August, 26, 2015 Attn: U. S. DepartmentofTransportation DocketOperations West Building Ground Floor, Room w12-140 1200 NewJerseyAve, SE Washington, DC 20590

RE: Tim Fleming DBA CVT Marketing 18696Autumn Lake Blvd Hudson Fl34667 813-784-7580 

# •

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14OF THE CODE OF FEDERAL REGULAliONS SECTIONS 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) CONCERNING COMMERCIAL OPERATION OF 1- YUNEEK Q-500 4KAND 2 BLADE 350'S THESE 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) EXPERIENCE 30 YEARS IN VIDEO PRODUCTION BUSINESS, 8 YEARS AS A RC OPERA TOR. 10 HOURS TRAINING ON THESE SPECIFIC DRONES. FLIGHT ALTITUDE REQUESTED 100 FEET MAXIMUM PURPOSE OF FLIGHTS: REAL ESTATE SALES, CAR DEALERSHIPS AND VIDEO MARKETING 

### TtMFLEMtNG

TIM FLEMING President TIM FLEMING DBA CVT MARKETING 18696 AUTUMN LAKE BLVD HUDSON, FL 34667 813-784-7580 TIM@CVTMARKETING.COM WEBSITE: CVTMARKETING.COM

1TABLE OF CONTENTS 

### Page GLOSSARY OF ABBREVIATIONS

...................................................................................3

SUMMARY

...........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER.

...................................................4



### BACKGROUND

....................................................................................................................4

BASIS FORPETITION

.........................................................................................................5

NAME AND ADDRESS OF PETITIONER

.........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE ALTEK MEDIA GROUP SEEKS EXEMPTION

............................................................................................................? 

### THE EXTENT OF RELIEF THE ALTEKMEDIA GROUP SEEKS AND THE REASON THE ALTEKMEDIA GROUP SEEKS THE RELIEF

..............................................................1 0 THE REASONS WHY GRANTING THE ALTEKMEDIA GROUP'S REQUEST WOULD BE IN THE PUBLIC INTEREST

............................................................................................12 THE REASONS WHY GRANTING THE EXEMPTION TO THE ALTEKMEDIA GROUP WOULDNOTADVERSELYAFFECT SAFETY

..............................................................14 

### SUMMARY THAT CAN BEPUBLISHED IN THE FEDERAL REGISTER.

..................25

2ANYADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORT THE ALTEKMEDIA GROUP'S REQUEST

..................................................25 CONCLUSION

.....................................................................................................................25 APPENDICES

......................................................................................... 26

AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS Above Ground Level AreaofInterest Air Traffic Control AirTraffic Organization Aerial Vehicle Code ofFederalRegulations Certificate ofAuthorization Federal Aviation Administration Federal AviationRegulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot InCommand FAAModernization andReformAct of2012 (FMRA) Safety Observer Standard OperatingProcedures UnmannedAircraft Unmanned Aircraft System Visual FlightRules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

3

### SUMMARY Tim Fleming DBA CVT Marketing hereafter referred to as CVT Marketing seeks 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)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit CVT Marketing to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes, automotive dealerships and events over certain areas ofthe United States. 

### INTRODUCTION AND INTERESTS OF THE PETITIONER CVT Marketing has for over thirty years provided their clients (which include private sector businesses and non-profits, along with local state and federal agencies) with expertise and knowledge in video and multimedia marketing, advertising, public relations and training using advanced technologies and solutions. CVT Marketing has worked on thousands ofproductions over the past 30 years in all types oflocations with a perfect client and employee safety record. In the pastwe have supplied our clients aerial video and photography using commercial aircraft. Theobjective ofCVT Marketing andourUnmannedAircraft Systems comprised of 1- YUNEEK Q-500 4K AND 2 BLADE 350'S aerial operations is to provide a more affordable, high-quality production system for a variety of governmental, commercial, public, and residential uses, specificallytargeting

• Construction sites before and after • Appraisals • Real-estate marketing • Economic development • Civic landmarks • Special event coverage • Private and governmental training Automotive Dealerships

4My staffhas safely flown small RC electric quad copters recreationally for approximately 5years without incident.

