September 10, 2015

Exemption No. 12812 Regulatory Docket No. FAA

− 20 15

− 2602

Mr. Jonathan Martin

582 Coatesville Road West Grove, PA 19390

Dear Mr. Martin :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 3, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption

. You requested to operate an unmanned ai rcraft system (UAS) to conduc t aerial photograph and videography, including film sets

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

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

.

Airworthiness Certification

The UAS proposed by the petitioner is a Tarot 65 0 Sport

.

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

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relief from 14 CFR part 21

, C ertification procedures for products and parts,2

Subpart H

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

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

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

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

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitio ner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public inte rest.

Having reviewed your reasons for requesting an exemption, I find that

—

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

• The reasons stated by the FAA for granting Ex emption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Jonathan Martin is granted an ex emption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitione r to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Jonathan Martin is hereafter referred to as the operator.

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

instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Tarot 650 when weighing less than 55 po unds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

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

aircraft manufacturer.

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

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

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and

limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The4

operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

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

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

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

- flight inspection must account for all potential discrepancies, e.g.

, inoperable com ponents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

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

aircraft components.

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

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certif icate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and

maintainin g appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs5

(traini ng, proficiency, and experience

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

traini ng, proficiency, and experience

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

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

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

FAA

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

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

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

pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibited fro m beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the man ufacturer if greater.

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

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

.

22. All aircraft operated in accordance with this exemption must be identified by serial

num ber, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

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

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

activities at all times.

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

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

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure

tha t nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipa ting persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

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

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

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

28. Any incident, accident, or flight operation that transgresses the lateral or vert ical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

containe d on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

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

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

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

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

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

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

- scene operation of the UAS;

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

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permissio n must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.

This exemption terminates on September 30

, 2017

, unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresIN THE MATTER OF THE P ETITION FOR EXEMPTION OF: Jonathan Martin

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b ) CONCERNING COMMERCIAL OPERATION OF TAROT 650 SPORT UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on JUNE 3, 2015

Jonathan Martin 582 Coatesville RD West Grove, PA 19390 (610)476-1702 FutureAviatorsUSA@gmail.com UN ITE D S T A TE S OF AM E RICA
D E PA RT M E N T OF T RANSPO RT A T ION
F E D E RA L AVIA T ION ADMINIS T RA T ION
W ASHING T ON, D CTABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 5

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JONATHAN MARTIN SEEKS EXEMPTION 8

THE EXTENT OF RELIEF JONATHAN MARTIN SEEKS AND THE REASON JONATHAN MARTIN SEEKS THE RELIEF 11

THE REASONS WHY GRANTING JONATHAN MARTIN REQUEST WOULD BE IN THE PU BLIC INTEREST 13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 15

CONCLUSION 26GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingSUMMARY

Jonathan Martin seeks exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a )(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Un manned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Jonathan Martin to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial vi deo and photography fo r videography, real estate photography, special events, film sets , and landscape over certain areas of the

United States. Jonathan Martin will in crease public awareness and knowledge of UAS and promote safe operations.

INTRODUCTION AND INTERESTS OF THE PETITIONER
Jonathan Martin provides its clients w ith expertise and knowledge in advanced technologies and solutions to increase effi ciency, productivity and effectiveness. Jonathan Martin also provides its clients with the highest quality di gital content for use in their commercial, personal, and non-prof it multimedia projects. Jonathan Martin has over 10 years of professional experience in aviation, photography and graphic design and work with remotely piloted aircraft. Jonathan Martin has his Commercial Pilot’s license (2784208) and his Certified In structor Rating (2784208CFI). The objective of Jonathan Martin’s operation is to provide high quality imaging for a variety of commercial, public, and residential uses, a nd promoting safe operations and airspace awareness while piloting UAS’s specifically targeting:

Aerial imaging for advertis ing and marketing brochures Real Estate Photography Land survey & appraisals Equipment Inspections Increase public knowledge of UAS a nd promote safe UAS operations.BACKGROUND

Unmanned Aircraft Syst ems: Tarot 650 Sport UAS

Jonathan Martin, Commercial Pilot #2784208 seeks an exemption to operate Tarot

systems for compensation or hire within the NAS. The 650 Sport is a vertical takeoff and

landing (VTOL) Unmanned Airc raft (UA) with a Ground Cont rol Station (GCS) utilizing

a LED monitor display. The Tarot 650 S port has a maximum gross weight of

approximately 7 pounds, while having a length of 20 inches, width of 20 inches, height

of 12 inches, and a maximum speed of approximately 29 knots. The Tarot 650 Sport is

equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors and utilizes the Eagle Tr ee Vector stabi lization system.

