### Private and Confidential

## ~~~·~~ij~!~ft\t~!llt<J~!f~f!~j~411\ff~~~~:lt~1f!j~~~·~~fl:ltf~- Section 333 Exemption Petition

U. S. Department ofTransportation Docket Management System
1200 New JerseyAve, SE Washington, DC 20590



### Re: Exemption Request Section 333 ofthe FAA Reform Act ofthe FederalAviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)
Dear Siror Madam, 

### I,

### !~~li!,Jl~~~~~~~'l;IJ¥~i,jt~~~~~~tlf;ilftflii,am writing pursuant to the FAA Modernization and Reform Act of2012 and the procedures contained within 14 C.F.R. 11, to request that

### I,~·-~ 

# ..**~~: :,!ttltfi)\l)~~)an**  owner and operator ofsmall unmannedaircraf(be'exempte rom the Fede'ral Aviation Regulations ("FARs") listed below so that 

### I,

## "ttl,!!i:~!~~Mt;t'~~-f&~~~!fifttl~l~il~~l\~''may operate my small ultra lightweight unmanned aircraft system ("UAS") in commercially regulated airspace by the Federal Aviation Administration ("FAA").

Following exemption and approval by the FAA, I, will primarily use my professionally built following applications:

' ....My,**~t:fi!~M!Ri~4!i!!~I'~~1@JIJJfi~s,** exemption request would permitthe operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS's for the development ofcommunity and government use videos, permissible within property boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehiculartraffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyistswith no safety plan or controls in placeto prevent catastrophe. Furthermore, it is my intent to assistfuture FAA safety protocols and regulations exclusive to lightweight UAS's for specificvideo and photography usage by sharing information with the FAA as I,

### lgfi:1~J)i~~~l-!111f~~llJl~ll~llf,1f:IIJ;t~record flight data and other pertinent information gained through permitted flight operations.

In addition, granting my,

### !(~if!1;!4B!Jtt1~~~1,f:ll!tf!~JI\~~li~s, exemption request will comply with the Secretary ofTransportation's (FAAAdministrator's) instructions to not only integrate UAS's into the national airspace system, butto "

...establish requirements for the safe operation ofsuch aircraft systems [UAS's] in the national airspace system" under Section 333(c) ofthe Reform Act specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, closed-set motion picture film operations and television, and structure inspections, to aid state and local agency's. Further I 

### Xfji\t)jffJj'"'**'"IO;~Sai~I,;Jil('''t•Mt~Mfir'**1\ii;:lwill conduct m o erations in 1**·c<:···•.:·::··'\;;;":i;;·>:~!t:l•::;.)'~~:·':i:•.;;,;x·s·;c;;;·::·,,;,•!.:.;•·;;:,·c;:.;:+~:'~r'\':\~ft':** 

### Y 

### p compliance with the protocols described herein or as otherwise established by the FAA. Forthe reasons stated below, I,

### Vtl:!fi!\IB:R~~~~~~!~I~~!t~ltl!f:ll'lftl!)~:respectfully request the grant ofan exemption allowing me to operate ultra lightweight, remote controlled UAS's to aid academic community awareness, to benefit/stimulate attraction to the metro**J4Q$;*~81Ji)** and to enhance personal and publicvideo feeds. A grantthatwill ultimately

## 'iii1~vJ\Jfo.s·~to play a more positive role in our local community by increasing employment opportunities, heightening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel- a potential public hazard in and of itself.Each ofthese items reflect in favor ofan exemption for me,

### ~,~,9!!~~·~'·'~4,..~~;**~IJ~'i'Gl\t~•·** My UAS's utilize eight (8) or less rotating propellers for balance, control and si'abilitY: MyUAs's are equipped with the following via video and datatelemetry: 1) Altimeter 2) Attitude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery Leftwith approximate time. 11) Loiter and circle mode. 12)Auto safety or RTL ( Return To Launch) 13)Auto landing technology.
Each UAS weighing less than thirty (36) pounds (far below the maximum 55 pound limit); lncludingcamera(s) with orwithoutgimbal (a camera stabilizer). I,**\r*IR'~'t-.,A~~·~-~**

## ~i!tAl~ttm~•'tlt'tJ. considers safety as foremost with each

## flight~**M,y~malfu~mann~'d''** ' aircraft is designed to hover in place, circle in a specific place or loitervia GPS and can be operated in winds upto 30.4 knots (35mph) wind. For safety, stability and fear of financial loss Iwill notfly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS modethat allows my UAS to hover/circle in place or land when radio controls are released.
With three (3) modes to choose from, Iwill fly with the modes safestto complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed slowly descend to point oftakeoff and orto land at point of launch after ascending to a pre-set altitude to ensurethe UASwill clear any obstacles that may be between the takeoff point and the current position ofthe UAS. This failsafe altitude will not be set more than 200ft and is determined before each flight.

