography for the advertising industry, Aerial photography and

videography of residential/commercial buildings for the real estate industry, Aerial photography

and videography for industrial/construction sites, Aerial photography and videography for the

agricultural and farming industry, and flight demonstrations to new users. Increase public

knowledge of sUAS and promote safe sUAS operations

This exemption application is expressly submitted to fulfill Congress’ goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the national airspace

system (NAS) before completion of the rulemaking required under Section 332 of the Reform

Act. In making this determination, the Secretary is required to determine which types of UASs

do not create a hazard to users of the NAS or the public or pose a threat to national security in

light of the following:

The UAS’s size, weight, speed, and operational capability;

Operation of the UAS in close proximity to airports and populated areas; and
Operation of the UAS within visual line of sight of the operator.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority by its terms includes exempting civil aircraft, as the term is defined

under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must

have a current airworthiness certificate.

UASs operated by Drone Aviation Rental Training and Services weigh less than 55

pounds, including the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more

than 50 knots, can hover, and can simultaneously move vertically and horizontally. Drone

Aviation Rental Training and Services will only operate its UASs in line of sight and will operate

only within the sterile area. Such operations will insure that the UAS will “not create a hazard to

users of the national airspace system or the public.”

Drone Aviation Rental Training and Services seeks an exemption to operate the DJI

Phantom 2, DJI Phantom 2 Vision+, and all Phantom 3 models, The DJI S1000, S900 and DJI

Inspire 1 model UAS for compensation or hire within the NAS.

Each UAS operated by Drone Aviation Rental Training and Services will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Marking.

3. BASIS FOR PETITION

Given the small size of Drone Aviation Rental Training and Services ’UASs and the

restricted sterile environment within which they will operate, Drone Aviation Rental Training

and Services’ UAS operations adhere to the Reform Act’s safety requirements. Additionally, due

to the size of the UASs and the limited areas in which they will operate, approval of this

application presents no national security issues. Each of Drone Aviation Rental Training and

Services sUASs, including payload, is far below the 55 pound sUAS classification requirement,

and one is also below the 4.4 pound requirement developed by the proposed 14 C.F.R. Part 107

that creates the “microUAS” subclass of sUAS. Based on the substantial level of safety

surrounding the proposed operations, and the significant public benefit (enhanced safety),

reduction in environmental impacts (reduced emissions and noise), the grant of the requested

exemption is in the public interest. Accordingly, Drone Aviation Rental Training and Services

respectfully requests that the FAA grant the requested exemption without delay.

Aircraft and equivalent level of safety
The applicant proposes that the exemption requested apply to civil aircraft that have the

characteristics and that operate with the limitations listed. These limitations provide for at least

an equivalent or even higher level of safety to operations under the current regulatory structure

because the proposed operations represent a safety enhancement to the already safe aerial

photography and aerial filming for movie and television filming operations conducted with

conventional aircraft.

These limitations and conditions to which Drone Aviation Rental Training and Services

agrees to be bound when conducting commercial operations under an FAA issued exemption

include:

The sUAS will weigh less than 55 lbs.

Flights will be operated within line of sight of a pilot and/or observer.

Maximum total flight time for each operational flight will be 30 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

Flights will be operated at an altitude of no more than 400 feet AGL

Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer.

sUAS pilot will be an FAA licensed airman with at least a private pilot’s certificate and

third class medical. The observer will hold at least a third class medical.

sUAS Pilot assume all duties and responsibilities as Pilot in Command (PIC).

The UAS will only operate within a confined “Sterile Area”. Security will be performed

by the operator and designated security personnel.

A briefing will be conducted in regard to the planned sUAS operations prior to each

day’s production activities. It will be mandatory that all personnel who will be

performing duties within the boundaries of the safety perimeter be present for this

briefing.

The operator will obtain the consent of all persons involved in the mission and ensure

that only consenting persons will be allowed within 100 feet of the flight operation, and

this radius may be reduced to 30 feet based upon an equivalent level of safety

determination. With the advanced permission of the relevant FSDO, operations at closer

range can be approved.
The operator will submit a written Plan of Activities to the FSDO three days before the

proposed shoot.

Pilot and observer will have been trained in operation of UAS generally and received

up­to­date information on the particular UAS to be operated.

ALL crew members will at all times be able to communicate by ONLY voice

communications as to ensure all crew members maintain a visual contact with the UAS at

ALL TIME.

Written and/or oral permission from the relevant property holders will be obtained.

All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

If the sUAS loses communications or loses its GPS signal, the UAS will have capability

to return to a pre­determined location within the Security Perimeter and land.

