January 19, 2016

U

. S. Department of Transportation Docket Managem ent System 1200 New

Jersey Ave., SE Wa shington DC 20590

Re: Exem ption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 45

. 23 (b); 14 CFR 21 ; 14 CFR 61.113(a) and (b); 14 CFR 61

. 113 (a) 

### & (b); 91

. 7 (a); 91.9 (b) (2); 91

. 1 03; 91

. 109; 91.119(c); 91

. 121 ; 91

. 151(a) ; 91.203 (a) & (b ); 91.405(a) ; 91.407(a)(1) ; 91.409 (a)(1) and (2); 91.417(a) and (b)

. 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 , Meldahl an operator of Unm anned Aircraft Systems ("UASs " ) for aerial photography, film , survey , and search and rescue, hereby applies for an exem ption from the Federal Aviation Regulations ("FARs " ) to allow commercial operation of its UASs. To date , the FAA granted num erous exem ptions to UAS operators , including Astraeus Aerial , Team 5 LLC , Alan Purwin, and Helinet Aviation Services. Meldahl’s requested exem ption would perm it the operation of small , unm anned UAS under controlled and sterile airspace that i s : (i ) lim ited , (ii) predete rmi ned , ( iii) subject to controlled access , and (iv) provide greater safety in connection with aircraft operations

. As established by the exem pt i ons already granted by the FAA , approval of Meldahl’s exem ption would enhance safety and fulfill the Secretary of Transportation ' s (the FAA Administrator's) responsibilities to " . .. establish requirem ents for the safe operation of such aircraft systems in the national airspace system ." Section 333(c ) of the Reform Act. The nam e and address of the applicant is : Bryan Meldahl Ph: 425.772. 3885 Em ail: pcab2004@gm ail.com 12303 Harbour Pointe BLVD O201 Mukilteo, W a 98275

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 2 This exem ption app l ication is expressly submitted to fulfill Congress ' goal in passing Section 333(a) throug h ( c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems m ay operate safely in the national a irspace system (NAS) before completion of the rulem ak i ng required under Section 332 of the Reform Act. In m aking this determ ination , the Secretary is required to de term ine w hich 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 , weigh t, s p eed , and operational capability ; • Operation of the UAS in close proxim ity to airports and populated areas ; and • Operation of the UAS within visual line of s i ght of the operator

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

. This statutory authority by its terms includes exem pting civil aircraft , as the term is defined under §401 01 of the Act , that includes UASs , fro m the requirem ent that all civil aircraft m ust have a current airworthiness certificate

. UASs operated by Meldahl weigh less than 5 5 pounds , including the payload (i.e

. cam era, lens, and gim bal). They operate at speeds of no m ore than 40 knots , can hover, and can sim ultaneously m ove vertically and ho r izontally. Meldahl will only operate its UASs in line of sight and will operate only w i thin 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. " Meldahl seeks an exem ption to operate the 3DR Iris, DJ1 Spreadwings S1000, DJI Phantom 2 and DJI Inspire 1 mo del UAS for compensation or hire within the NAS. Such activ i ties include, but are not lim ited to, aerial survey , aerial photography and film , and assist search a nd rescue operations in rem ote areas. Each UAS has a maxim um g ross weight under 10 pounds , maxim um speed of 49 mph (approxim ately 42 knots) , and a run tim e of approxim ately 30 mi nutes. A copy of the operating handbook for each aircraft will be subm itted wi th this exemption request. Each UAS operated by Meldahl 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

. Given the sm all size of Meldahl’s UASs and the res t ricted sterile environm ent within which they will operate , Meldahl’s UAS operations adhere to the Reform Act ' s safety requirem ents. Additionally, due to the size of the UASs and the limited areas in which they will operate , approval of th i s application presents no national security issues. Based on the substantial level of safety surrounding the proposed operations , and the significant public benefit (enhanced safety) , reduction i n environm ental im pacts (reduced em issions and noise), the grant of the requested exem ption is in the public interest. Accordingly , Meldahl respectfully requests that the FAA grant the requested exem ption without delay

.