### I**Vince'~ "i'''ifii,;~tl~~~~~~V'tiif0<11:ij~'g"""~** **~will** not o erate m UAS near air orts '**'e'':::+;:,::;c:');:;!!llcj};;,!i;\~:,i'fi' 'i"ji~;;:,;y::~';c:;;,;!{,i;'!:;:,;~;,,~~~~,,f;f"J{** **1::** 

### p Y 

### p 1 hospitals nor police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. I am constantly on alertfor any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediatelyto the nearest and safest ground point should a manned aircraft approach my location or 

### I suspect manned aircraft may approach near my location. My UAS's are capable of vertical and horizontal operations, and is flown only within my line ofsight, as the remote control pilot. My UAS's are alsoflown with a second operatorwho aids in watching for any obstacles, including manned aircraft, within the flight zone ofthe UAS. Utilizing battery power rather than combustible fuels, flights generally last between three (10) to fifteen (25) minutes, with an altitude underone hundred fifty (150) feet. (3 )Smart Mode includes, position hold, self-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event ofcommunication interruption between RC transmitter and UAS.
I,

### ~~~:~ii!!·~~\1l@~~~~i!1~1"1

# .. tifiD)fiutilize afresh fully charged battery with each flight

# asa safety preca\Jilo'n'; fulftiighftime ilmlffor'each battery is eight (8) to thirty (30) minutes as tested. 

### I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level ofoperation. 

### I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. 

### I have clocked numerous practice flights in remote areas as a hobbyist simulating flights forfuture commercial use to gain familiarization with the characteristics ofthis specific UAS's performance underdifferenttemperature and weather conditions. 

### I also practice computerized simulated flights to maintain adequate skills and response reflex time. All forthe sake ofsafety.
I,

### ~!!JIIi·!~~~,~~tKiJi~teit~~¥:fifam extremely cautious when operating ofmy UAS/ultra lightweight unmanned aircraft and will not "create a hazard to users ofthe national airspace system orthe public." 

### 112 P.L. 95 

### § 333 (b). Given the small size and weight of my UAS it falls well within Congress's contemplated safety zone when it promulgated the ReformAct and the corresponding directive to integrate UAS's into the national airspace s stem.**V'ilt"'"''~O'.''jl.m;~Rat~l:e.** 

## tt'**t'il?Jl.I~"A~fibJ1fs** UAS used in hobb fli ht has a 

### Y ;.:;:

..**tv~ :,.:Jf!\:i:':'''";::,~'~,;:''!ii':,,:>c.::::Ju:';~'Vt:.:',,,.,,.}f\'~~f;"!'!~:·;,,,;i,!**  ' 

### Y 

### g ' demonstrable safety record and does not pose any threatto the general public or national security.



### IV. How

### !~fl;~{l~til\ifl!f@~ft·l~tfl~ltl,@H!Iftlt~·s Request Will Benefitthe PublicAsA Whole: Aerial videography for geographical awareness, education, search and rescue, land management, structure inspections and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies, average homeowners and property owners the expense ofsuch aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense; depriving non-luxury owners and lower budget companies from a valuable marketing tool. Manned aircraft pose athreatto the publicthrough potential catastrophic crash thatthe**~~~~,.,,,** community has experienced in the past with militaryaircraft, medical helicopters, and news helicopters crashes within the city of**lf,~~~~~~~-** Each resulting in loss of life. ··· ··· ...... ' · ··· y
Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard landingswithin city limits. My,

### !fi~'t;:g!!!!~~l!~~!~!M~~@;i**Pt'Jil~--iy;Jtzz~·s,** UAS poses no such threat since size and lack of combustible fuel allevrates'anyp.otential threatto the public. Congress has already proclaimed that it is in the public's interestto integrate commercially flown UAS's into the national airspace system, hencethe passing ofthe ReformAct. Granting my,

### ~lttRt~~!~~~ffA~~f:~'!'t'Jt

### 1\tiJ:~.If;Jt'J!It~~·s, exemption request furthers the public intere.st through acaC:temTc/visual awareness.of

## the geographical benefits in and around the metro 

### Los Angeles area. My ultra light weight UAS is battery powered and creates no emissionsthat can harm the environment. The consequence ofmy ultra lightweight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. The public's interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight UAS's. Permitting me,