BACKGROUND UnmannedAircraft Systems: CVT Marketing seeks anexemptionfor 1- YUNEEK Q-500 4K AND 2BLADE 350'Sto operate for compensation orhire withintheNAS. YUNEEK Q-500 4Kis

vertical takeoffand landing (VTOL) UnmannedAircraft (UA) witha Ground Control Station (GCS) utilizing electronictablet orsmartphone systems. YUNEEK Q-500 4Kand 2BLADE 350'Shave a maximum gross weight ofapproximately4.8 lb. while having a diagonal dimension of23.2", a maximum speedofapproximately 16.4'fps and a maximum flying height of200'. All UnmannedAircraft are equippedwith four mainrotors; drivenbyLithiumPolymerbattery powered electric motorswithgroundvideo from aerial cameradisplayed on6" monitoron Transmitter. The YUNEEK Q-500 4KAND 2 BLADE 350'S that will be operated by CVT Marketing and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, AircraftRegistration, and marked in accordance with 14 C.P.R. Part 45, Identification andRegistrationMarking.

BASIS FORPETITION Petitioner, CVT Marketing, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.P.R. 

### § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rulesfor Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the Q-500 4K AND 2 BLADE 350'8, UAS inthe 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)(l) 

### & (a)(2), and 91.417(a) 

### & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, CVT Marketing operation ofthe Q-500 4K AND 2 BLADE 350'S UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate inaccordance with 14 C.P.R. Part21, SubpartH. Accordingly, CVT Marketingrequests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only applyto aircraft with an airworthiness certificate. CVT Marketing submitsthatthe requested reliefis proper since an equivalent level ofsafety will be ensured. the CVT Marketing will ·use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed inthe operating documents (i.e., Monthly Maintenance Log, Instruction

5Manual). Furthermore, CVT Marketing will document and maintain all maintenance records the Q-500 4KAND 2BLADE350'S CVT Marketing seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, CVT Marketing submits that they will ensure that the Unmanned Aircraft System is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and The YUNEEK Q-500 4K AND 2 BLADE 350'S Instruction Manuals), and that the aircraft are in a condition for safe flight. CVT Marketing also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the YUNEEK Q-500 UAS will not have a typical barometric altimeter onboard. However, altitude information ofthe YUNEEK Q-500 4K AND 2 BLADE 350'S UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with CVT Marketingoperation ofthe YUNEEK Q-500 4KAND 2 BLADE 350'S UAS within visual line ofsight, at or below 200 feet AGL, will ensure a level ofsafety equivalentto Section91.121. Additionally, CVT Marketing seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel requirementsforflight in VFR conditions. CVT Marketing submits that safety will not be affected by operation of3 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 25 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point oftake off. In accordance with 14 C.F.R. § 11.81, CVT Marketing provides the following information in support ofits petition for exemption:

A. NameAndAddress OfThePetitioner. The name and address ofthe Petitioner and point ofcontact is: Tim Fleming-President Tim Fleming dba CVT Marketing 18696 Autumn Lake Blvd. HudsonFl 34667 813-784-7580 tim@cvtmarketing.com website: cvtmarketing.com

6B. The Specific Sections Of14 C.F.R. From Which CVT Marketing Seeks Exemption. 1. CVT Marketing Seeks Exemption From TheRequirements OfSection 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, inrelevantpart: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers or property for compensation or hire; normay thatperson, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connectionwith anybusiness oremployment if- (1) The flight is only incidental to thatbusiness oremployment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. 2. CVT Marketing Seeks Exemption From The Requirements OfSection 91.7(a). Section 91.7, entitled Civil aircraftairworthiness, subsection (a), states the following: (a) No personmay operate a civil aircraftunless it is in an airworthy condition. 3. CVT Marketing Seeks Exemption From TheRequirements OfSection 91.121. Section 91.121, entitledAltimeter settings, subsection (a), states the following, inpart: (a) Eachperson operating an aircraft shall maintainthe 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 setting of a station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting ofan appropriate available station; or

7(iii) In the· case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

4. CVT Marketing SeeksExemptionFromTheRequirements OfSection91.151(b). Section91.151, entitled

### Fuel requirements for flight in VFR conditions, subsection (b), statesthe following: (b) 

### No person may begin a flight in a rotorcraft under VFR conditions unless (considering windand forecast weather conditions) there is enoughfUel tofly to the firstpoint of intended landing and, assuming normal cruising speed, tofly after that for atleast20minutes. 5. CVT Marketing SeeksExemptionFromTheRequirementOfSection91.405(a). Section 91.405, entitled