The Tarot 650 Sport UAS that will be ope rated by Jonathan Martin and 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 Re gistration Marking

.

BASIS FOR PETITION

Petitioner, Jonathan Marti n, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the F AA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby

petitions the Administrator to commercia lly operate the Tarot 650 Sport UAS in the

National Airspace System (NAS), and for an exemption from the requirements of 14

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b).In consideration of the speed, weight, si ze, and limited operating area associated

with the unmanned aircraft and its operati on, Jonathan Martin’s operation of 650 Sport

UAS meets the conditions of FMRA Secti on 333 and therefore, will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Jonathan Martin requ ests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as th ese sections set forth

requirements for maintenance that only apply to aircraft with an ai rworthiness certificate.

Jonathan Martin submits that the request ed relief is proper since an equivalent

level of safety will be ensured. Jonathan Martin will use experienced personnel or

technicians to perform maintenance, altera tions, or preventive maintenance on the UASs

using the methods, techniques, and practices prescribed in the operating documents (i.e.,

Monthly Maintenance Log, and Tarot 650 S port Instruction Manual). Furthermore,

Jonathan Martin will document and maintain all maintenance records for the Tarot 650

Sport UAS.

Jonathan Martin seeks relief fr om Section 91.7(a), entitled Civil aircraft

airworthiness , because the Tarot 650 Sport UAS does not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Jonathan Martin

submits that he will ensure that the Tarot 650 Sport UAS is in an airworthy condition,

prior to every flight, by determining that the UAS is in compliance with the operating

documents (i.e., Monthly Maintenance Log, and Tarot 650 Sport Instruction Manual),

and that the aircraft are in a condition for safe flight.

Jonathan Martin also seeks an exemp tion from the requirements of Section

91.121, entitled Altimeter Settings , as the Tarot 650 Sport UAS will not have a typical

barometric altimeter onboard. However, altitude information of the Tarot 650 Sport UAS

will be provided to the PIC via Eagle Tree Vector Global Positioning System (GPS)

equipment and radio communications telemetr y data link, which downlinks from the UA

to the GCS for active monitoring of the flight path. This altitude information, combined

with Jonathan Martin’s operation of the Taro t 650 Sport UAS within visual line of sight,

at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.Additionally, Jonathan Mart in seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Jonathan

Martin submits that safety will not be a ffected by operation of the Tarot 650 Sport UAS

during daylight hours in visual meteorological conditions (VMC) under visual flight rules

(VFR), with enough battery power to fly for a total duration of approximately 13 minutes

to the first point of intended landing and, assu ming normal cruising speed, to fly after that

for at least 4 minutes.

In accordance with 14 C.F.R. § 11.81, Jonathan Martin provides the following

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Jonathan Martin
582 Coatesville RD West Grove PA 19390
Email: FutureAviatorsUSA@gmail.com 610-476-1702B. The Specific Sections Of 14 C.F.R. From Which Jonathan Martin Seeks Exemption.

1. Jonathan Martin Seeks Exemption Fr om The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

2. Jonathan Martin Seeks Exemption Fr om The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, s ubsection (a), states the following, in

part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter settin g of a station along the route and within 100 nautical m iles of the aircraft;

(ii) there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) the case of an aircraft not equippe d with a radio, the elevation of the departure airport or an appropr iate altimeter setting available before departure.

3. Jonathan Martin Seeks Exemption Fr om The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landi ng and, assuming normal cruising speed, to fly after that for at least 20 minutes.

4. Jonathan Martin Seeks Exemption Fr om The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the

following: Each owner or operator of an aircraft— (a) Shall have that aircraft in spected as prescribed in s ubpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies re paired as prescribed in pa rt 43 of this chapter[.]5. Jonathan Martin Seeks Exemption Fr om The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration , subsection (a)(1), st ates the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebui lding, or alteration unless--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

6. Jonathan Martin Seeks Exemption Fr om The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preced ing 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

7. Jonathan Martin Seeks Exemption Fr om The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) a nd (b), state the

following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller , rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limite d parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhaule d on a specified time basis.

(iv) The current inspection status of th e aircraft, including the time since the last inspection re quired by the inspection program under whichthe aircraft and its app liances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each , the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring acti on, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and cu rrently installed engines, rotors, propellers, and appliances.

(b) The owner or operator sh all retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the wo rk is performed.

(2) The records specified in paragraph (a)(2) of this s ection shall be retained and transferred with the aircra ft at the time the aircraft is sold.

(3) A list of defects furnished to a re gistered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Jonathan Martin Seeks And The Reason Jonathan Martin Seeks The Relief.