### K!~§i\l,l~I!~!~HJ:;~!~If~:fl~~~-~~~~jfi· to immediately fly within national airspace furthers economic growth. Granting my exemption request substantially furthers the economic impactforthe metro 

### La Mirada and surrounding community for companies looking to relocate or build around the 

### La Mirada metro area as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both ofwhich serve as a stimulus to the community. V. Reasons Why

### !!J!~~"Jtt~';t.ll~!fl'*!l~lfA!~f!'fi~'s Exemption Will NotAdverselyAffect Safety Or HowThe Exemption Will Provide a Level ofSafetyAt Least Equal To Existing Rule: My,

### ~t(-~;~-~t·~~~,-~tJi·i·-~~~~~~~~·s,**exem~tion**.· will not adversely affect safety. Quite the contrary, forthe reasons stated permitting me,**Ji~~~itt**

### ~'!~!tlt~~~!~flt~!~l!llltJl~~~~. to log more flight time in FAA controlled airspace,.with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as ofyet undiscovered safety protocols for Realtors, land and structured oViners. Fordevelopment in cooperation with the FAA. In addition**l.~~~ii~lj~~-~~,'60)~;;**

## ~~l'f 

## •.**\\!BitlfiftiPlfl~~.** submit thefollowing representations of

## enhan~~~:~n!~t?~~~;~~f~~·;fal

## ~~cl~ography'**~~·a** ?t1?tography:.f\AY

..UAS's weigh less than 

### s1>(,(&l·PQ\Jf\d$

## ~<>inPl~~**~~h.~,ap !nff)graJe.¢f·;tl,Jtrad\91'll>'t~eigt)t~mer~,;**  I only operate my UAS below200feet (well within the·400 foot permissible ceiling set by the FAA Modernization and ReformAct of2012); My UAS only operate for 3-30 minutes perflight; I land my UAS priorto manufacturer recommended minimum level ofbattery power; I pilot my UAS through remote control only by line ofsight; and have live video feed for a secondary pilotto monitor video recording; I receive a live telemetry feed from my UAS during all flights which include remaining battery voltage, distance, altitude, and any anomalies that may occur during flight; My UAS's Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz frequencies in accordancewith CFR47, Part 15 for model aircraft use. My UAS's camera system utilizes 5.725Ghz-5.875Ghzfrequencies in accordance with CFR47, Part 15.My UAS's have a GPS controlled flight controller- a flight safety feature whereby it hovers or circles and then lands atthe GPS takeoff point ifcommunication with the remote control pilot is lost; I actively record and analyze flight data through the DJIInspire 1 and DJI phantom 3 flight controller app to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions priorto operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger. My,

### fll~~~~~~,~~5:!.,1tlf~~~~~~-~i;Jls, safety protocols provide a level ofsafety equal to or exceeding existing rules. It is important to note that absentthe integration ofcommercial UAS into our national airspace system, helicopters are the primary means ofaerial video and photography for community awareness real estate, structured inspections, land management and search and rescue. While the safety record ofsuch helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far saferto operate a battery powered ultra lightweight UAS. First, the potential loss oflife is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential forfire or explosions is greatly diminished. Third, the small size and extreme maneuverability ofmy UAS allow meto remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use ofpost editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated forfamiliarization/competency and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitledAirworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The

### size~ weight and enclosed operational area of my,

### ~~~B~~Ii~tt9;~9~~~~fj~J{**1 ~~!ft-tiJ)JtJJ's,**  UAS permits exemption from Part 21 because my UAS meets (and exceeds) 

# a'n equlva'fen'f"Jevel ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both theAct (49 U.S.C. § 44701 (f)) and Section 333 ofthe ReformAct. Both pieces oflegislation permit the FAAto exempt UAS'sfrom the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My,

### ~«lfiri~li!lf~£tl§~l~,~~~~l!lftlWiill~~~~·s, current and projected UAS's meet or exceed each ofthe elements.

14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. 

### § 91.9 (b) (2) requires an aircraftflight manual in the aircraft. As there are no on board pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. Anequivalent level ofsafety will be achieved by maintaining a safety/flight manual delineating areas ofwhere safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827.
14 C.F.R. 

### § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systemswith a barometric sensor orcontrolled GPS "geofencing"
14 C.F.R. § 91.203 (a) and (b) provides forthe carrying ofcivil aircraft certifications and registrations. They are inapplicable forthe same reasons described above. The equivalent level ofsafetywill be achieved by maintaining any such required certifications and registrations by me,

## ~if:q:~~~~l~,~~~!~-~~(@~IJfi~JJ~~ B. 14 C.F.R. 

### § 45.23: Marking ofTheAircraft. Applicable Codes of Federal Regulation require aircraftto be marked according to certain specifications. My UAS can be marked with the appropriate "N" numberonce this "N" number has been given.
C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuantto 14 C.F.R. 