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 3 Aircraft and equivalent level of safety The applicant proposes that the exem ption requested apply to civil aircraft that have the characteristics and that operate with the lim itations listed. These lim itations provide for at least an equivalent or even higher level of safety to operat i ons under the current regulatory structure because the proposed operations represent a safety enhancem ent to the already safe aerial photography and aerial film ing for m ovie and television film ing operations conducted with conventional aircraft

. These lim itations and conditions to which Meldahl agrees to be bound when conducting commercial operations under an FAA issued exem ption include : 1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line of s i ght of a pilot and/or observer

. 3. Maxim um total flight tim e for each ope rational flight w ill be 30 m inutes

. Flights will be term inated at 25% battery power reserve should that occur prior to the 30 minute lim it. 4. Flights will be operated at an altitude of no more than 400 feet AGL 5

. Minim um crew

for each operation will consist of the UAS Pilot , the Visual Observer, and the Camera Operator. 6. UAS pilot w ill be an FAA licensed airm an with at least a private pilot ' s certificate and third class m edical. The observer w ill hold at least a third class medical. 7. UAS Pilot assum es all duties and responsibilities as Pilot in Command (PIC)

. 8

. The UAS will only operate within a confined " Sterile Area ". Security will be perform ed by the operator and designated security personnel. 9. A briefing will be conducted in regard to the planned UAS operations prior to each day's production activities. It will be m andatory that all personnel who will be perform ing duties within the boundaries of the safety perim eter be present for this briefing

. 10. For photo and film missions, 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 m ay be reduced to 30 feet based upon an equivalent leve l of safety determ inat ion. W ith the advanced perm ission of the relevant FSDO , operations at closer range can be approved

. 11

. For photography and photo m issions , the operator will subm it a written Plan of Activities to the FSDO three days before the proposed m ission. 12. Pilot and observer will have been trained in operation of UAS generally and received up

-to

- date inform ation on the particular UAS to be operated

. 13. ALL crew

me mbers will at all tim es be able to communicate by ONLY voice communications as to ensure all crew m e mbers m aintain a visual contact with the UAS at ALL TIMES

.

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 4 14. W ritten and/or oral perm ission from the relevant property holders will be obtained. 15. All required perm issions and perm its will be obtained from territorial , state, county or city jurisdictions, including local law enforcem ent, fire, or other appropr iate governm ental agencies. 16. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determ ined location w ithin the Security Perimeter and land. 17

. The UAS w ill have the capability to abort a flight in case of unpredicted obstacles or em ergencies. *For em ergency assistance with State and Governm ent Agencies, such as assisting in search efforts, we ask that we be exem pt from the 72 hour plan of activities notice

. UAS Crew

Requirem ents: UAS Pilot in Comm and m ust: 1. Hold at least a FAA Private Pilot with current 2nd class m edical 2. Have logged a minim um of 100 takeoff and landing cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours l ogged as a UAS pilot with a sim ilar UAS type (single blade or multirotor); a minimum of 5 hours as UAS pilot with the m ake and model of UAS to be utilized for operations under the exem ption and 3 take offs and landings in the preceding 90 days; (training and currency docum entation will be submitted w ith plan of activities) 3. Received training in the safe operation of the UAS to be operated. Training will include: a. Norm al and emergency m odes of operation b. Familiarization with the operation m anual published by the UAS manufacturer

. c. Types of maneuvers to be performed during operations including safe operation in relation to persons, property and applicable airspace using the actual UAS or m anufacturers sim ulation software Cam era Operator must: 1

. Be familiar with the operation m anual published by the UAS manufacturer. 2. Receive training in the safe operation of the cam era I gyro systems operated onboard the UAS. Training will include:

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 5 a. Proper m ethod of loading, rigging, or attaching the cam era mount, lighting, and any external equipm ent b

. Types of ma neuvers to be performed during operations c. Safe operation in relation to persons, property and applicable airspace

. d. Receive training on basic VFR weather minim um s outlined in 14 CFR 91

. 155 In a dual control configuration , the Cam era Operator w ill not operate the m aster controller. Observers m ust: 1. Hold at least a third class m edical 2

. Be fam iliar with the use of VHF I FM radio communication. 3. Have received training on the National Airspace System 14 CFR 71 and the basic VFR weather mi nim um s outlined in 14 C.F.R. 91.155. Th e Plan of Activities The Plan of Activities must include the following : 1. Dates and times for all flights; 2. Name and phone num ber of the person responsible for the photography I filming event; 3. Name and phone num ber of the person responsible for the aircraft ; 4. Make, model and serial num ber and/or registration num ber of all UAS t to be used; 5. Name and certificate num ber, if applicable , of

all crewme mbers to be utilized in the event includin g copies of FAA Medical Certificates, endorsem ents , and flight logs to indicate currency; 6. A statement that the W aiver Holder has obtained perm ission from property owners and/or local governm ental officials to conduct the event; 7. Signature of W aiver Holder or representative; 8. A description of the flight activity including m aps or diagram s of any area, city, town, county, and/or State over which film ing will be conducted and the minim um altitudes essen tial to accomplish the operation

. Bri efing for Photography and Film Missions Meldahl and the event representative will conduct a verbal and wr itten briefing for the m em bers involved , including em ergency, if applicable, and security personnel. This briefing w ill be conducted prior to each day' s UAS activities and will include the follow ing item s.

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 6 1. 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 I film ing area. 2. Radio communications. 3. Takeoff procedures. 4. Aviation activities to be conducted during the event. 5. Approach and landing procedures. 6. Alternate landing zone in the event of emergency or security breach 7. Recall procedures

. 8

. Em ergency procedures. 9. Possible risk to personnel that are involved. 10. Control of non

- participating persons. 11

. Location of boundaries or deadlines, m an - ma de or natural , readily visible to the participants

. 12. Local governm ental lim itations, restrictions , or an y special circumstances , such as noise sensitive areas , tim e of day restrictions or changes in operating procedures. Security The exclusion fro m the flight operations area of unauthorized persons , vehicles or aircraft w ill be enforced by designated event personnel , private security officers or sworn law enforcem ent officers at the direction of Meldahl

. Meldahl or a designated representative will halt flight operations in the event unauthorized persons , vehicles or aircraft enter the flight operations area. A predeterm ined abort signal will be used to halt flight operations should a breach of perim eter security occur, or for any other reason in the interest of safety. Alternate UAS landing sites will be m ade available prior to the start of the event. Regulations from which the exem ption 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)

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 7 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) ( 2) 14 CFR 417 (a) & (b) 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 requirem ents for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1 ). Given the size and lim i ted operating area associated with the aircraft to be utilized by the Applicant , an exem ption from Part 21 Subpart H m eets the requirem ents 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 exem pt aircraft from the requirem ent for an airworthiness certificate, upon consideration of the size , we ight, speed , operational capabili ty , and proxim ity to airports and populated areas of the particular UAS. In all cases , an analysis of these criteria dem onstrates that the UAS operated without an airworthiness certificate, in the restricted environm ent 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 UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger , carries no explosive ma terials or flammable liquid fuels, and operates exclusively within a secured area

. Unlike other civil aircraft , operations under this exem ption will be tightly controlled and m onitored b y both the operator and under the requirem ents and in com pliance with local public safety requirem ents, to provide security for the area of operation as is now done with conventional film ing

. The FAA will have advance notice of all operations. These safety enhancements, w hich already apply to civil aircraft operated in connection with m otion picture and television production , provide a greate r 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 sam e 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 expl os ive ma terials 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: Wh en marks include only the Rom an capital letter "N" and the registration num ber is displayed on lim ited , restricted or light

- sport category aircraft or experim ental or provisionally certificated aircraft , the operator m ust also display on that aircraft near each entrance to the cabin, cockpit, or pilot station , in letters not le ss than 2 inches nor more than 6 inches high , the

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 8 words "lim ited," "restricted," "light

- sport," "experim ental," 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 sta tion on which the word Experim ental" can be placed. Given the size of the UAV , two - inch lettering will be im possible. The word "Experim ental" w ill be placed on the fuselage in com pliance with §45.29 (f). The equivalent level of safety w ill be provided by having the UAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAV will see the identification of the UAS as "Experim ental." The FAA has issued the follow ing exem ptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 

### A.

14 C.F .R. § 61.113 (a) & (b): Private Pilot Privileges and Lim itations: Pilot in Comm and

. Sections 61.113 (a) 

### & (b) lim it private pilots to non - comm ercial 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 commercia l pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is rem otely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. 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 UAS are so dim inished 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 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 m ay operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft , should this exem ption be granted , no FAA regulatory standard will exist for determ ining airworthiness. Given the size of the aircraft and the requirem ents contained in the Manufacturers Operating Manual for m aintenance and use of safety check lists prior to each flight, an equivalent level of safety will be provided

. 14 C.F

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

. Section 91.9 (b) (2) provides:

12303 Harbour Pointe BLVD O201, Mukilteo W a 98275 T : 425.772. 3885 E : pcab2004@gmail.comDOT

January 19, 2016 Page 9 No person m ay operate a U

. S

. - registered civil aircraft ... (2) For w hich 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 m anual material , markings, and placards, or any com bination thereof. 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 w ill be m aintained by keeping the flight manual at the ground control point where the pi l ot flying the UAS w ill have immediate access to it. The FAA has issued the following exem ptions to this regulation: Exem ption Nos. 8607 , 8737,8738,9299, 9299A, 9565,95658 , 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 m anuals will not be provided for the aircraft an exem ption will be needed. The PIC will take all actions including reviewing weather, flight battery requirem ents , landing and takeoff distances and aircraft perform ance data before initiation of flight. 14 C.F.R. §91.1 09: Flight instruction: Section 91.103 provides that no person m ay operate a civil aircraft (except a m anned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UASs and rem otely piloted aircraft , by their design do not have fully functional dual controls. Flight control is accom plished through the use of a control box that communicates w ith the aircraft via radio comm unications. The FAA has approved exem ptions for flight training without fully functional du al controls for a num ber of aircraft and for flight instruction in experim ental aircraft

. See Exem ption Nos

. 5778K & 9862A. The equivalent level of safety can be achieved as neither a p i lot nor passengers will be carried in the aircraft in addition to the sm all 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 m inim um s prescribed, provided the person operating the helicopter complies w ith any route or altitudes prescribed for helicopters by the FAA. As this exem ption is for a UAS that is a helicopter and the exem ption requests authority to operate at altitudes up to 400 AGL. As set forth

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January 19, 2016 Page 10
herein , except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It will ho wever be operated in a restricted area with security perim eter, where buildings and people will not be exposed to operations without their pre - obtained consent. The equivalent level of safety w ill 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 perm ission of the property owner or local officials. Because of the advance notice to the property owner and participants in the film ing activity, all affected indivi duals will be aware of the planned flight operations. Com pared to flight operations with aircraft or rotorcraft weighting far more than the maxim um 551bs. 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 sm aii

- UAS operations and the ope rations of conventi onal aircraft that must com ply with Section 91.119. 14 C

. F. R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to m aintain cruising altitude by reference to an altim eter that is set " ..

. to the elevation of the departure airport or an appropriate altim eter setting available before departure." As the UAS may not have a barom etric altim eter, but instead a GPS altitude read out, an exem ption ma y be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, by receiving altitude inform ation via a digitally encoded telem etric data fe ed , which downlinks from the aircraft to a ground

- based on screen display. This altitude inform ation will be generated by equipment installed on board the aircraft , using GPS triangulation, or digitally encoded barom etric altim eter, or radio altim eter , or any com bination thereof. Prior to each flight, a zero altitude initiation point will be established a nd confirm ed for accuracy by the pilot. 14 C

. F.R. § 91.151(a): Fuel Requirem ents 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 , assum ing norm al cruising speed

- (1) During the day, to fly after that for at least 30 m inutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the UAS provides approxim ately 40 m inutes of powered flight. To meet the 30 minute reserve requirem ent in 14 CFR §91.151, UAS flights would be lim ited to approxim ately 10 m inutes in length. Given the lim itations on t he UAS's proposed flight area and the location of its proposed operations within a predeterm ined area , a longer tim e frame for flight in daylight or night VFR conditions is reasonable. Meldahl believes that an exem ption fro m 14 CFR §91.151 (a) falls within the scope of prior exem ptions. See Exem ption 10673 (allowing Lockheed Martin

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February 13 , 2015 Page 11 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.

Meldahl 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 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: (1) An appropriate and current airworthine ss certificate .... (b) 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 UAS. 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

. 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

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January 19, 2016 Page 12 repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or m aintain the aircraft in com pliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate , these sect ion s wi ll not apply to the applicant. Maintenance will be accom plished by the operator pursuant to the flight ma nual 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 m aintenance log. An equivalent level of safety will be achieved because these sm all UASs are very lim ited in size and will carry a sm all payload and operate only in restricted areas for lim ited periods of time. If mechanical issues arise the UAS can land immediately and wi ll be operating fro m n o 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 ma intenance , and keep a log of any maintenance perform ed. Moreover, the operator is the person most familiar w ith the aircraft and best suited to m aintain the aircraft in an airworthy condition to provide the equiva lent leve l of safety. If the operator encounters a m aintenance i ssue which cannot be addressed, the UAS will be returned to the m anufacturer or a qualified repair facility where such repairs or maintenance can be perform ed

. Pursuant to 14 C.F.R. Part 11, the following summary is provided fo r publication in the Federal Register, should it be determ ined that pu blication is needed: Applicant seeks an exemption fro m 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 sm all unmanned vehicle (551bs or less) in aerial photography and aerial filming operations. Approval of exem pt i ons allowing commercial operations of UASs in the aerial photo and film industry will enhance safety by reducing risk. Conventional film operations , using jet or piston power aircraft, operate at extrem ely low altitudes just feet fro m the subject being film ed and in extrem e proxim ity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,0001bs., carrying large am ounts of jet A or other fuel. Such aircraft m ust fly to and from the film location. In contrast, a UAS wei ghing fewer than 55 lbs. and powered by batteries elim inates virtually all of that risk given the reduced m ass and lack of com bustible fuel carried on board. The UAS is carried to the film set and not flown

. The UAS will carry no passengers or crew

and, therefore, will not expose the m to the ri sks associated with manned aircraft flights. The operation of small UASs, weighting less than 55 lbs. , conducted in the strict conditions outlined above , will provide an equivalent level of safety supporting the grant of the exem ptions requested herein , including exem pting the applicant from the

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February 13 , 2015 Page 13 requirem ents of

Part 21 and allowing commercial operations

. These lightweight aircraft operate at slow speeds , close to the ground , and in a steri l e environment and , as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximi ty 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. Film ing will be of people who have also consented to being filmed or otherwise have agreed to be in the area where film ing will take place. If you have any questions or need any additional inform ation, please contact the undersigned at 425.772.3885 or pcab2004@gmail.com Sincerely yours,

Bryan Trevor Meldahl

12303 Harbour Pointe Blvd O201, Mukilteo W a 98275 T: 425.772.3885 E:pcab2004@gmail.com