1. Extent Of Relief Jonathan Martin Seeks And The Reason Jonathan Martin Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to

the extent required to allow Jonathan Martin to determine that the Tarot 650 Sport UAS

are in airworthy condition pr ior to every flight by en suring that the UAS is in

compliance with the operating documents (i.e., the Jonathan Martin Aerial Operations

Manual, Monthly Maintenance Log, and Tarot 650 Sport Instruction Manual).Jonathan Martin seeks the requested re lief because the Tarot 650 Sport UAS does

not require an airworthiness certificate in acco rdance with 14 C.F.R. Part 21, Subpart H.

Therefore, Jonathan Martin will ensure that the Tarot 650 Sport UAS is in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and Tarot 650 Sport Instruc tion Manual) prior to every flight, and

further, determine that the aircraft are in condition fo r safe flight, as stated in the

conditions and limitations below.

2. Extent Of Relief Jonathan Martin Seeks And The Reason Jonathan Martin Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimet er settings, may be required to allow

flight operations of the Tarot 650 Sport UAS, which utilize a barometric pressure sensor,

GPS equipment, and a radio co mmunications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA

requires that any altitude information concer ning UAS operations be re ported to air traffic

control (ATC) in feet above ground level (AGL), Jonathan Martin seeks the requested

relief because the Tarot 650 Sport UAS altimeter may be set on the ground to zero feet

AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of th e proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the Tarot 650 Sport UAS is equipped with a barometric pressure

sensor and GPS equipment, whic h automatically ensures that a ground level pressure

setting will be established prior to each flight, and provides th e PIC with altitude

information of the UA on the heads-up display of the GCS.

3. Extent Of Relief Jonathan Martin Seeks And The Reason Jonathan Martin Seeks Relief From Section 91.151(b).Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow f lights of the battery powered Tarot 650 Sport

UAS during daylight hours in visual meteorological conditions (VMC), under visual flight

rules (VFR), for a total duration of 13 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4 minutes. Jonathan Martin

seeks the requested relief because without an exemption from Section 91.151(b), the flight

time duration of the battery powered Tarot 650 Sport UAS will severely constrain the

practicality of any aerial vide o or still photo flight operati ons that Jonathan Martin

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the techni cal specifications of the Tarot 650 Sport UAS,

the Tarot 650 Sport operating documents, a nd Jonathan Martin’s proposed operating

limitations, ensure that Jonathan Martin will safely operate the battery powered Tarot 650

Sport UAS during daylight hours in visual meteorological conditions (VMC), under visual

flight rules (VFR), with enough battery power to fly for a total duration of 13 minutes to

the first point of intended landing and, assu ming normal cruising speed, to fly after that for

at least 4 minutes.

4. Extent Of Relief Jonathan Martin Seeks And The Reason Jonathan Martin Seeks Relief From Sect ions 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b)

only apply to aircraft with an airworthiness certificate, Jonathan Martin requests relief

from these Sections becaus e the Tarot 650 UAS does not require airworthiness certificates.

As set forth more fully below, the Tarot 650 Sport UAS meet the conditions of FMRA

Section 333 for operation without an airworthine ss certificate. Accordingly, Jonathan

Martin will use trained tec hnicians to perform maintenan ce, alterations, or preventive

maintenance on the UAS using the methods, techniques, a nd practices prescribed in the

UAS operating documents (i.e., the Jonathan Ma rtin Aerial Operations Manual, Monthly

Maintenance Log, and Tarot 650 Sport Instructio n Manual). Furthermore, Jonathan Martin

will document and maintain all maintena nce records for the Tarot 650 Sport UAS.

D. The Reasons Why Granting Jonathan Ma rtin’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.Granting the present Petition will further the public interest by allowing Jonathan

Martin to safely, efficiently, and economi cally perform aerial video and photography of

construction sites, real estate, and lands cape over certain areas of the United States.

Additionally, use of the Tarot 650 Sport UAS will decrease congestion of the

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the

benefits of Jonathan Martin’s proposed operation of the Tarot 650 Sport UAS will be

realized without implica ting any privacy issues.

1. The Public Will Benefit From De creased Congestion Of The NAS.

Tarot 650 Sport is battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditiona lly utilized to obtain aerial imagery. By

reducing the amount of manned ai rcraft needed to perform aerial acquisitions, an

exemption allowing the use of a Tarot 650 Sport UAS would reduce the amount of

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety

of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving an d departing aircraft will be reduced. The

Tarot 650 Sport UAS do not require an airport to takeoff or land.

Likewise, a reduction of manned aircra ft conducting aerial video and photography

missions would result in fewer ai rcraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Tarot 650 Sport UAS.