### Maintenance required, subsection (a), states the following: Each owneroroperatorofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired asprescribed inpart43 ofthis chapter[.] 6. CVT Marketing SeeksExemptionFromTheRequirements OfSection91.407(a)(l) Section 91.407, entitled 

### Operation after maintenance, preventive maintenance, rebuilding, oralteration, subsection (a)(l), statesthefollowing: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, oralterationunless-- (1) Ithas been approved for return to service by a person authorized under § 43.7 ofthis chapter[.] 7. CVT Marketing Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2). Section91.409, entitled

### Inspections, subsection (a), statesthe following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraftunless, withinthe preceding 12 calendarmonths, ithas had

-- (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved forreturnto service byapersonauthorizedby§ 43.7 ofthis chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part21 ofthis chapter.

88. CVT Marketing Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled 

### Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owneroroperator shallkeep the following records fortheperiods specified inparagraph (b) ofthis 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 ofanaircraft. Therecordsmustinclude-- (i) A description (or reference to data acceptable to the Administrator) ofthe workperformed; and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature, and certificate numberofthepersonapprovingthe aircraft for returnto service. (2) Records containingthefollowing information: (i) The total time in service ofthe airframe, each engine, each propeller, and eachrotor.

(ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul ofall items installed on the aircraft which arerequiredtobeoverhauled ona specifiedtimebasis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under which the aircraft andits appliances are maintained. (v) The current status ofapplicable 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 action, thetime and date whenthe nextaction isrequired.

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

9(b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified inparagraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraft atthe time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for returnto service.

C. The Extent OfRelief CVT Marketing Seeks And The Reason CVT Marketing Seeks The Relief. 1. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing Seeks Relief From Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Privatepilotprivileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation orhire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carrypassengers orproperty for compensation orhire. As set forth more fully below, CVT Marketing submits that an equivalent level ofsafety will be maintained because no PIC will be allowedto operate the Q-500 4KAND 2BLADE 350'8 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate eitherthe Q-500 4KAND 2BLADE 350'8 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, The CVT MARKETING submits that all flights ofthe Q-500 4KAND 2 BLADE 350'8 3 UA8, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to CVT Marketing'sbusiness; and (2) will not carrypassengers orproperty for compensationorhire.

102. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing 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 CVT Marketing Seeks 

### to determine that the Q-500 4K AND 2 BLADE 350'S 

### 3 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., CVT Marketing 

### Aerial Operations Manual, Monthly Maintenance Log, and InstructionManual). The CVT Marketing 

### seeks the requested relief because the 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. 

### Part 21, Subpart H. Therefore, CVT Marketing 

### will ensure that the 3 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing Seeks Relief From Section 91.121. 

### Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe 3UAS, whichutilize abarometric pressure sensor, GPS equipment, and aradio communications 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 concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), CVT Marketing 

### seeks the requested reliefbecause the Q-500 4K AND 2 BLADE 350'S 

### 3 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before eachflight. Considering the limited altitude oftheproposed operations, relieffrom 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 DJI Phantom 3 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information oftheUA on the heads-up display ofthe GCS.

4. Extent OfReliefCVT Marketing Seeks And The Reason The CVT Marketing 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 flights ofthe battery powered 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 25 minutes. The CVT Marketing 

### seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration ofthe battery powered 3 UAS will

11severely constrain the practicality of any aerial video or still photo flight operations that The CVTMarketing proposes to conductpursuantto this Petition. Significantly, as set forth below, the technical specifications of the 3 UAS, the operating documents, and CVT Marketing's proposed operating limitations, ensure that CVT Marketing will safely operate the battery powered 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of25 minutes.

5. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing Seeks Relief From Sections 91.405(a), 91.407(a)(l),91.409(a)(l) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, CVT Marketing requests relief from these Sections because the Q-500 4K AND 2 BLADE 350'S 3 UAS do not require airworthiness certificates. As set forth more fully below, the 3 UAS meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, CVT Marketing will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the CVT Marketing Aerial Operations Manual, Monthly Maintenance Log, and 3 Instruction Manual). Furthermore, CVT Marketing will document and maintain all maintenance records for the Q-500 4K AND 2 BLADE350'S 3UAS.

D. The Reasons Why Granting CVT Marketing Request Would Be In The Public Interest; ThatIs,How ItWouldBenefitThePublicAs A Whole. Granting the present Petition will further the public interest by allowing CVT Marketing to safely, efficiently, and economically perform aerial video and photography ofconstruction sites, real estate, events and civic landscape over certain areas ofthe United States. Additionally, use of the 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofCVT Marketing's proposed operation ofthe 3UAS will berealized without implicating any privacy issues.