The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

The Plan of Activities

The Plan of Activities must include the following:

Dates and times for all flights;

Name and phone number of the person responsible for the photography / filming

event;

Name and phone number of the person responsible for the aircraft;

Make, model and serial number and/or registration number of all UAS t to be

used;

Name and certificate number, if applicable, of all crewmembers to be utilized in the

event including copies of FAA Medical Certificates and endorsements;
A statement that the Waiver Holder has obtained permission from property

owners and/or local governmental officials to conduct the event;

Signature of Waiver Holder or representative;

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

minimum altitudes essential to accomplish the operation.

Briefing

Drone Aviation Rental Training and Services and the event representative will conduct a

verbal and written briefing for the members involved, including emergency, if applicable, and

security personnel. This briefing will be conducted prior to each day’s UAS activities and

will include the following items.

Authorization UAS flight operations, Plan of Activities, special provisions and any

additional provisions issued by the Flight Standards District Office having jurisdiction

over the photo / filming area.

Radio communications.

Takeoff procedures.

Aviation activities to be conducted during the event.

Approach and landing procedures.

Alternate landing zone in the event of emergency or security breach

Recall procedures.

Emergency procedures.

Possible risk to personnel that are involved.

Control of non­participating persons.

Location of boundaries or deadlines, man­made or natural, readily visible to the

participants.

Local governmental limitations, restrictions, or any special circumstances, such as noise

sensitive areas, time of day restrictions or changes in operating procedures.

Security
The exclusion from the flight operations area of unauthorized persons, vehicles or aircraft

will be enforced by designated event personnel, private security officers or sworn law

enforcement officers at the direction of Drone Aviation Rental Training and Services.

Drone Aviation Rental Training and Services or his designated representative will halt

flight operations in the event unauthorized persons, vehicles or aircraft enter the flight

operations area.

A predetermined abort signal will be used to halt flight operations should a breach of

perimeter security occur, or for any other reason in the interest of safety.

Alternate UAS landing sites will be made available prior to the start of the event.

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

3. EXTENT OF RELIEF AND REASONS (DARTS) SEEKS RELIEF

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size

and limited operating area associated with the aircraft to be utilized by the Applicant, an
exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement

for an airworthiness certificate, upon consideration of the size, weight, speed, operational

capability, and proximity to airports and populated areas of the particular UAS. In all cases, an

analysis of these 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, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this

exemption will be tightly controlled and monitored by both the operator, pursuant to the

Manual’s requirements, and under the requirements and in compliance with local public safety

requirements, to provide security for the area of operation as is now done with conventional

filming. The FAA will have advance notice of all operations. These safety enhancements, which

already apply to civil aircraft operated in connection with motion picture and television

production, provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible

threat to national security posed by the UAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a

substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light­sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light­sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word
Experimental” can be placed. Given the size of the sUAS, two­inch lettering will be impossible.

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on its

fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS

will see the identification of the UAS as “Experimental.” The FAA has issued the following

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non­commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent

level of safety of current operations by requiring the PIC operating the aircraft to have a private

pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with

no living thing on board. The area of operation is controlled and restricted, and all flights are

planned and coordinated in advance as set forth in the Manual. The level of safety provided

exceeds that provided by a single individual holding a commercial pilot’s certificate operating a

conventional aircraft. The risks associated with the operation of the sUAS are so diminished

from the level of risk associated with commercial operations contemplated by Part 61 when

drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds

the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the Manufacturer's Operating

Manual for maintenance and use of safety check lists prior to each flight, an equivalent level of

safety and operating criteria can be found at the following links:

Requested exemption Aircraft Operating User’s Manuals

http://www.dji.com/product/phantom­3/download,

http://www.dji.com/product/phantom­2/download

http://www.dji.com/product/inspire­1/download

http://www.dji.com/product/spreading­wings­s900/download
http://www.dji.com/product/spreading­wings­s1000­plus/download

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.­registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of

this chapter, unless there is available in the aircraft a current approved airplane or

Rotorcraft Flight Manual, approved manual material, markings, and placards, or

any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no room

or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the

ground control point where the pilot flying the sUAS will have immediate access to it. The FAA

has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299,

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for

the aircraft an exemption will be needed. The PIC will take all actions including reviewing

weather, flight battery requirements, landing and takeoff distances and aircraft performance data

before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.
sUASs and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates with

the aircraft via radio communications. The FAA has approved exemptions for flight training

without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety can be

achieved as neither a pilot nor passengers will be carried in the aircraft in addition to the small

size and low speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the person

operating the helicopter complies with any route or altitudes prescribed for helicopters by the

FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority

to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from

which filming is planned, an exemption may be needed to allow such operations. As set forth

herein, except for the limited conditions stated in the Manual, the UAS will never operate at

higher than 400 AGL. It will however be operated in a restricted area with security perimeter,

where buildings and people will not be exposed to operations without their pre­obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS

as well as the location where it is operated. No flight will be taken without the permission of the

property owner or local officials. Because of the advance notice to the property owner and

participants in the filming activity, all affected individuals will be aware of the planned flight

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these

operations is far less than those presently presented with conventional aircraft operating at or

below 500 AGL in the movie industry. In addition, the low­altitude operations of the sUAS will

ensure separation between these small­UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate

altimeter setting available before departure.” As the sUAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety
will be achieved by the operator, pursuant to the Manual and Safety Check list, by receiving

altitude information via a digitally encoded telemetric data feed, which downlinks from the

aircraft to a ground­based on­screen display. This altitude information will be generated by

equipment installed on board the aircraft, using GPS triangulation, or digitally encoded

barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero

altitude initiation point will be established and confirmed for accuracy by the pilot.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel

to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45

minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and

the location of its proposed operations within a predetermined area, a longer time frame for flight

in daylight or night VFR conditions is reasonable.

Drone Aviation Rental Training and Services believes that an exemption from 14 CFR

§91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed

Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small

UAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given

the size and speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would

greatly reduce the utility for which the exemption will be granted.

Drone Aviation Rental Training and Services believes that an equivalent level of safety

can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens

first. This restriction would be more than adequate to return the sUAS to its planned landing

zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F,

5745, 10673, and 10808.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless

it has within it the following:

An appropriate and current airworthiness certificate. . . .

No person may operate a civil aircraft unless the airworthiness certificate required

by paragraph (a) of this section or a special flight authorization issued under

§91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard

pilot. As such, there is no ability or place to carry certification and registration documents or to

display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the sUAS will have immediate access to them; to the extent

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A,

9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the applicant. Maintenance will be accomplished by

the operator pursuant to the flight manual and operating handbook. As the manufacturer does not

provide specific maintenance instructions, maintenance will be “on condition” for all aircraft and

each aircraft will have a maintenance log.
An equivalent level of safety will be achieved because these small UASs 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. As provided in the Manual, the operator will ensure that the UAS is in

working order prior to initiating 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. If the operator encounters a maintenance issue which cannot be addressed, the UAS will

be returned to the manufacturer or a qualified repair facility where such repairs or maintenance

can be performed.

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

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b)

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1);

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned

vehicle (55lbs or less) in aerial photography and aerial filming operations and flight

demonstrations for training purposes..

Approval of exemptions allowing commercial operations of sUASs in the aerial photo

and film industry will enhance safety by reducing risk. Conventional film operations, using jet or

piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed

and in extreme proximity to people and structures; and present the risks associated with vehicles

that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel. Such

aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs.

and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of

combustible fuel carried on board. The sUAS is carried to the film set and not flown. The sUAS

will carry no passengers or crew and, therefore, will not expose them to the risks associated with

manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict

conditions outlined above, will provide an equivalent level of safety supporting the grant of the

exemptions requested herein, including exempting the applicant from the requirements of Part 21
and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to

the ground, and in a sterile environment and, as a result, are far safer than conventional

operations conducted with turbine helicopters operating in close proximity to the ground and

people.

Privacy

All flights will occur over private or controlled access property with the property owner’s

prior consent and knowledge. Filming will be of people who have also consented to being filmed

or otherwise have agreed to be in the area where filming will take place.

4. SUMMARY

Drone Aviation Rental Training and Services exemption request should be granted due to the

fact that the business will increase competition in the marketplace, serve to benefit the public

good in a safe and not interfere with other safe and effective operations in the National Airspace.

Similar exemptions have been granted and have been given previously to other operators who are

operating the same sUASs, e.g. Exemptions Nos. 11062, 11109, 11112, 11213, 11641, 11639,

11240, 11654,11656, 11658, 11659, 11660, 11663, 11664, 11655, 11669, 11670, 11672, 11639,

11641, 11642, 11644, 11626.

If you have any questions or need any additional information, please contact

the undersigned at

Dated: 12­JULY 2015

Sincerely yours,

/s/ Ryan Salcido

Ryan Salcido

Owner, Drone Aviation Rental Training and Service (DARTS)