Conducting aerial acquisitions with the Tarot 650 Sport and UAS, instead of

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and

noise pollution generated during tr aditional aerial video and still photography flight

operations. By using battery power and electric motors, the Tarot 650 Sport UAS produce

no air pollution, and is the most viable environmentally consci ous alternative to the cabin

class, six cylinder internal combustion engine aircraft that ar e typically utilized for aerial

video and photography, while bur ning approximately 15 gallons per hour of AVGAS. TheTarot 650 Sport UAS, while reducing the carbon footprint of aerial acquisitions, also

eliminates noise pollution, as the UAS are pr opelled by battery powered electric motors,

rather than an intern al combustion engine.

By using the Tarot 650 Sport UAS to perform aerial acquisitions, the substantial

risk to life and property in the air and on the ground, which is usually associated with

traditional manned aircraft flight operations, wi ll be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboa rd the aircraft, the

Tarot 650 Sport UAS (weighing approximately 7 pounds, at their maximum gross weights

with lengths of 20 inches and, widths of 20 inches, and with no fuel on board), has less

physical potential for collateral damage to life a nd property on the ground, and in the air,

compared to the manned aircraft that t ypically conduct simila r operations (weighing

approximately 6,000 pounds with a wingspan of approximately 36 feet, a length of 30

feet, and a fuel capacity of 70 gallons).

3. Performing Aerial Video and Phot ography Operations With The Tarot 650 Sport UAS Will Benefit The Economy.

In addition to being safe and efficient, the Tarot 650 Sport and UAS is also an

economical alternative to usi ng manned aircraft to conduct similar aerial operations. As

such, operation of the Tarot 650 Sport UAS w ill allow United States based companies,

like Jonathan Martin, to remain competitiv e and contribute to growth of the U.S.

economy. Specifically, with the rising cost of aviation fuel and the Environmental

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S.

owned and operated companies must adopt new and alternative technology in order to

remain competitive. Operating the battery powered Tarot 650 Sport UAS is one such

technology that not only allows companies greater operational flexibility compared to

manned aircraft, but provides such flexibi lity without the high operational cost of a

traditional manned aircraft.

By operating the Tarot 650 Sport, companies such as Jonathan Martin, can remain

competitive and profitable, and therefore, provide greater job stability to employees and

contractors, which will ultimately contribute to growth of the U.S. economy. Improvedfinancial performance of U.S. companies, th rough commercial use of the Tarot 650 Sport

UAS, provides a stable workforce that increases consumer spending; improves local,

state, and federal tax revenues; and allows companies to invest in research and

development in order to remain competitiv e both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Jonathan Martin’s proposed opera tion of the Tarot 650 Sport UAS will not

implicate any privacy issues. Specifically, th e Tarot 650 Sport UAS will be operated only

in compliance with operating documents (i.e., the Jonathan Martin Aerial Operations

Manual, Monthly Maintenance Log, and Tarot 650 Sport and Instruction Manual) which

requires property owner involvement as well as local law enforcement notification, and in

accordance with the Federal Aviation Regulations, including the minimum altitude

requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemptio n Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Wh ich Jonathan Martin Seeks Exemption.

1. Reasons Why The Tarot 650 Sport UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, sp eed, and limited operating area associated

with the unmanned aircraft and its operation, Jonathan Martin’s opera tion of the Tarot 650

Sport UAS meets the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate wit hout airworthiness

certification and sets forth requirements fo r considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 st ates the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after th e date of enactment of this Act, the Secretary of Transportation shall determine if cer tain unmanned aircraft systems may operate safely in the nati onal airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Syst ems.--In making the determinationunder subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft sy stems, if any, as a result of their size, weight, speed, opera tional capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and whether a certificate of waiver, certificate of authorization, or airworthine ss certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If th e Secretary determ ines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft syst ems in the national airspace system.

In seeking this exemption, Jonathan Martin submits that the Tarot 650 Sport UAS

can operate safely in the NAS pursuant to FM RA Section 333, as demonstrated by: (a) the

characteristics of the Tarot 650 Sport UAS; (b ) the pilot certificati on requirement; and (c)

the specific operating limitations.

a. The Specifications Of The Tarot 650 Sport UAS Demonstrate Its Safe Characteristics.

The Tarot 650 Sport UAS does not create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security consid ering its size, weight, speed,

and operationa l capability.

i. Technical Specifications Of The Tarot 650 Sport UAS.