### §§ 61.113 (a)& {b),**priv~te** pilots are limited to non-commercial operations. I,**~~~1·i~ltM-i'{**

### flt~f-"tJ@l~II!IJ\IJ'tWIIJ'i}£, The sUAS Pilot in Command must possess

# at least

### a~spolfpilot c**,;l"'"'-'·'">h~O_>•c"•':'** :J·.V:><**·'-~c?-• ,,,:,.1** **;f.--·J'~~>** "'•',' ,l,;"£'w;o;.j'',_,•**;:.-:.~.<** certificate and a driver's license. The PIC must also meetthe flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. 

### § 61.
D. 14 C.F.R. 91.119: Minimum SafeAltitudes. 14 C.F.R. 

### § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greaterthan 300fclose AGL; safely below the standard of400AGL. I**Yl-~lil$lt4il81Ji(;t•tti*IR1liii''1Mih~''1~will** however operate '**{~n·> -1':.-\~\** **;:.cJ\·c>·?,:···sv-·:;,\Wi~7~';f >X~>"·\~1~~L'·$?/,J~}\}Y-·~"~)5i~s~;;.<t,,\~~,;::;,,,):·?;;.** **-~-~:~;.><:vj!<':'C-~~- ,_,;;cj~f!!}~f:,f:fr;**  my UAS in safe areas awayfrom public and traffic, providing a level ofsafety at leastequivalent to or belowthose in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofmy UAS, an equivalent or higher level ofsafety will be achieved.


### E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance lnspections.1,2, Manual

The above-cited Regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...."These Regulations only apply to aircraftwith an airworthiness certificate. Theywill not, therefore, apply to**my,§,il(tji;1D;.Utct~i(S:8jJ:~t)l~tt**

### l!lt&i~felil'i~l's, UAS. However, as a safety precaution 

### 1

### in;p~~f,~yUAs't)~tor~,,~~Ci'ci'fi~r"',' {/C,d**,.·~** ?ifY.<,- ';:- <••,·', ·/•'**>····-'"'"'!"'~"'\·;-~·~** "'"-'' each flight.
A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary airworthinesscertificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area ofmy UAS permits exemption from Part 21 because**my,J~\(IiQjs··-Jil'(~~~~~ti-"~;**

## IJ!~~~f~,-~~·s, UAS meets an equivalent level of

## safetyp~rsu'anit~''secti~n,333~fthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both theAct (49 U.S.C.§ 44701 (f)) and Section 333 ofthe ReformAct. Both pieces of legislation permitthe FAAto exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets orexceeds each ofthe elements. 14 C.F.R. 91.7(a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. Asthere are no pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level ofsafetywill be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safet will be achieved. In summa**VlitMiBii&ti~(l•llf.AtJlllrRbflM:liiib'MI/;:'seeks** 

### y ry,**~ ~'r** ,.{<V

..**<'f~.,.;,J~L<<;; ·\c~** **~ \<'c':>c~':**  \,,('>**·cy,~·:>:.·"·** ··/A:,c**.·.~;/'-'(;;;· ;r,YF~-;·::'-\~~:** **-;,,'(,~\<~'** ,::z_**·~ '·:'-->~·,-sn,** ,. y· 1•. -t· .,,;I,Y;**;C~"' -/.,-:;.:;~{if,'**  an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) 

### & (b) to commercially operate my,

### Jt\\tl\~!~~"~~liJ!Mllffil~:'IJ!1'f§if.~fA~l~1~s. small unmanned vehicle/lightweight unmanned aircraftvehicle in community awareness, education, structural inspection land management, search and rescue and real estate operations, and to develop economic platforms for the aforementioned to enhancethe experience ofthose seeking to relocate, rebuild, reevaluate and to find in the metro 

### La Mirada area.



### F. Additional FAA Required Operating Conditions and Limitations

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

1. The UAmustweigh less than 55 pounds (25kg}, including energy source(s) and equipment 2. The UAmay not be flown at a speed exceeding a ground speed of85 knots.
3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported toATC must be in feetAGL. 4. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times.I. Contact Information:

II. The Specific Sections ofTitle 14 ofthe Code of Federal Regulations From Which

### -it~t~;~9t~t~~~~~t\lifl!t,~~I!HrfP!ti*Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).


### Ill The Extent of relief

## Vafi"**''~,flluUifi:*l~aJ-li'¥181W~i~~ijii!Yt~Seeks** and the

•**:,~ ,f~-f.**  <,**;._.3!!.:·~\r)':.:::..-\ ;,,n~,.::f** **'i~\-·f;'o./ ;·,~~x..,__4;** ...**,,':~;';:'i~'.~;.f;**'!·:.,,;,I/3'·.·**:~;vo:' f>)_,;.,~?Jc.\~·:t·~'-i.q,,,"N~~~-~f·::,**  Reason He Seeks Such Relief: I,**!'tD~'t!~~~~§f1'~·~·f'l~l~¥~l1~~~·~~'llsubmit** this application in accorda'rice;ith the

## 'Retci'rm'fi.ct:

..Hf'j:)I. 95.§§331-334, seeking relieffrom any currently applicable FARs operating to prevent me,

### ~-~~~~~-~·~~(li~~~~tr}~.;

### ~tlllttill~~'· contemplated commercial cinematic; academic

# and'otherflight operations within the national airspace system. The ReformAct in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interestto do so. M**WMit'GlftifA~'t!·''IM±f&~''·ilt~llilm~i''"*w•',(d•s** ultra li htwei ht UAS 

### y, '::;:;•,.,:,;.,.\:.;,";;,;;,

..//'"'::.:.'·,,,;**:•·;[;'.{~ :1~**  Ft\**cr:'t\~~iti<~t;t:c;cii;'<i·,,;;,;;',.;~.·V'~JJ;,f;** ' 

### g g meets the definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration ofmy ultra lightweight UAS is expressly contemplated by the Reform Act. Iwould like to operate my ultra lightweight UAS priorto the time period by which the ReformAct requires the FAAto promulgate rules governing such craft. Thereby, providing direct experience and valuable information forformal regulation that can be administered uniformly to all related UAS aerial video and photography. The ReformAct guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS's; Whetherthe UAS will be operated near airports or heavily populated areas; and, Whetherthe UAS will be operated by line ofsight. 112 P.L. 95 

### § 333 (a).10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a current state driver's license. The PIC must also meetthe flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 11. Priorto operations conducted forthe purpose ofmotion picture filming (orsimilar operations}, the PIC must have accumulated and logged, in a mannerconsistent with 14 CFR 

### § 61.51 (b), a minimum of200 flight cycles and 25 hours oftotal time as a UAS rotorcraft pilot and at leastten hours Jogged as a UAS pilotwith a similar UAStype (single blade or multirotor}. Prior documentedflight experience thatwas obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted underthis grant ofexemption to accomplish the required flight cycles and flighttime. During training, proficiency, and experience-building flights, all persons not essential forflight operations are considered non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119. 12. Priorto operations conducted forthe purpose ofmotion picture filming (orsimilar operations), the PIC must have accumulated and logged, in a mannerconsistent with 14 CFR 

### § 61.51 (b), a minimum offive hours as UAS pilot operating the make and model of UAS to be utilized for operations underthe exemption and three take-offs and three landings in the preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency flights can be conducted underthis grant ofexemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience-building, and take-off and landing currency flights, all persons not essential forflight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from non-participants in accordance with 14 CFR 

### § 91. 119.

13. Priorto any flight operations authorized by this grant ofexemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator's manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated atthe sole discretion ofthe operator. A record ofcompletion ofthis qualification process must be documented and made available to theAdministrator upon request.

14. Priorto operations conducted forthe purpose ofmotion picture filming (or similar operations), a flight demonstration, administered by an operator-approved and -qualified pilotThis requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's state driver's license. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. Ifa discrepancy exists between these limitations and any procedure outlined elsewhere in this operations manual, the conditions and limitations herein take precedence and must be followed. 7. Priorto each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, ifutilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any UAS that has undergone maintenance or alterations that affectthe UAS operation
orflight characteristics, e.g. replacement ofa flight critical component, must undergo a functional testflight in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. 9. The operator mustfollow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. At a minimum, the following must be included in the operator's manual:
a. Actuators 

### I Servos
b. Transmission (single rotor)

c. Powerplant (motors)
d. Propellers

e. Electronic speed controller f. Batteries g. Mechanical dynamic components (single rotor)
h. Remote command and control
i. Ground control station (if used) j. Any other components as determined by the operatorbattery power remaining, whichever occurs first.
21. The operator must obtain anAirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting any operations underthis grant of exemption. This COAwill also require the operatorto request a Notice toAirman (NOT AM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. The operator must develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service ofthe UAS. These procedures must be added to the operator's manual. 24. Each UAS operated underthis exemption must comply with all manufacturer Safety
Bulletins.
25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator's manual. 26. The preflight inspection section in the operator's manual must be amended to include the following requirement: The preflight inspection must accountfor all discrepancies, i.e. inoperable components, items, orequipment, not covered in the relevant preflight inspection sections ofthe operator's manual. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. At leastthree days before scheduled filming, the operator ofthe UAS affected by this exemption must submit a written Plan ofActivities to the local FSDO withjurisdiction
overthe area of proposed filming. The 3-day notification may be waived with the
concurrence ofthe FSDO. The plan ofactivities must include at leastthe following:
a. Dates and times for all flights
b. Name and phone number ofthe person responsible forthe UAS filming production underthis grant ofexemption
c. Name and phone number ofthe person responsible forthe on-scene operation ofthe UAS.

### must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed bythe operator, and there are no established practical test standards that support ajurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitionerwill conductthese tests in accordance with the operator's manual.

15. The UAS may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event ofa UAS failure or emergency.

16. Regarding the distance from participating persons, the operator's manual has safety mitigations for authorized and consenting production personnel. At all times, those persons must be essential to the**closed~set**

### film operations. Because these procedures are specificto participating persons, no further FSDO orAviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petitioner's manuals. This is consistentwith the manned aircraft procedures described in FAAOrder 8900.1, V3, C8, S 1 Issue 

### a Certificate ofWaiverforMotion Picture and Television Filming.



### 17. Regarding distance from non-participating persons, the operator must ensure that no persons are allowed within 500 feet ofthe area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if itwould not adversely affect safety and theAdministrator has approved it. For example, an equivalent level ofsafety may be determined by an aviation safety inspector's evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect non-participating persons (observers, the public, news media, etc.) from debris in the event ofan accident. This is also consistent with the same FAAOrder 8900.1, V3, C8, 51. 18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a**pre~determined** 

### location within the security perimeter and land or be recovered in accordance with the operator's manual.

18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a**pre~** 

### determined location within the security perimeter and land or be recovered in accordance with the operator's manual. 19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator's manual. 20. Each UAS operation must be completed within 30 minutes flight time orwith 25%d. Make, model and serial or N-number ofthe UAS to be used

e. Name and certificate number ofthe UAS PIC's involved in thefilming production event f. A statementthatthe operator has obtained permission from property
owners and/or local officials to conductthe filming production event; the list ofthose who gave permission must be made available to the inspector upon request. g. Signature ofexemption-holder or representative
h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/orstate overwhich filming will be conducted and the altitudes essential to accomplish the operation 29. The documents required under 14 CFR § 91.9 and§ 91.203 must be available to the PIC atthe ground control station ofthe UAS any time the aircraft is operating. These documents must be made available to theAdministrator orany law enforcement official upon request. 30. The UAS must remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralightvehicles, parachute activities, parasailing activities, hang gliders, etc.). 31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 32. The UAS cannot be operated by the PIC from any moving device orvehicle.
33. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 34. The UAS may not operate in Class B, C, or D airspacewithoutwritten approval from the FAA. The UAS may not operate within 5 miles ofthe geographic center ofa non-towered airport as denoted on a current FAA-published aeronautical chart unless a letter of agreementwith that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter ofagreement with the airport management must be made availableto theAdministrator upon request. 35. Any 1) incident, 2) accident, or 3) flight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FederalAviationAdministration's (FAA) UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSBWeb site: www.ntsb.gov. Furtherflight operations maynot be conducted until the incident, accident, ortransgression is reviewed byAFS-80 and authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential riskto the public. Granting my,

### !«~IM~!tlll't~J1;~·ff~f:r;~~~~ifif,i:Jfs, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk fl in to and from established airfields. I**.~Wlili~eDialik~l:f:Qat5'AWiii1Jt~t-lt:IP1\IJ?**



### Y 

### g '•·.·;·,;J{(·,,;,•n.w,.; ·.;;:'.·SiF ><',,•,:n·,JX#i· <<·;·;;,;t>;,c:u,,;,•>·\i·O.'•·>n.:·· ••I<·''·" ,.,,,,,,,,,,;,**''''~** have been informally analyzing and recording flight information and will compile safety protocols and the implementation ofa flight operations manual for usage that exceeds currently accepted means and methods for safe flight. Formal collection ofinformation shared with the FAAwill enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of2012. There are no personnel on board my,**~·t\l;J':**

### ~:il:.l'itfil~l:tjlftit•'liMMf.,li}~'s, UAS and therefore the likelihood ofdeath or.se'rious 

# 6adi1}7rnJuryTs'si9niticantl}ta1minisheCi:''My,

## ~!1~,5~1~\:~~~!~,!~~,,~~;!~~~~•~~llfs, operation of my UAS, weighing less than forty (40) pounds and traveling at lowerspeeds within limited areas lowto the ground will provide an equivalent level ofsafety as that achieved under current FARs. Accordingly I,

### ~~~~~~~~~~~~-\'·~~~jMIJJ~respectfully request thatthe FAA grant my exemption request and am willing to cooperate in sharing information to benefitthe FAA, safety of manned aircraft, and the general public at large. Respectfully submitted,



# ..**'.'~!~ttL.·** 

# .**~~Ji,i;,~il~q~~~!l~!,**

### 14~1·~S~I1~-~~~a" 

# ..**t:i~ ca.JVI'r~<Ja;,** **Qaliforni~'·~~J~S**

### 10 AppendixA



### List ofAircraft

2

3



## •**[)~11NSJ;>l!1£E** 

## QNE The operation ofthe DJi INSPIRE ONE system is as follows.


### 1. Build Materials 

### I. Plastic II. Aluminum
2. Motor Configuration I. The DJI INSPIRE ONE flight in a 4 motorquadcoptersetup. ,

3. Payload • The DJI INSPIRE ONE flies it's own light-weight integrated camera. • MaximumAll-up weight- 61bs

4. Maintaining the DJI INSPIRE ONE I. Before each flight: 

### 1. Check all hardware to ensure it is securely tightened. 2. Check thatthe motor is level and locked in place. 

### Pending Pending

3. Check the propellerto ensure it is tight and there are'no visible signs ofcracks, stress,4. Check all wiring to motors, motor controllers, batteries, and flight controllerfor signs of stress orfrays. 5. Check all navigational lighting to ensure it is properlyworking.
II. After 45 hours offlight 1. Remove and check all motors and motor mounts for signs ofwear and tear. Replace as necessary. 2. Remove motor controllers and visually inspect and checkfordamage. Replace as necessary. 3. Remove flight controllers and visually inspect and checkfordamage. Replace as necessary. and/or chips. Replace the propeller ifquestionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Checkfor updates to flight controllerfirmware. Ifavailable, install and perform a minimum of 15 test flights before conducting commercial work.

1. Build Materials I. Plastic II. Aluminum

2. Motor Configuration 

### I. The Phantom 3 uses a 4 motorquadcoptersetup.
3. Payload 

### I. The Phantom 3's own integrated camera. II. MaximumAll-up Weight- 41bs

4. Maintaining the Phantom 3 I. Before each flight: 1. Check all hardware to ensure it is securely tightened. 2. Check that the motor is level and locked in place. 3. Checkthe propellerto ensure it is tight and there are novisible signs ofcracks, stress, 4. Check all wiring to motors, motor controllers, batteries, and flight controllerfor signs ofwear. 5. Check all navigational lighting to ensure it is properlyworking.
II. After45 hours offlight 1. Remove and check all motors and motor mounts for signs ofwear and tear. Replace as necessary. 2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace ifpropeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Checkfor updates to flight controllerfirmware. Ifavailable, install and

### perform a minimum of 15 test flights before conducting commercial work. Appendix C

## e~f~~~~~!i''~~b;~iM~J~t~!~t! The operation ofthe CineChopperX8 multirotor system are as follows (the flight controller operation manual is NOT explained in this manual but can be found inAppendix E, Section 1 ). 1. Build Materials I. Carbon Fiber II. ASS Plastic Ill. Stainless Steel Hardware
2. Motor Configuration I. 

### X8 configuration utilizing 8 motors (KDEDirect 5215-435KV) which is powered by the Herkules Ill motor controller. The motors are configured with 2 motors per arm, one top and one bottom spinning in acounter-rotating direction. We have tested this situation and can confirm itworks as described.
II. In this configuration the CineChopperx8 can handle up to four (4) motors failing and still be able to fly.
3. Payload I. The CineChopperx8 will carry the Freefly Systems MoVI M5, M10, or M15 camera gimbal. II. The cameras thatwill 

### be flown on the CineChopperX8 include, but are not limited to, Canon 5DMKIII, Canon 1D-C, RED Epic, RED Dragon, and Sony FS700. Ill. MaximumAll-up Weight- 341bs
4. Maintaining the CineChopperx8 I. Before each flight: II. After 45 hours offlight
1. Check all hardware to ensure it is securely tightened. 2. Checkthat all motors are level and locked in place. 3. Check all propellers to ensure they are tight and there are no visible signs of cracks, stress, and/or chips. Replace ifany propeller is questionable. 4. Check all wiring to motors, motor controllers, batteries, and flight controllerfor signs ofcuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Check all navigational lighting to ensure it is properly working. 6. Remove and check all motors and motor mounts for signs ofwear and tear. Replace as necessary. 7. Remove motor controllers and visually inspect and checkfor damage. Replace as necessary. 8. Remove flight controllers and visually inspect and checkfor damage. Replace as necessary. Check for updates to flight controllerfirmware. Ifavailable, install and perform a minimum of 15 test flights before conducting commercial work.Appendix D