1. ThePublicWillBenefitFromDecreased Congestion OfTheNAS. The Q-500 4KAND 2 BLADE350'S 3UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofQ-500 4K AND 2 BLADE 350'S 3 UAS would reduce the amount ofmanned

12

### aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property inthe air and onthe ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Q-500 4K AND 2 BLADE 350'S 3 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landingphases offlight operations.

2. ThePublicWill BenefitFromThe SafetyAndEfficiency OfThe3 UAS. Conducting aerial acquisitions with the 3 UAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the 3 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The Q-500 4K AND 2 BLADE 350'S 3 UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelled bybatterypowered electricmotors, ratherthan an internal combustion engine. Byusing the 3 UAS to perform aerial acquisitions, the substantial riskto life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the 3 UAS (weighing approximately 4.8 pounds at their maximum gross weight with diagonal dimension of23.2 inches, and with no fuel onboard), has less physical potential for collateral damage to life and property onthe ground, and inthe air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 3. PerformingAerialVideo andPhotographyOperationsWith The3 UAS WillBenefitThe Economy. In addition to being safe and efficient, the 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe 3 UAS will allow United States based companies, like CVT Marketing, 

### to remain competitive 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 3 UAS 

### is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility withoutthe high operational cost ofatraditional manned aircraft.

13By operating the 3 UAS, companies such as CVT Marketing, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe YUNEEK Q-500 4K AND 2 BLADE 350'S 3 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 competitive bothinthe United States and abroad.

4. ThereAreNo PrivacyIssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, CVT Marketing's proposed operation of the 3 UAS will not implicate any privacy issues. Specifically, the 3 UAS will be operated only in compliancewith operating documents (i.e., CVT Marketing Aerial Operations Manual, Monthly Maintenance Log, and 3 Instruction Manuals) whichrequires 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.P.R.§ 91.119. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level OfSafety At Least Equal To That Provided ByTheRule FromWhich CVT Marketing Seeks Exemption. 1. Reasons Why The YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS Meet The Conditions OfTheFAAModernization andReformAct of2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, CVT Marketing's operation of the 3 UAS meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.P.R. Part21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazardto users oftheNAS orthe public, or otherwise pose a threatto national security. Specifically, FMRA Section 333 states the following, inpart: (a) In General.--Notwithstanding any other requirement of this subtitle, andnot later than 180 days after the date of enactment of thisAct, the Secretary of Transportation shall determine 

### ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion of theplan and rulemaking required by section 332 of thisActorthe guidance requiredbysection 334 of thisAct. (b) Assessment ofUnmannedAircraft Systems.--In making the determination under subsection (a), the Secretaryshalldetermine, ata minimum-- (1) which types of unmannedaircraft systems, 

### if any, as a result of their size, weight, speed, operational capability, proximity to airports andpopulated
14

### areas, andoperation within visual line of sightdo notcreate a hazardto users ofthe national airspace system or the public orpose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is requiredfor the operation ofunmanned aircraft systems identified underparagraph (1). 

### (c) Requirementsfor Safe Operation.--Ifthe Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirementsfor the safe operation ofsuch aircraftsystems in the nationalairspace system. In seeking this exemption, CVT Marketing submits that 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe 3 UAS; (b) the pilotcertificationrequirement; and (c) the specific operating limitations.



### a. The Specifications OfThe3 UAS DemonstrateIts Safe Characteristics. The 3 UAS's do not create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. 

### i. Technical Specifications OfTheDJIPhantom 3 UAS. The technical specifications ofthe YUNEEK Q-500 4K AND 2 BLADE 350'S UAS are set forth bythe YUNEEK Q-5004KAND 2 BLADE 350'SUserManual, attachedhereto as Appendix A. ii.

### TheYUNEEK Q-500 4KAND 2BLADE 350'S 

### UAS GlobalPositioningModes EnableThe UAS To RemainWithin A Defined OperationalArea. The YUNEEK Q-500 4K AND 2 BLADE 350'S UAS may be operated inboth manual and global positioning flight modes. iii.

### TheYUNEEK Q-5004KAND 2BLADE 350'S

### 3 UAS AreDesigned ForAutomatic ReturnTo HomePoint OrHoverInTheEvent OfLoss OfTheControlLinkOr Navigation. When the Control Link is lost, the YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS does not reacquire control link data from the GCS, the UAS will assume that the Control Linkis lost andthe will returnto the home position (i.e., failsafe mode) via GPS, and will descendto thetakeoffpositionand shutdown. 

### iv. TheYUNEEK Q-5004KAND 2BLADE 350'S

### And Its Operation. A complete description ofthe operation and specifications ofthe YUNEEK Q-500 4K AND 2 BLADE 350'S GCS and flight control software is provided.

15b. FlightOperations OfYUNEEKQ-500 4KAND 2BLADE350'S 3 UAS IsLimitedToThe Line OfSightOfA CertificatedPilotin CommandWithA Safety Observer. The CVT MARKETING video production staff will be the only persons to act as a pilot in command (PIC) ofthe 3 UAS. Additionally, a safety observer will assist him at all times during flight time.

c. Flights Of3 UAS WillBe ConductedPursuantTo Specific OperatingLimitations. In seekingthis exemption, The CVT MARKETING proposes to commercially operate 3 UAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations. 1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: 3 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a newpetition or apetitionto amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography. 3. The UAS maynot be flown at an indicated airspeed exceeding 20 knots. 4. The UA mustbe operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be infeetAGL. 5. The UAS must be operated within visual line of sight (VLOS) ofthe 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. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. · 7. All operations must utilize a safety observer (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 flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must notperform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the cameraorother instruments.

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### 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 conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator 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 revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Priorto each flight the PIC must inspectthe UAS to ensure that itis in a condition for safe flight. Ifthe 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. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraftrecords.

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 test flight. The PIC who conducts the functional test flight must make an entry inthe aircraftrecords. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature ofthe authorizedpersonreturning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discoveredbetween inspections.

1717. The PIC must possess at least a private pilot certificate and at least a currentthirdclass 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 withhowthe UAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 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 exemption. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAwith appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. 

### § 1.1. 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 ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management 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 uponrequest. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhenvisibility is less than 3 statute miles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance withthe operating documents. 23. The PIC must abortthe flight inthe event ofunpredicted obstacles or emergencies in accordance withthe operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and landthe UA with 25%batterypowerremaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations underthe grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

18

### operation. All operations shall be conducted inaccordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponderrequirements. 26. All aircraft operated inaccordance withthe exemptionmustbe identifiedby 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 radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate 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 Control Station ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official uponrequest. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may notbe operatedbythe PIC from any moving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential 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 ofan 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 ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that it does notpresent anundue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do notpresent an undue hazard to thosepersons per §91.119(a). 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller 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 operation that transgresses the lateral or vertical boundaries ofthe operational area as defmed by the applicable COA must be reported

19to 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 onthe NTSB Web site: www.ntsb.gov.



### 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. CVT MARKETING submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering CVT MARKETING's proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the 3 UAS, CVT MARKETING submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for CVT MARKETING's specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances 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, 11158, 11159, 11160, 11161). CVT MARKETING will not allow any PIC to operate the Q-500 4KAND 2 BLADE 350'S 3UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 3 UAS training and currencyrequirements, thatthe PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC musthave accumulated and logged, in a mannerconsistentwith 14 C.F.R. 

### § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operatingthe same make and model ofUASto be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currencypurposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during CVT MARKETING's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:



### 20In 

### Exemption No. 11062, the FAA required that prior to conducting operations for the purpose ofmotionpicture filming (or similar operations), the PIC musthave accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 

### 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hourrequirements to be inclusive rather than additive; i.e. 5hours make and model time may be included in the 10 hours ofmulti-rotortime and the 10 hours may be included in the total 25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in ExemptionNo. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplishthe required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

ExemptionNo. 11138 atpage 15. Accordingly, CVT MARKETING will ensure safe operations bynot allowing any PIC to operate the 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. 

### The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, CVT MARKETING will ensure that the Q-500 4K AND 2 BLADE 350'S 3 

### UAS are in an airworthy conditionbased uponthe UAS's compliance with its operating documents and as stated inthe conditions and limitationsherein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances 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).

21

### 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because the altitude information ofthe Q-500 4KAND 2 BLADE 350'S 3 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 altitude. This altitude information, combined with CVT MARKETING's operation ofthe Q-500 4K AND 2 BLADE 350'S 3 UAS within visual line ofsight, at or below 500 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established bythe UAS at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, 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).



### 5. Reasons Why An Exemption From The Requirements OfSection 91.151(b) Would Not Adversely Affect Safety. A grant ofthis 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 specifications ofthe Q-500 4K AND 2 BLADE 350'S 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, CVT MARKETING will ensure that it will safely operate the battery powered Q-500 4KAND 2 BLADE 350'8 3 UAS during daylighthours in VFR conditions, with enoughbatterypowerto fly for a total duration of25 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe 3 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section91.151(b). Furthermore, safety will be ensured as the Q-500 4KAND 2 BLADE 350'S 3 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. Atthe critically lowbattery level, the Q-500 4KAND 2 BLADE 350'8 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.



### 228811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,11138,11150,11153,11156,11157, 11158,11159,11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, CVT MARKETING submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because CVT MARKETING will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., CVTMARKETING Aerial Operations Manual, Monthly Maintenance Log, Instruction Manual). Furthermore, CVT MARKETING will document and maintain all maintenance records for the Q-500 4KAND 2 BLADE350'S 3 UAS. Since the Q-500 4KAND 2 BLADE 350'S 3 UAS will be inspected as prescribed by the operating documents, CVT MARKETING will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe Q-500 4KAND 2 BLADE350'S UserManuals are attachedhereto as Appendix A andB; Likewise, the exemption sought will not adversely affect safety because CVT MARKETING will use trained technicians to performmaintenance, alterations orpreventive maintenance onthe UAS usingthe methods, techniques, andpracticesprescribedbythe operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Q-500 4K AND 2 BLADE 350'S 3 UAS will beperformed bytrained technicians. Maintenance will be documented andmaintainedutilizing the monthlymaintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. In consideration of CVT MARKETING's proposed operating limitations, the operating documents, and the technical aspects ofthe 3 UAS, CVT MARKETING submits that safety will not be adversely affected by granting exemption from 14 C.P.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 circumstances 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). 7. TheFAAMayPrescribeAny OtherConditionsForSafe Operation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.P.R. § 21.16 entitled Special Conditions, CVT MARKETING requests that the FAA

23prescribe special conditions for the intended operation ofthe DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalentto that established by 14 C.F.R. Part 21, SubpartH, 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)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwisepose a threatto national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that mustbe established for the safe operation ofthe UAS inthe NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation ofthe 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel orunusual design features ofthe aircraft. Section21.16, entitled Special Conditions, states the following: If the FAA fmds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA fmds necessary to establish a level ofsafety equivalentto that establishedinthe 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 Leading Edge's intended operation ofthe DJI Phantom 3 UAS, which contain such 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 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The Rules FromWhich CVTMARKETING Seeks Exemption:



### The CVT MARKETING seeks exemptionfrom the requirements of14 C.F.R Sections 61.113(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and91.417(a) & (b). A BriefDescription OfTheNature OfTheExemption CVTMARKETING Seeks:

24This exemption willpermit CVTMARKETING to commercially operate an Unmanned Aircraft System (UAS)for thepurpose of conducting aerial video andphotography over certain areas of the UnitedStates.

• Any Additional Information, Views, Or Arguments Available To Support CVT MARKETING's Request.

This Petitionis made pursuantto the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, CVT MARKETING's request for exemption may be grantedpursuantto the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for suchUAS to operate without airworthiness certification. As discussed in detail above, CVT MARKETING will operate the Q-500 4K AND 2 BLADE 350'S 3 UAS safely inthe NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threatto national security. CONCLUSION As set forth herein, CVT MARKETING seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), whichwill permit safe operation ofthe Q-500 4K AND 2 BLADE 350'S 3 UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests ofthe public, by allowing CVT MARKETING to safely, efficiently, and economically operatethe Q-500 4KAND 2 BLADE 350'S 3UAS commercially withintheNAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, CVT MARKETING respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 UAS commercially for the purpose ofconducting aerial video and photography over certain areas of the United States. Dated: August 23, 2015 Respectfully submitted,

. 

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Appendices:

A- Linkto Q-500 4KAND 2 BLADE350'SClickonlinkbelow Yuneee Q500 4k-manual: http://yuneec.com/supportldownload/manuals/q500

_4k _user_ manual.pdf Blade350Manual: http://www.horizonhobby.com/pdf/BLH8100-Manual-EN.pdf



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