The technical specifications of the Taro t 650 Sport UAS is set forth by the Tarot

650 Sport Specifications and Data Sheet, attached here to as Exhibit A.

ii. The Tarot 650 Sport UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

The Tarot 650 Sport UAS may be operate d in both manual and fully autonomous

flight modes.

iii. The Tarot 650 Sport UAS Are Designed For Automatic Return To

Home Point Or Hover In The Even t Of Loss Of The Control Link Or Navigation.When the Control Link is lost, the Tarot 650 Sport UAS will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the Tarot 650 Sport UAS do not

reacquire control link data from the GCS, the UAS will assume that the Control Link is

lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will

descend to the takeoff position and shutdown.

iv. The Tarot 650 Sport GCS And Its Operation.

A complete description of the operation and specificati ons of the Tarot 650 Sport

GCS and flight control software from Eagle Tree Systems is provided in the Tarot 650

Sport User Manual. Tarot 650 Sport Eagle Tree Systems Vector User Manuals are attached

hereto as Exhibits C.

b. Flight Operations Of Tarot 650 Sport UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Jonathan Martin will only utilize certif icated pilots who possess a current and

valid airman medical certificat e to act as a pilot in comma nd (PIC) of the Tarot 650 Sport

UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of Tarot 650 Sport UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Jonathan Ma rtin proposes to commercially operate

Tarot 650 Sport UAS for the special purpose of conducting aerial video and photography

over certain areas of United States, pursuant to the following specific operating

limitations:

1. Operations authorized by this gran t of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: Tarot 650 Sport Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a pe tition to amend this grant.

2. UAS operations under this exemption w ill be limited to conducting operations for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.4. The UA must be operated at an altitude of no more than 200 feet above ground level (AGL), as indicated by the pr ocedures specifie d in the operating documents unless a special request is made and appr oved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual li ne of sight (VLOS) of the PIC at all times. This requires the PIC to be ab le to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by th e PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety obse rver (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the fli ght and cannot tran sfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescrib ed in the operating documents.

8. The SO must not perform any other dutie s beyond assisting the PIC with seeing and avoiding other air traffic and othe r ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditi ons and limitations contained in the grant of exemption and the procedures out lined in the operating documents, the conditions and limitations contained in th e grant of exemption take precedence and must be followed. Otherwise, the ope rator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revi sed documents to the Ad ministrator upon request. The operator must also present updated a nd revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision woul d affect the basis upon which the FAA granted the exemption, then the operator must pe tition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspec tion reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Cont rol Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e .g. replacement of a flight critical component, must undergo a functional te st flight. The PI C who conducts the functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equi pment, not already covered in the relevant sections of the operating documents.13. The operator must follow the UAS ma nufacturer’s ai rcraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintena nce, inspections, a nd record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhau l component parts must be noted in the aircraft record s, including total time in service, description of work accomplished, and th e signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exempti on must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an en try in the aircraft record of the corrective action taken agai nst discrepancies discove red between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emer gency maneuvers and maintaining appropriate distances from persons, ve ssels, vehicles a nd structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemp tion. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flight s, all persons not essential for flight operations are considered nonparticipan ts, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted duri ng night, as defined in 14 C.F.R. §

All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s manage ment is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or le ss than 2,000 feet horizontally from a cloud or when visibi lity is less than 3 statute miles from the PIC.

22. If the UA loses communications or lose s its GPS signal, it must return to a pre- determined location within th e planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in th e event of unpredicted obstacles or emergencies in accordance with the operating documents.24. The PIC is prohibited from beginning a flight unless (c onsidering wind and forecast weather conditions) there is e nough power to fly at normal cruising speed to the intended landing point a nd land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prio r to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more th an 72 hours in advance, but not less than 48 hours prior to the ope ration. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the ra dio frequency spectrum used for operation and control of the UA mu st comply with the Federal Communications Commissi on (FCC) or other ap propriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Cont rol Station of the UAS any time the UAS is operating. These documents mu st be made available to the Administrator or any law enfo rcement official upon request.

29. The UA must remain clear and yield th e right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PI C from any moving de vice or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator train ees or essential persons), vessels, vehicles , and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA a nd/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, ve hicles or struct ures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and de termined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, op erator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with permission from the land owner/cont roller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.33. Any incident, accident, or flight opera tion that transgresses the lateral or vertical boundaries of th e operational area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From Th e Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety establis hed by Section 91.7(a) will be maintained

because prior to every flight, Jonathan Martin will ensure that the Tarot 650 Sport UAS is

in an airworthy condition based upon the UAS’s compliance with its operating documents

and as stated in the conditions and limitations herein.

Additionally, the FAA has previously gran ted relief from Section 91.7(a) specific to UAS,

in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

3. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety establ ished by Section 91.121 will be maintained

because the altitude information of the Tarot 650 Sport UAS will be provided to the PIC

via GPS equipment and a radio communications telemetry data link, which downlinks

from the UA to the GCS for active monitoring of the flight path and al titude. This altitude

information, combined with J onathan Martin’s operation of the Tarot 650 Sport within

visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to

Section 91.121. The altitude information will be generate d by GPS equipment installed

onboard the aircraft. Prior to each flight, a zero altitude init iation point is automatically

established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respec ts, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).4. Reasons Why An Exemption From Th e Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established

by 14 C.F.R. Section 91.151(b) as a result of (1 ) the technical specifi cations of the Tarot

650 Sport and Tarot X4; (2) the lim itations on the proposed flight operations; and (3) the

location of the proposed flight operations. Acco rdingly, Jonathan Martin will ensure that

it will safely operate the battery powered Ta rot 650 Sport UAS duri ng daylight hours in

VFR conditions, with enough battery power to fly for a total duration of 13 minutes to the

first point of intended landing and, assuming normal cruising speed, to fly after that for at

least 4 minutes.

Here, as in Exemption No. 11109, the tech nical specifications of the Tarot 650

Sport; the limitations on the proposed flight operations; and the location of the proposed

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as the Tarot 650 Sport UAS provide

audible and visual warnings to the PIC at the GCS when the UAS experiences low battery

voltage, the first warning occurring at appr oximately 33% remaini ng battery power, and

again at approximately 10% remaining battery po wer. At the critically low battery level,

the Tarot 650 Sport UAS will descend and land automatically.

Significantly, previous exemptions gr anted by the FAA concerning Section establish that

safety is not adversely affected when the technical characte ristics and operating

limitations of the UAS are considered. Relief has been granted for manned aircraft to

operate at less than the minimums prescr ibed in Section 91.151, including Exemption

Nos. 2689, 5745, and 10650. Moreover, the FAA ha s previously granted relief from

Section 91.151 specific to UAS, in circ umstances similar, in all material respects, to those

presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Jonathan Martin submits that the equivalent level ofsafety with regard to the regulatory mainte nance and alteration requirements established

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) will be

met because Jonathan Martin will use trained technicians to perform maintenance,

alterations, or preventive ma intenance on the UASs using the methods, techniques, and

practices prescribed in the operating docum ents (i.e., the Jonathan Martin Aerial

Operations Manual, Monthly Maintenance Log, and Tarot 650 Sport Instruction Manual).

Furthermore, Jonathan Martin will document and maintain all maintenance records for the

Tarot 650 Sport UAS.

Since the Tarot 650 Sport UAS will be in spected as prescribed by the operating

documents, Jonathan Martin will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Tarot 650 Sport User

Manuals are attached hereto as Exhibit C; a copy of the Tarot 650 Sport and UAS

Maintenance LOG is attach ed hereto as Exhibit D.

Likewise, the exemption sought will not a dversely affect safety because Jonathan

Martin will use trained tec hnicians to perform maintenan ce, alterations or preventive

maintenance on the UAS using the methods, t echniques, and practices prescribed by the

operating documents.

Furthermore, the exemption sought would ma intain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 9 1.417(b), because all ma intenance of the

Tarot 650 Sport and Tarot X4 UASs will be performed by trained technicians.

Maintenance will be documented and maintain ed utilizing the monthly maintenance log.

Significantly, previous exemptions gr anted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) es tablish that safety is

not adversely affected when the technical ch aracteristics and operating limitations of the

UAS are considered.

In consideration of Jonathan Martin ’s proposed operating limitations, the

operating documents, and the technical aspe cts of the Tarot 650 Sport UAS, Jonathan

Martin submits that safety will not be a dversely affected by gran ting exemption from 14

C.F.R. Sections 91.405(a), 91.407(a)(1) and (a )(2), 91.409(a)(2), and 91.417(a) and (b).The FAA has previously granted relief specific to UAS in ci rcumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the F AA Modernization and Reform Act of

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Jonathan Martin

requests that the FAA prescribe special condit ions for the intended operation of the Tarot

650 Sport and UAS, which contain su ch safety standards that the Administrator finds

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21,

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will

permit safe operation of the UAS for the li mited purpose of conducti ng aerial video and

photography over certain areas of the United States for compensa tion or hire. FMRA

Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security;

and further, provides the aut hority for such UAS to operate without airworthiness

certification in accordance with any requirements that must be established for the safe

operation of the UAS in the NAS.

Likewise, the Administrator may prescr ibe special conditions pursuant to 14

C.F.R. § 21.16, for operation of the Tarot 650 Sport, since the airworthiness regulations of

14 C.F.R. Part 21 do not cont ain adequate or appropriate safety standards, due to the novel

or unusual design features of the aircraft. Section 21.16, entitled Spec ial Conditions, states

the following:

If the FAA finds that the airworthine ss regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, ai rcraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he

prescribes special conditions and amendmen ts thereto for the product. The special

conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary toestablish a level of safety equivalent to that established in the regulations. See 14 C.F.R. §

21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the

FAA may prescribe special conditions for J onathan Martin’s intended operation of the

Tarot 650 Sport UAS, which contain su ch safety standards that the Administrator finds

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21,

Subpart H, and 14 C.F.R Sections 91 .7(a), 91.121, 91.151(b), 91.405( a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Jonathan Martin Seeks Exemption:

Jonathan Martin commercial pilot certificate number 2784208 seeks exemption from the requirements of 14 C.F.R Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Jonathan Martin Seeks:

This exemption will permit Jonathan Mar tin commercial pilot certificate number 2784208 to commercially operate an Unmanne d Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support Jonathan Martin’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of

2012 (FMRA) Section 333, which directs the Secr etary of Transportation to determine if

certain UAS may operate safely in the NAS. As such, Jonathan Martin’s request for

exemption may be granted pursuant to the au thority of FMRA Section 333 and 14 C.F.R.

Part 11, as set forth above.

FMRA Section 333 sets forth the requir ements for considering whether a UAS

will create a hazard to users of the NAS or the public, or otherwise pose a threat to

national security; and further, provides the authority for such UAS to operate without

airworthiness certification.

As discussed in detail above, Jonathan Martin will operate the Tarot 650 Sport UAS safely

in the NAS, without creating a hazard to user s of the NAS, or the public, or otherwisepose a threat to national security.

CONCLUSION

As set forth herein, Jonathan Martin co mmercial pilot certif icate number 2784208 seeks

an exemption pursuant to 14 C.F.R. §11.61 a nd Section 333 of the FAA Modernization

and Reform Act of 2012 (FMRA), which will permit safe operation of the Tarot 650

Sport and UASs commercially, without an ai rworthiness certificate, for the limited

purpose of conducting aerial video and phot ography over certain areas of the United

States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Moderniz ation and Reform Act of 2012, while also

advancing the interests of the public, by allowing Jonathan Ma rtin to safely, efficiently,

and economically operate th e Tarot 650 Sport UAS comm ercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Se ction 333, Jonathan Ma rtin respectfully

requests that the Administrator grant this Pe tition for an exemption from the requirements

of 14 C.F.R Sections 91.7(a) , 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b), a nd permit Jonathan Martin to operate the Tarot 650 Sport

UAS commercially for the purpose of conducting aerial video and photography over

certain areas of the United States.

Dated: June 3, 2015

Respectfully submitted,

Jonathan Martin

582 Coatesville RD
West Grove PA 19390Appendices :

A – Tarot 650 Sport Specifications Data Sheet B – Tarot 650 Sport Manufactures User Manual C – Eagle Tree Systems Vector User Manuel (ATTACHED) D – Monthly Maintenance LogEXHIBIT – A

TAROT 650 SPORT UAS TECHNICAL

SPECIFICATIONS

The Tarot 650 Sport and Tarot X4 UAS’s ar e professional grade all carbon fiber UAS’s which are installed with Eagle Tree Vector so ftware enabling the user to set parameters which will not allow flight into controlled ai rspace. Parameters can also be set to limit flight to no higher than a predetermi ned and set altitude as well as limit flight to a predetermined and set distance. In addition, the installed Eagle Tree Vector software provides real-time altitude and location information to the PIC via the linked monitor and on screen display visually as well as audibly.

Tarot 650 Sport

Aircraft Supported Battery – Stor m 5500mAH LiPo Battery Weight (Battery & Prope llers Included) – 5 lbs Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m Max Yaw Angular Velocity - 2001/s Max Tilt Angel - 351 Max Ascent Speed – 6m/s Max Descent Speed – 2m/s Max Flight Speed – 15m/s (NOT RECOMMENDED)

Gimbal

Tarot 2D Vs. 2 Operating Current – 200mA-500mA Control Accuracy - ±0.1 Controllable Range – Pitch: -135 - 90 Maximum Angular Speed – Pitch: 2 000/s

Camera

GoPro Hero 3+ Lens Aperature – f/2.8 Effective Pixels – 12mp Resolution – 12 mega pixels HD Video Recording – 1080p30 & 720p

Transmitter Operating Frequency – 5.728GHz – 5.85GHz Communication Distance (unobstruc ted) – FCC Compliance: 800m Receiver Sensitivity (1%PER) - -93dBm Transmitter Power – FCC Compliance: 100mW Working Voltage – 120mA@3.7VRange Extender Operating Frequency – 2412-2462MHz Communication Distance ( unobstructed) – 500-700m

Transmitter Power – 20dBm Power Consumption – 2WEXHIBIT-B

Tarot 650 SPORT USER MANUEL

Tarot FY650 Sport - A Portable size Quadcopter with Motorized Landing Gear This is Tarot's only Quadcopter frame, 650 size, came with Motorized Landing Gear and it takes maximum 15" propeller.