Personal Protocols/Controls/Flight Manual Protocols and Controls

## ~il9~~~li~~t:~'BJI:r:l~tii;J,tl~i~l8"J~~~!;~~,(~@~i~~!l~fltt~ Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre-flight preparation and during flight. Pre-Flight Protocol:
Check batterieswith voltage meterto insure fully charged and ready for use. Inspect batteries for damage or leakage that may affect proper operation. Inspect propellers for cracks, chips ordamage that may cause sudden loss of propulsion or unmanageable/uncontrolled flight.
Check all GPS and Telemetry connections priorto flight.
Checkweatherforecasts forwind advisory orother conditions that my impactflight.
Consult Sky Vector aeronautical Charts (Skyvector.com)for airport vicinity and flight paths of possible airtraffic.
Contact respective airport to advise ofestimated flight time, estimated flight duration, estimated elevation offlight, and any other pertinent information. Inspectflight area for Vicinity of public safety helipads/heliports Vicinity of medical helipads/heliports Vicinity of light poles vicinity or utility wires Vicinity oftrees flocks ofbirds that may cause interference and potential flight impact Vicinity ofany elevated obstructions that may pose potential flight hazard Vicinity of roadways with moderate to heavy traffic that can distract the public Gatherings that may attract viewers optional point ofcontrol for best visual site of UAS while in flight Emergency landing areas
Takeoffand landing Inspect area for best and safest point oftakeoff and landing Ifin a subdivision or area that is within 150feet ofa residential street, postwarning Sign(s)/stand(s) "AttentionAerial Photography In Progress- Remain Back 150 Feet" Flight Protocol: takeoffand land from same location ( have alternate landing areas in case of emergencies) remain alert to birds, sound oraircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation or distractthe remote control pilot restrict flight tominimal elevation sufficient to acquire desired results remained prepared for emergency landing atall times pay attention to flight time -warning meterfor lowvoltage.
Setvoltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut down propulsion immediately following landing

- priority ofdisconnecting batteries
Postflight:

1. a) Disconnect battery to prevent accidental activation of propulsion system

2. b) Secure UAS in a safe location c) Remove all warning signs from public access areas Emergency or Suspected Hazard:
Immediate land UAS atsafest and closet ground location in the event
Manned aircraft is heard orseen in vicinity offlight There is a public gathering within established safety boundary wanting to observe flight Pilot is being distracted from focusing on flight and safety Sudden change in weather (wind bursts) Sudden increase in vehiculartraffic in vicinity offlight Birds enter into proximity offlight Any sudden unsafe event that can cause collision, distraction or interruption ofcontrol Safetyfor public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. Maintaining a record ofsafe flight for FAA request and for determining future UAS safety protocols is imperative.

Date:

________ _ Location:

_____________________ _ pre-flight Inspection:

o Yes o No Comment:

_____________________________________ _
Elements Proximity to airport: ------------(seeattached map pinpointing approximate location offlight) Airport notified: NoYes

### Date:

_______Time:------
Phone Number:



# ---------------- Contact Name:

_________________ _ Nearest major intersection:

Proximity to medium traffic road:

Proximity to heavily traveled roadway road:

Proximity to congested population:

Approx. TakeoffTime : GMT:
Weather Good Fair Poor Comment : Visibility Good Fair Poor Comment :
Wind Speed _mph_Gusts/MPH_avg/MPH Comment : Approx. Landing Time: GMT: Estimated Elevation Ground level: Safety Concerns: Additional Comments: sea level:Appendix '0'



### Aircraft Manuals
ThisAppendix includes UAS manufacturer's user manuals, maintenance instructions, and illustrated parts catalogs. These manuals may be attached to the docketwhen submitted. Information regarding design, aircraft performance, fail-safe features, operating limitations, normal and emergency procedures, and maintenance and inspection procedures is contained within the manuals and supplemental information documents listed below:

1. DJI Inspire Manual V1.0 2. Inspire 1 Maintenance Manual v1.0 3. Intelligent Flight Battery Safety Guidelines v1.4 4. Inspire 1 Safety Guidelines 5. Phantom 3 Professional Manual V1.0 6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)

For more information orquestions aboutthis manual please contact: