October 30, 2015

Docket Management Facility US Department of Transportation 1200 New Jersey Avenue SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

Re: Shane Floyd Films LLC Request for Exemption Request from t he Requirements of Title 14 of the Code of Federal Regulations Section s:

• 14 C.F.R. § Part 21, Subpart H: Airworthiness Certifi cates

,

• 14 C.F.R. §91.203 (a) (1),

• 14 C.F.R. § 45. 23 (b). Marking of the Aircraft,

• 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privi leges and Limitations: Pilot in Command, 14 C.F.R. §91.7(a) : Civil aircraft airworthiness,

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

• 14 C. F.R. § 91.103: Preflight action,

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

• 14 C. F.R. §91.119: Minimum safe altitudes, 14 C. F.R. §91.121 Altimeter Settings, 14 C.F.R. § 91.151(a): Fuel Requiremen ts for Flight in VFR Conditions,

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

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

Shane Floyd Films LLC Shane Floyd

P.O. Box 98563

Lubbock Texas 79499 Phone (806) 544

- 0147

Email: shanetelevision2000@gmail.comTable of Contents

I. The Applicable Legal Standard Under Section 333

II. Airworthiness of the Inspire 1

III. Mandatory Operating Conditions

IV. Training & Operator Requirements

V

. Requested Exemptions and Equivalent Level of Safety

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

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

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

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

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

• 14 C.F.R. § 91.103: Preflight action

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

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

• 14 C.F.R. §91.121 Altimeter Settings

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

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragr aph 16(e)(1) Observer Medical

V I

. Privacy and Public Interest

VII. Summary for Federal Register

VII. Closing

Additional Documentation:

• Flight Planning Document (Appendix A )

• I nspire 1 UAS Operations Manual (Appendix B )

• Inspire 1 UAS Maintenance Man ual ( Appendix C )October 30 , 2015

Docket Management Facility US Department of Transportation 1200 New Jersey Avenue SE West Building Ground Floor Room W12

- 140 Washington, DC 20590 Exemption Request under Section 333

Dear S ir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14 C.F.R. Part 11, Shane Floyd Films LLC (“ Applicant ”) seeks an exemption from Federal Aviation Regulations (“FARs”) to allow commercial operation of it s Unmanned Aircraft System (“UAS” ), the DJI Inspire 1 (“Inspire 1”) equipped to conduct aerial photography and videography for the motion picture and television industry for scripted closed set filming so long as such operations are conducted within and un der the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would support an application for a commercial Certificate of

Authorization to use the above described Inspire 1 to support aerial pho tography and
video graphy for use in the motion picture and television industry for scripted closed set filming.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 30 minutes, this is offers little or no risk to national security.

The name and contact information of the applicant are:

Shane Floyd Films LLC Shane Floyd

P.O. Box 98563
Lubbock Texas 79499 Phone (806) 544

- 0147
Email: shanetelevision2 000@gmail.com

The regulations from which the exemption is requested are listed below:• 14 C.F.R. § Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

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

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

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

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

• 14 C.F.R. § 91.103: Preflight action

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

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

• 14 C.F.R. §91.121 Altimeter Settings

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

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

The Applicable Legal Standard Under Section 333

Shane Floyd Films LLC su b m i t s t h a t g r a nt o f t h i s e x e m p t i on app li ca t i on f o r u se o f t he Inspire 1

i n aerial photography and videography for the motion picture and television industry for scripted closed set filming w i l l ad v ance t he C on g r e s s i onal m and a t e i n S ec t i on 333 o f t h e
R e f o r m A ct t o acce l e r a t e t he i n t r oduc t i on o f UAS s i n t o t he na t i onal a i r space s y s t em ( “ NAS ” ) i f

i t can be acc o m p li shed s a f e l y

. T h i s l aw d i r ec t s t he S ec r e t a r y o f T r a n spo r t a t i on t o con s i der

w he t h e r c e rt a i n UAS s m ay ope r a t e s a f e l y i n t he N A S b e f o r e c o m p l e t i on o f t h e r u l e m a k i n g

r e q u i r ed u n der S e c t i on 332 o f t he R e f o r

m A c t

. I n m a k i ng t h i s d e t e r m i na t i o n , t h e S ec r e t a r y i s

r e q u i r ed t o de t e rm i ne w h i ch t y pes o f UAS s do n o t c r e a t e a ha z a r d t o u s e r s o f t he NA S or t he pub li c or pose a t h r e a t t o na t i onal secu r i t y i n l i g ht o f t he f o ll o wi n g :

• T he UAS’ s s i z e, w e i g h t , speed

, and ope r a t i onal c apab ili t y ;

• O pe r a t i on o f t he UA S i n c l ose p r o x i m i t y t o a i r po r t s and popu l a t ed a r eas;

• O pe r a t i on o f t he UA S w i t h i n v i sual li ne of s i g h t o f t he op e r a t o r

.

R e f o r m A c t § 333 ( a )( 1 )

. I f t he S ec r e t a r y de t e r m i nes t h a t s uch v eh i c l es “m ay ope r a t e s a f e l y i n

t he n a t i onal a i r space s y s t e m , t he S e c r e t a r y sha l l es t ab li sh r e q u i r e m e n t s f or t he s a f e op e r a t i on o f
such a i r c r a f t i n t he na ti onal a i r space s y s t e m

. ” I d. §33 3 ( c)

.

T he Fede r al A v i a t i on A ct e x p r ess l y g r a n t s t he F A A t he a u t h o r i t y t o i ssue e x e m p t i ons. T h i s

s t a t u t o r y a u t ho r i t y , by i t s t e r m s, i nc l udes e x e m p t i n g c i v i l a i r c r a f t

, as t he t e r m i s d e f i ned und e r

§40101 o f t he A c t

, fr o m t he r e q u i r e m ent t h a t a l l c i v i l a i r c r a f t m u s t ha v e a c u rr e n t a i r w o rt h i ness

ce rt i f i c a t e and t h o se r e gu l a t i ons r e q u i r i n g co mm e r c i al p il o t s t o op e r a t e a i r c r a f t i n c o mm e r c i al

se r v i ce:T he A d m i n i s t r a t o r m ay g r ant an e x e m p t i on fr om a r e q u i r e m ent o f a r e g u l a t i on

p r esc r i bed under subse c t i on ( a ) o r ( b) o f t h i s se c t i on or any o f sec t i ons 44702

- 44716

o f t h i s t i t l e i f t he A d m i n i s t r a t o r f i n d s t he e x e m p t i on i s i n t he pub li c i n t e r es t

.

T he g r a n t o f t he r e q ue s t ed e x e m p t i on i s i n t he p u b li c i n t e r est based on t he c l ear d i r e c t i on i n S ec t i on 333 o f t he R e f o r

m A c t ; t he add i t i onal au t ho r i t y i n t he Fede r al A v i a t i on A c t

, a s

a

m ended; t he s tr o n g e q u i v a l ent l evel o f s a f e t y su rr ound i n g t he p r oposed ope r a t i ons; and t he

s i g n i f i ca n t pub li c ben e f i t

, i nc l ud i ng enhanced s a f e t y and c o s t sa v i n g s assoc i a t ed w i t h

t r ans i t i on i ng t o UAS s f or ae r i al s u r v ey pho t o g r aph y

. A cco r d i n g l y , t he a pp li cant r espe c t f u ll y

r e q u es t s t hat t he F A A g r ant t he r e q ue s t ed e x e m p t i on w i t hout de l a y

.

I I

. Airworthiness of the Inspire 1

The UAS includes an Unmanned Aircraft (UA) and ground station

- based equipment and crew:

The Unmanned Aircraft System (UA):

• The Inspire 1 is a lightweight (2935 g gross weight with all on

- board equipment and battery), battery operated 4

- motor rotorcraft in the form of a quadcopter that takes off and lands vertically, m anufactured by DJI, t he Inspire 1 Model T600.

• An on

- board flight computer with GPS navigation and locatio n ability that receives signals for flight controls from a ground

- based transmitter/controller.

• An on

- board camera capable of capturing imagery in the form of full color, high definition still photos and video.

• An on

- board telemetry system that delivers f light data from the on

- board flight computer to the on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site.

• A 600mW, 5.8GHz on

- board radio transmitter that transm its live video from the on

board camera plus all the flight data from the telemetry system described above;

The Ground Station

- Based Part of the System:

• A Pilot in Command (PIC) in operational control of a flight operation from beginning
to end and who co ntrols the UA while in the air.

• A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight.

• A radio receiver receiving live video and flight data from the on

- board camera and computer projects it all together onto a screen for the PIC to view during flight.

• A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while in flight.II. Mandatory Operating Conditions

Grant of the exemption to Shane Floyd Films LLC will be subject t o the following mandatory conditions which are based upon opera ting conditions set forth in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:

• The Inspire 1 will be operated in the field with both a pilot

- in

- command (“PIC”) and a visual observer (“VO”)

• No flight will be made with a UA gross weight exceeding 55 pounds;

• All operations must occur in FAA Class G airspace at no more than 400 ft

. AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC

• All operations must utilize a VO. The VO and PIC must be able to communicate by voice at all times during a flight operation;

• Operations will be restricted to flights over private property with the permission of the

pro perty owner;

• The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type;

• Al l required permits will be obtained from state and local government prior to operation;

• The Inspire 1 will not be operated over densely populated areas;

• The Inspire 1 will not be operated at air shows;

• The Inspire 1 will not be operated over any open

- air a ssembly of people;

• The Inspire 1 will not be operated over heavily trafficked roads;

• The Inspire 1 will not be operated within 5 NM of an airport or heliport;

• The Inspire 1 will not be operated over properties smaller than two acres in size;

• Operations wil l be restricted to day only and weather conditions equivalent to VFR;

• The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location;

• No flight may be made without a Pre

- Flight Inspection by the PIC b efore each operation

III. Training and Operator Requirements

The Inspire 1 will be operated by a contracted pilot with a private pilots certificate . The airspace in which the Inspire 1 will operate will be disclosed to the FAA in advance.

The PIC and VO w ill meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training.

T he combination of the UA's small size, light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (o) listed above, the FAA can have full confidence that theoperation will have an equivalent or greater level of safety than manned aircraft performing the
same mission.

As described more fully below, the requested exemption would authorize commercial operations of aerial surveys usi ng the Inspire 1, which at 6.47 lbs

. , is small in size. The Inspire 1 will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein.

IV. Requested Exemptions and Equivalent Level of Safe ty

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 Fed eral Av iation 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 t o 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 s afe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS 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 noti ce 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 c onducted 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, locatio n 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 that the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less tha n 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "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 entran ce to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS , two

- inch 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 UAS marked on its fuselage as required by §45.29 (f) where the pilot, observ er and others working with the UAS will see the identification of the UAS as “Experimental.” Additionally, we feel that the permanen t placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Statio n" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

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 an d Limitations: Pilot in Command

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because t he 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 UAS 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 a dvance as set forth in the Manual.

The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with t he operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safet y 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 th e aircraft, should thisexemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each fligh t, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

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

Section 91.9 (b) (2) provides that no person may operate an aircraft unless a current, approved
f light manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the UAS , 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 ma intained by keeping the flight manual at the ground control point where the pilot flying the UAS 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, 10 167, 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 f or the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in Sections J and K of the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distance s 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 airc raft has fully functioning dual controls.

UAS 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 communica tions. 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 provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. The regulation stats t hat over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person,vessel, vehicle, or structure. Since the UAS will be operating at a maximum of 400 ft AGL, we cannot comply with this requirement.

The equivalent level o f safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. The UAV will never operate at higher than 400 AGL. The UAS will be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. No flight will be taken without the permission of the property owner or local officials. The property owner or local officials will be briefed on the expected flight path and the associated risks to persons and property on the ground. The UAV will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

Compared to flight operations with aircra ft 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 low

- altitude operations of the UAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regul ation 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.” Since, t he UAS does not hav e a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. The regulation also

r equires that the aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft.

The UA S will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An AGL altimeter measurement above the takeoff point is transmitted via radio from the UAS on

- board computer to the dis play screen held by the PIC providing a constantly updated AGL readout.

An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indi cator before flight.

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) the re 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 UAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited toapproximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location o f its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 1 0673 (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 UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.

Applicant 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 UAS 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 Re gistration

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certifica te be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

At a maximum gross weight of 6.47 pounds, the UA V is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

In order to identify the aircraft, we p ropose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word “EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed placard description below:

EXPERIMENTAL Manufacturer: DJI Innovations, Inc. Model: Inspire 1 Serial Number: W13DCH19040647 If found please contact: (806) 544

- 0147The 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 is primarily responsible for maintaining the aircraft in an airworthy condition including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be “approved for return to service by a person authorized un der 43.7” after maintenance and inspection.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. It is our intention that the PIC preforms maintenance and inspection of the aircraft pursuant to the flight manual and operating handb ook as referenced in the Manual and “be authorized to approve the aircraft for return to service.” Moreover, the PIC 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.

As provided in the Pre

- Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, conduct deta iled inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing propellers, checking electrical connections and updating software and firmware for the on

- board computer. The manufacturer or their designated repair facility shall perform all other maintenance

.

An equivalent level of safety will be achieved because this small UAS is very limited in size and carries a small payload and operate s 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 Appendix A , the operator will ensure that the UAS is in working order prior to initiating flight, perform required mai ntenance, and keep a log of any maintenance performed in accordance with 91.417.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical

This policy provides that both the PIC and VO must have a valid FAA second

- class medical

cert ificate issued under part 67 in order to perform as a pilot or observer.

The UAS maximum gross weight is 6.47 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention.

Therefore, requiring the PIC and VO to meet the same medic al requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid state issued driver's license. The 20/20 v ision requirement will ensure that thePIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

V. Privacy and Public Interest

The public’s best interest is achieved by the safe integration and operation of UAS into the national air space . With the ongoing exemption process, the FAA has to identify those exemption requests with the public’s best interest in mind and select the companies who will be able to achieve this in a safe and responsible manner. The main problems the public has with UAS are the fear of what they will be used for and whether or not they pose a safety hazard when shared with commercial airspace. One of the main concerns the public has with the integration of UAS into nationa l air space is protection of privacy. The media has also placed a negative light on UAS when it comes to privacy sharing only stories of how the military has used this technology for surveillance and how un

- responsible UAV pilots have invaded FAA airspace and threatened the safety of aircraft.

In order to assure the public of Shane Floyd Films LLC’s assurance of 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.

Shane Floyd Films LLC is more than willing to help with public assurance and education and that safe UAV operations starts with c onducting flight operations within strict operating environments to protect the safety and privacy of the public.

The experience we have built from UAS operations, manned flight operations and training and aircraft maintenance; the FAA will provide a gr eat service to the American public by approving

our exemption request herein. Shane Floyd Films LLC will provide any additional information requested and will diligently work with the FAA to make this approval a reality as it is in the best interest and sa fety of the public as directed by Congress.

VI. Summary for Federal Register

Shane Floyd Films LLC hereby submits, pursuant to Part 11 a summary of its exemption application to al l ow commercial operation of the Inspire 1 unmanned aircraft to conduct aeri al photography and videography for the motion picture and television industry for scripted closed set filming . An exemption is requested from the following regulations:

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

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

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

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

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

• 14 C.F.R. § 91.103: Preflight action• 14 C.F.R. §91.109: Flight instruction

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

• 14 C.F.R. §91.121 Altimeter Settings

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

• 14 C.F.R. §91.203 (a) and (b) : Carrying Civil Aircraft Certification and Registration

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

VII. Closing

Shane Floyd Films LLC respectfully submits that because this small, unmanned aerial vehicle will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achie ve at least an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establis h requirements for the safe operation of such aircraft systems in the national airspace system.”

Shane Floyd Films LLC is prepared to modify or amend any part of this request to satisfy the FAA’s need for an equivalent level of safety. Please contact us at any time if you require additional information or clarification. We look forward to working with your office.

Regards,

Shane Floyd, Owner Shane Floyd Films LLCAPPENDIXA

– FLIGHT MANUAL

FLIGHT RESTRICTIONS
(a) No flight will be made with a UA Gross w eight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400'AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; (c) All operations must utilize a visual observer (VO). The VO and PI C must be able to communicate verbally at all times during a flight operation; (d) Operations will be restricted to flights over private property with the permission of the property

owner; (e) The PIC must have accumulated and logged, in a manner consisten t with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; (f) All required permits will be obtained from state and local government prio r to operation; (g) The UAC System will not be operated over densely populated areas; (h) The U AV System will not be operated at air shows; (i) The U AV System will not be operated over any open

- air assembly of people; (j)The U AV System will not be operated over heavily trafficked roads; (k) The U AV System will not be operated within 5 NM of an airport or heliport; (l) The U AV System will not be operated over properties smaller than two acres in size; (m) Operations will be restricted to day only and weather conditions equivalent to VFR; (n) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location; (o) No flight may be made without a successful Pre

- Flight Inspection by the PIC before each operatio n to ascertain that the UA is in a condition safe for flight.

PRE

- FLIGHT CHECKLIST
(1) Use voltmeter to determine that UA battery is fully charged in order to prevent unexpected premature descent; (2) Check all wiring connections are tight; (3) Check all propellers are undamaged and no cracks exist in any structural members of the UA V ; (5) Turn on radio controller, check for adequate voltage, set it to connect to the UA V , move all control switches to forward or down position and throttle control stick fu ll back position; (6) Connect UA main battery, check for radio contact with UA’s radio receiver; (7) At a location different from previous flight, re

- set GPS and compass to current location; (8) Turn on transmitter, gimbal and camera.