The Tarot FY650 Sport has a lot in common with the bigger Tarot FY680-Pro (it has Six rotors), both have a Carbon Fiber

Deck and a Integrated PCB Board, user can solder the ESC's power cable directly onto this PCB board and save a lot of heavy and messy cables. The movable battery mount is also a go od feature to balance the best C.G., because when you put

a Tarot T-2D gimbal in the front of the drone, you need to off-set the weight with battery. The best of all is the Motorized Landing Gear, they connected to a Controller (included) and through a switch on your RC transmitter, you can retract and

deploy the legs, so you will not see the legs in your Video anymore, this is a nice touch as the Motorized Landing Gear usually is "DIY" item, now Tarot includes them in the package.

The Tarot FY650 Sport airframe is versatile, you can put small but high speed motors and smaller props on it to become an agile GoPro Camera platform, or use with big motors and props on it to be a long flight time platform, it's a great choice for you in Price and Performance for shooting beautiful scenery or interesting footage for YouTube.

We recommend 4S 14.8V, Tarot 4006 620kv and 13" prop, or even more powerful config like 6S 22.2V Li-Po, Tarot 4008 380kv motor 13" propeller, this can carry payload up to 1kg to 1.3kg, that means GoPro and similar size camera are no problem. Remember that if you put the camera in front, please adjust the battery's position at the rear to have best C.G.

Great all around drone

You can put a lot of different gadgets on the drone, for lighter payload you can use lighter and cheaper config like small motors and battery, if you want to go big, just increase the size of the motor and props, we like this FY650 Sport

. Motorized Landing Gear

Came with the package, 100% made by Tarot, fully integrated with the FY650 Sport Airframe.

Retract and Deploy with a flip of a switch

The two landing gears connect to a controller, and connect the controller to the RC receiver.

Four rotor drones will have longer flight time, but less payload capacity

Two motor less then Hexacopter, that means less energy consumption and fly longer.

The new designed Integrated PCB Upper Deck

The Tarot FY650 Sport has a PCB Upper Deck and Carbon Fiber Lower Deck. You can solder the ESC's power directly onto the PCB Upper Deck, no need to handle a bunch of power cables, much clean layout in the drone.

The soldering points on the PCB Board

This is the PCB Board of the FY680 Pro, very similar to the FY650 Sport.Light weight and easy to adjust motor mount

Support motor up to 45mm Dia., with 16m m, 19mm, 25mm and 27 .7mm hole spacing.

Came with Mounting Rail and Movable Battery Mount

No need to spend money for the mounting rail. It is 60mm apart, you can put T-2D Gimbal on it and move that battery position for best C.G.

A Portable 650 Size Hexacopter Frame

Easy transportation is very important, especially when you try to put it in the car by yourself...

Fold it up, it's very portable

It's foldable, easy to put in the back seat of your car.

Specifications : - Frame weight : 750g

- Arms diameter : 16mm

- Drone dia : 650mm - Center body dimension : 190 x 200 x 2.0mm - Mount mounting hole : 16mm hole x 2 / 19mm hole x 2 / 25mm hole x 4 / 28mm hole x 3 - Drone's weight (everything it needs to fly) : around 2.3kg - Payload (it can carry) : 1~1.3kg

Our Flight Reference : - Battery Supply : One 4S 14.8V 5500mah for 13 minutes

- Motor : Tarot 4006 620kv Motor - ESC : Hobbywing Platinum 30A-OPTO - Propeller : Tarot 1355 Carbon Propellers - Carrying : Tarot T-2D Brushless Motor Gimbal, TS352 FP V Transmitter, GoPro Hero 3+ (They weight about 700g)

This package includes : 1. 1 X Tarot 650 Sport Airframe and Motorized Landing Gear 2. 1 X Controller for the Landing Gears 3. 1 X Manual with English

4. Battery Velcro Tape

EXHIBIT-C Eagle Tree Systems Vector Manuel

(Attached)EXHIBIT – D

MO N T H L Y $ MAI N T E N AN CE $ L O G

month: (year:

U AS $ #: $ Date(Issue(

Discovered Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:((( Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: