### November 18,2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition ofDronemation for an Exemption Pnrsuant to Section 333 oftheFAA Modernization and Reform Act of2012 Director: Flight Standards Service: Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 ("Reform Act") and 14 C.P.R. Part 11, Dronemation hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified belowto allowcommercial operation ofsmall unmanned aerial vehicles (i.e., 

### "small unmanned aircraft" or "UAS") for the pnrpose ofconducting aerial photography, videography, mapping and inspections for residential and commercial real property for the real estate industry as well as infrastructnre inspection for municipalities. This petitionfor exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying Dronemation documents; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as "Documents & 

### Manuals") 3. User Guide and; 4. FlightManual 1 

### (Collectively 3 and 4 are referred to as "Manufactnrer's Manuals") Dronemation submits these supporting materials as confidential doctnnents pursuantto 14 C.P.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary informationthat Dronemationhas not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom oflnformation Act, 5 U.S.C. § 552 et. seq. 

### NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIAL AND SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER.

1• The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation November 18,2015 Page2 Foryour convenience, this Petition is organized as follows: 

### I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Videography, Photography,mapping and Inspection 

### III. Relevant Statutory Authority IV. Dronemation's Proposed UAS Operations Meet the Requirements ofSection 333 Ofthe Reform Act A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions SetForth inthe Operations Manuals 

### V. Regulations From Which Exemption is Requested A. 14 C.F.R. Part21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and IdentificationRequirements D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. 

### § 61.3, 14 C.F.R. 

### § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. 

### § 91.7(a): Civil AircraftAirworthiness G. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft FlightManual inthe Aircraft and 14 C.F.R. 

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

### § 91.103: PreflightAction I. 14 C.F.R. § 91.109(a): FlightInstruction J. 14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes K. 14 C.F.R. 

### § 91.121: Altimeter Settings L. 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight inVFR Conditions 

### Vl. Drug and Alcohol Program VII. Public Interest VIII. Privacy IX. Federal Register Summary X. Conclusion

### U.S Department ofTransportation November 18, 2015 Page 3 

### I. DESCRIPTION OF PETITIONER Dronemation is based in Corona, CA working in aerial photography, videography, mapping and inspection services. The Company specializes in, and will continue to focus on thephotography, videography and inspection ofreal property for the industrial and commercial real estate industry as well as infrastructure inspectionfor municipalities. The Company's Principal and ChiefPilot Jasmine Faqihhas been flying UA V Quadcopters as a hobby for more than one year without incident, logging hundreds ofhours flying. Upon the grant ofthe 333 Exemption the Company's business will specialize in photography, videography and inspection ofreal property and infrastructure inspection. Dronemation's staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot incommand ("PIC") in addition to any other needed on site assistance. All ofthe equipment ownedby Dronemation is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. Dronemation's goal is to advise the perspective client that Dronemation is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. Dronemation seeks an exemption to allow for photography, videography, inspection and other related media products. The contactinformation for Petitioner is as follows: Jasmine Faqih Dronemation 22295 Jessamine Way Corona, CA 92883 Phone: 951.317.3706: Email:jazzyf2293@aol.com 

### II. DESCRIPTION OF PROPOSED OPERATION Dronemation seeks an exemption pursuantto Section 333 ofthe Reform Act to operate the DJI 

### Phantom 3 Pro (referred to DM-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur undertightly controlled conditions onprivate property or approved location where Dronemationhas received verifiable permissionto operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance with the conditions and limitations ofthis Petition for Exemption and Dronemation's Operations Manuals. As detailed in Dronemation's Operations Manuals, all UAS operations will be limited to daytime VFRconditions, within visual line-of-sight ("VLOS") ofthe operator, inuncontrolled airspace, and will occur at least 5 mn away from an airport reference point. Moreover, Dronemation's Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. 

### A. Aerial Videography, Photography, Cinematography and InspectionU.S Department ofTransportation November 18,2015 Page4

Dronemation seeks to use small DM-UAS for the purpose ofconducting aerial photography, videography and inspection for the real estate industry as well as infrastructure inspection for municipalities. Dronemation has purposefully tailored its operations to meetthe requirements establishedby the FAAinprior grants ofexemption authorizing commercial use ofUAS inthe real estate industry, including:


### • • • • • Trudeau, Realtor® (ExemptionNo. 11138) Alon Sicherman (Exemption No. 11728) SokolerMedly (ExemptionNo. 11341) Raven Executive (ExemptionNo. 12639) Airshark (ExemptionNo. 11651) All UAS photography, videography and inspection operations will occur onprivate property or approved locationin a controlled area away from spectators and persons not involved in the recording process. In addition, the filming will be conductedbetween dawn and duskto ensure maximum safety for the public :md those involved in the manipulation and operation ofthe UAS; VFRconditions, at altitudes below 400' above ground level ("AGL"). As set forth below, Dronemation's operationsprovide an equivalent level ofsafety which is superiorto performing the same workusing conventional fixed-wing aircraft orhelicopters. Small UAS video production is also saferthan traditional manned aircraft performing the same function. Videographer-inspectors also frequently needto climb rooftops, trees, ladders or otherwise perform elevated work, which exposes themto the risk ofdangerous falls, electrocution or other workrelated injuries. In addition, depending on the nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk ofexposure to hazardous conditions. The use ofDM-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most other types ofinspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in lowlevel operations presentrisks associated with vehicles weighing tens ofthousands ofpounds (including payload) and carrying large amounts offuel which inherently presents significant fire hazards as well as exposureto other chemical contan1inates. 

### Itis importantto note the use of small UAS in this areawill not only be safer and more cost effective to the perspective user or purchaser ofthe service, but the quality and expanse ofacquired information will be far more robust giventhe low cost associated with its acquisition and otherpotential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greaterprecision and duration at a very low cost. Small UASs will also be capable ofaccessing and inspecting areas thatwould otherwise be inaccessible orhighly dangerous using conventional aircraft or other inspection methods. 

### III. RELEVANT STATUTORY AUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) ofthe

### U.S Department ofTransportation November 18,2015 Page 5 FAA Modernization and Reform Act of2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the.integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 333 ofthe Reform Act, the FAA Administrator is to permit unmmmed aircraft systems to operate inthe National Airspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS within the visual line ofsight ofthe operator. Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(J) (defining the authority ofthe Administrator); 49 U.S.C. § 44701(J) (permitting exemptions from§§ 44701(a), (b) and §§ 44702-44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (I) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level ofsafety at least equal to the existing rules). See 14 C.F.R. 

### § 11.81 (petitions for exemption). IV. DRONEMATION'S PROPOSED DM-UAS OPERATIONSMEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT The small DM-UAS operationsproposedby Dronemation as noted above in this Petition for Exemption quality for expedited approval pursuantto Section 333 ofthe Reform Act as each of the statutory criteria and relevant factors are satisfied. A. Approval is WarrantedBased on the UAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The DM-UAS utilized by Dronemationhas been approved for use inprior Section 333 Grants ofExemption from the FAA.2



### • The DM-UAS weighs less than 55 pounds, includingpayload

• The DM-UAS will notbe flown at a ground speed in excess of50 knots. The exemptionholder may use either groundspeed or calibrated airspeed to determine compliance with the 50 knot speedrestriction. • Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio

2 See e.g., Grant ofExemption to Trudeau, Realtor® (Exemption No. 11138); Grant ofExemption to Alon Sicherman (Exemption No. 11728); Grant ofExemption to Sokoler Medly (Exemption No. 11341).

### U.S Department ofTranspmiation November 18,2015 Page 6 altimeter, or any combinationthereof. This information will be transmitted to the pilot viatelemetric data feed.

• The DM-UAS will have systemrednndancies and independent fnnctionality to ensurethe overall safety and predictability ofthe system. Ifconnection to the remote control or ground control station is lost, failsafe systems will permitthe UASs to retumto apredetermined location and safely land without injmy or damage.

• The radio frequencies used for operations and control ofthe DM-UAS comply with the Federal Commnnications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the DMUAS is 2.4 GHz frequency bands. Ifthe same operations were conductedusing a helicopter, the aircraft's take-offweight would likely exceed 6,000 ponnds depending on payload. The difference in weightbetweenthe DMUAS and a helicopter significantly reduces the potential harmto the participating and nonparticipating individuals and/or smroundingproperty in the event ofan unintended accident or incident. In addition, the risk to the onboardpilot and camera operator is eliminated. B. Approval is Warranted Based on the Operational Restrictions Set Forth in Dronemation's Operations Manuals Dronemation's Operations Manuals and the Manufactmer's Manual for the selectedDM-UAS will contain all the procedures and limitations necessary to safely and successfully performthe operations specified in this Petition for Exemption. To assist the FAA inmaking a safety assessment ofDronemation'sproposed operations, below is a summary ofoperational limitations and conditions that Dronemation will adhere to, and which will ensme an equivalent or higher level ofsafety to operations conducted under currentregulatory guidelines: 1. The DM-UAS weighs less than 55 ponnds, withpayload. 2. All operations shall be conducted over private or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight prior to operation. 3. All UASs operated under the Grant ofExemption will be identifiedby serial number, registered in accordance with 14 CFRpart47, and have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings will be as large as practicable. 4. Minimum crew for eachflight operation will consist ofapilot, who will be Pilot-in Command ("PIC") ofthe DM-UAS, and one or more Visual Observers ("Observer") as necessary to safely conductthe mission. 5. PICs shall possess either a private, recreational, or sport pilot certificate. The PIC must also hold a cmrent FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, aU.S Department ofTransportation November 18,2015 · Page 7 possession, orthe Federal government. The PIC will also meetthe flight review requirements specified in 14 C.F.R 61.56 in an aircraft in whichthe PIC is rated on his or herpilot certificate. 6. The DM-UAS shall be operated within VLOS ofthe PIC and Observer at all times. The PIC must use human visionunaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issuedmedical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging or texting will not be permitted during flight operations. 9. The additional requirements identified inthe Grant ofExemption shall be added to the Dronemation's Operations Manuals. The Operations Manuals will be maintained and made available tothe Administrator uponrequest. Ifa discrepancy exists between the conditions and limitations inthe Grant ofExemption and Dronemation's Operations Manuals, the conditions and limitations inthe Grant ofExemption shall take precedence and must be followed. Otherwise, Dronemation shall follow the procedures outlined intheir Operations Manuals. I0. Dronemationmay update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to the Administratorupon request. Dronemation will also present anupdated and revised Operations Manuals ifit petitions for extension or amendment to its Grant ofExemption. Ifan update or revision would affect the basis upon which the FAA grants the exemption, Dronemation will seek an amendmentto its Grant ofExemption. Dronemation will contactthe FAA's UAS Integration Office (AFS-80) ifquestions arise regarding updates orrevisions to the operating documents. 11. Dronemation Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the DM-UAS is operating. 12. The PIC is prohibited from beginning a DM-UAS flight unless (considering wind and forecast weather conditions) there is enoughpower to fly to the first intendedpoint of landing, and assnming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximum total flight time for each operational flight using the DM-UAS will be limited to 40 minutes orthe amount oftime the UAS can be flown and still maintain a reserve battery power ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enter navigable controlled airspace withouttimely prior written authorization and approval from the FAA. Inthe eventthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet abovethe highest point onthe structure, and no more than 50 feet horizontally from the structure.U.S Department ofTransportation November 18, 2015 Page 8 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons otherthanthe PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protectnonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure thatnonparticipatingpersons remain under such protection. Ifa situation arises where nonparticipatingpersons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has grantedpermission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does notpresent an undue hazard, and;

c. Operations nearer to the PIC, VO, operatortrainees or essential persons do not present anundue hazard to those persons per 

### § 91.119(a). 16. The DM-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 17. The DM-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chartunless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the FAA. The letter ofagreement with the airport managementwill be made available to the Administrator upon request. 18. Prior to each flight the PIC shall inspectthe DM-UAS to confirmthat it is in a condition safe for flight. The pre-flight inspection will accotmt for all discrepancies, e.g. inoperable components, items, or equipment, not already covered inthe relevant sections ofthe operating documents as well as equipment updates. The PIC shall not operate any DM-UAS ifthe inspection reveals a conditionthat affects the safe operation ofthe DM-UAS until the necessary maintenance has been performed and the DM-UAS is found to be in a conditionfor safe flight. The ground control station shall be included in the preflight inspection. All maintenance and alternations mustbe properly documented in the UAS'srecords as required by Dronemation's Operations Manuals. 19. Dronemation will timely carry out its maintenance, inspections, and record keeping requirements in accordance withthe Operations Manuals. Maintenance, inspection, and alterations will be fully noted in the DM-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized personreturning the DM-UAS to service. 20. Any DM-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component) musttimely undergo a functional test flight in accordance withDronemation's Operations Manuals. The PIC who conducts the functional test flight must make anU.S Department ofTransportation November 18,2015 Page 9 entry inthe UAS aircraftrecords ofthe flight. The requirements andprocedures for a functional test flight andDM-UAS record entry shall be included in the Dronemation's Operations Manuals. 21. The DM-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates. 22. Priorto the operation, a MissionPacketwill be created in accordance withthe requirements onDronemation's Operations Manuals. 23. Dronemationwill obtain an AirTraffic Organization ("ATO") issued Certificate of Waiver or Authorization, otherwise !mown as a COA, priorto conducting any operations under this Grant ofExemption. A NOT AM will be issued as required by the CO 

### A. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level andpotential transponderrequirements. 24. All requiredpermissions andpermits will be obtained from territorial, state, connty or cityjurisdictions, including local lawenforcement, fire or other appropriate governmental agencies. 25. Ifthe DM-UAS loses communication withthe PIC, it will have the capability to safely return to a pre-determined location withinthe operational area and land safely. 26. Contingency plans will beinplace to safely terminate flight ifthere is a loss of communication betweenthe PIC andthe Observer. 27. The DM-UAS will have the capability to safely abort flight inthe case ofunpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued within the United States. 29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least I0 hours logged as a UAS pilotwith a similarDM-UAS type platform. This requirement canbe achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a marmer consistentwith 14 CFR 

### § 61.5l(b), a minimtml ofhours pursuantto 54 CFR §61.5l(b) as UAS pilot operating the make and model ofDM-UAS to be utilized for operations under the exemption and three take-offs and tln·ee landing in the preceding 90 days. 31. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules (''SVFR") shall notbe conducted.U.S Department ofTransportation November 18,2015 Page 10 32. The DM-UAS shall remain clear and yield the right ofway to all other mam1ed operations and activities at all times (including, butnot limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. DM-UAS Operations under InstrumentFlight Rules, at night, or beyond VLOS are prohibited. 34. The UAS will not be operated from an elevatedplatform unless designed and engineered specifically for suchpurposes andbe in compliance withthe general restrictions imposed by the applicable regulations. Additionally no PIC will provide any film-flight operations while inmotion from atop any elevatedplatformvehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe DM-UAS will comply with the Federal Communications Conunission (FCC) or other appropriate government oversight agency requirements. V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal AviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 40101 ofthe Act, including UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest.3 Dronemation seeks an exemption from several interrelated provisions ofTitle 14 ofthe Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconductingthe requested operations using DM-UAS platforms noted above. Listedbelow are: (I)the specific sections of 14 C.F.R for which exemption is sought, and (2) the operatingprocedures and safeguards that Petitionerhas established whichwill ensure a level ofsafety betterthan or equal to the rules from which exemption is sought.4 UNMANNEDAIRCRAFT SYSTEM 

### A. 14 C.P.R. Part21, Subpart H- Airworthiness Certificates and 14 C.P.R. §91.203(a)(l) The FAA has stated that no exemptionis needed from this section ifa finding is made under the Reform Actthat the UAS selectedprovides an equivalent level ofsafety when comparedto aircraft normally used for the same application. These criteria are met and inpoint offact exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines that there 3 49 U.S.C. §44701(f) (authorizing the grant ofexemptions from requirements ofregulations prescribed pursuant to Sections 4470l(a) and (b) and Sections 44702- 44716). 4 14 C.F.R § 11.8l(e), which requires a petition for exemption to include: 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 by the rule from which you seek exemption.

5 See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-20 14-0352 at pgs. 13-14, 22).U.S Department ofTransportation November 18,2015 Page 11

are some characteristics ofthe chosenUAS that fail to meetthe requirements ofthe Reform Act, an exemptionis requested. 

### EquivalentLevelof Safety Dronemation's use ofthe DM-UAS is safe when taking into account its size, weight, speed, and operational capability. As setforth inthe description ofproposed operations 

### in Section IV(A), the DM-UAS weighs less than 55 pounds, including payload and will notbe flown at a ground speed in excess of50 knots. The DM-UAS is also equipped with safety features which will allow Petitionerto operate the DM-UAS safely after experiencing certain in-flight contingencies or failures as noted below. 6 7 Additionally, the DM-UAS carries neitherpilots norpassengers, carries no explosive materials or flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in Dronemation's Operations Manuals. Operations conducted underthis exemption will be closely controlled and monitored by the PIC operator and will be conducted in compliance with localpublic safety requirements, to provide security for the area ofoperation. Dronemationwill also provide the FAA with advance notice of all operations viaNOTAMs as required by the applicable COA. In all cases, operation ofthe DM-UAS under the proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operating withan airworthiness certificate. Lastly, the DM-UASs do not need a means to communicate with other aircraft or ATC, becausethose capabilities will be solely possessed by the PIC and Observer, who are not onboardthe DM-UAS. 8 In addition, no sense-and-avoid

6 See e.g., Grant ofExemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI SIOOO] has the capability to operate safely after experiencing certain in-flight

**con~ingencies** or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing asimilar operation."

7 See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The DM-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. TheDM-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the VAS has built-in intelligent fault handling which allows the DM-UAS to detect a system fault while in the air and automatically fly back to its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set wind thresholds; and low battery levels." All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight termination link- to prevent a 'fly away' or other potentially dangerous situation- is available to the operator."

8 See Grant ofExemption No. II062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).U.S Department ofTransportation November 18,2015 Page 12 technology is necessary for the DM-UASs because they will be operated at all times in VFR conditions and within VLOS ofthe PIC and Operator? 

### B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the proceduralrequirements for airworthiness certification of normal category rotorcraft. To the extentthat Dronemation's small DM-UAS would otherwise require certificationunder Part27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. R. Part 21, Subpart H, supra. 

### C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Dronemation seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. 

### § 91.9(c), Civil Aircraft FlightManual, Marking and Placard requirements, provides that: No personmay operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Prut 45 ofthis chapter.

• 14 C.F.R. 

### § 45.23(b), Markings ofthe Aircraft, states: Whenmarks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operatormust also display onthat aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable.

• 14 C.F.R. 

### § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display onthatrotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, or tail the marks requiredby 

### § 45.23. In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warrantedprovided thatthe aircraft "have identification (N-Number) markings in accordance with 14 C.F.RPrut 45, Subprut C ifthe markings are as large as practicable." 10

9 •Id
10 FAA DocketNo. FAA-2014-0352.U.S Department ofTransportation November 18, 2015 Page 13 

### EquivalentLevelof Safety All DM-UAS flown by Dronemation will bearN-munbermarkings that are as large as practicable in accordance with 14 C.P.R. Part 45, Subpart C. 11 

### D. 14 C.F.R. 

### § 

### 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 

### 91.417(a) and (b): 

### MaintenanceInspections Dronemation seeks an exemption from the maintenance inspectionrequirements contained in 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards inreference to 14 C.F.R. Part43. See, e.g., 14 C.P.R. § 91.405(a) (statingthat each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpartE ofthfs part and shall between required inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). 

### An exemptionfrom these regulations is neededbecause Part43 andthese sections onlyapply to aircrqftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption will nothave. (Emphasis added) 

### EquivalentLevelof Safety 

### An equivalent level ofsafety will be achieved or exceededbecause maintenance and inspections will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Dronemation's Operations Manuals, the PIC will conduct a pre-flightinspection ofthe DM-UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe DMUASs and no flights will occur imless, and until, all flight critical components ofthe DM-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by Dronemation's Operations Manuals, the PIC who conducts the functional test flight will make an entry inthe DM-UAS aircraftrecords ofthe flight. Dronemation's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station,hazard accessories, and spare parts. Further, Dronemation's Operations Manuals also includeprocedures to document and maintain a record ofthe DM-UAS's maintenance, preventativemaintenance, alterations, status ofreplacement /overhaul componentparts, and the total time in service ofthe DM-UAS used under this Grant ofExemption. As a whole, the maintenance and inspectionprocedures required in Dronemation's Operations Manuals ensure that an equivalent orhigher level ofsafety will be achieved.

11 See, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Department ofTransportation November 18, 2015 Page 14



### PILOT-IN-COMMAND OFTHE UAS E. 14 C.F.R. 

### § 61.113: PrivatePilot Privileges andLimitations Dronemation seeks exemption from 14 CFR 

### § 61.113, whichrestricts private pilot certificate holders from flying aircraftfor compensation or hire, and would also require a second class medical certificate. The'purpose ofPart 61 is to ensure thatthe skill and competency ofany PIC matches the airspace inwhich the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. In this case, while the DM-UAS will be operated as part ofa commercial operation, they carry neither passengers nor cargo. Inthe Grant ofExemptionto Astraeus Aerial, the FAA determined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did notwarrant the additional cost and restrictions attendant withrequiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilotwould not lead to any additional safety benefits when UAS operations are involved. 

### EquivalentLevelof Safety The restrictions Dronemationhas placed onits DM-UAS operations meet or exceed the restrictions similarly imposed onAstraeus Aerial. Dronemation will operate onprivate property away from persons and property not involved inthe operation. Dronemationwill also obtain an ATO issued COApriorto conducting any operations under this Grant ofExemption. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level andpotential transponder requirements. A NOT AM will also be issued as required by the applicable COA. In addition to these flight restrictions, Dronemation will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects ofDM-UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in DM-UAS operations generally but have logged flight time inthe specific make and model used for the operations before they are permittedto participate in commercial flights onbehalfofDronemation. The pilot qualification, training, and currencyrequirements inthe Operations Manuals ensure that Dronemationpilots are competent and proficient in the DM-UAS they are operating. Dronemation's training and qualificationrequirements are consistent with those contained in prior FAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety to the public. 

### OPERATING PARAMETERS OF THEUAS F. 14 C.F.R. § 91.7(a): Civil AircraftAirworthiness

12 Exemption No. 11062 (FAA DocketNo. FAA-2014-0352).U.S Department ofTransportation November 18,2015 Page 15 Inasmuch as there will be no airworthiness certificate issued for the UASs, Dronemation seeks an exemption from 14 C.F.R. § 91.7(a), whichrequires that a civil aircraft be in airworthy condition to be operated. The FAA has statedthat no exemption is required for 14 C.F.R. § 91.7(a) to the extentthat the requirements ofPart 21 are waived or found inapplicable." Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with SectionV(A), supra. 

### G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft FlightManualinthe Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.F.R. 

### § 91.9(b) (2) and§ 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuantto 14 C.F.R. § 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft- (2) For which anAirplane or Rotorcraft Flight Manual is required by§ 21.5 of

### this chapter, unless there is available inthe aircraft a current approved Airplane orRotorcraft Flight Manual, approved manual material, markings, andplacards, or any combination thereof. Pursuantto 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no person may operate a civil aircraftunless ithas within it the following: (1) An appropriate and current airworthiness certificate

... (b) No personmay operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Given the small size and configuration ofthe DM-UAS, itwould be impossible to keep airworthiness documents and other aircraft manuals onboard the DM-UAS because there is simply no room and the DM-UAS has no cabin or cockpit. As a way to comply withthe code Dronemationwill maintainthe documents with the PIC and make them available for inspection. 

### EquivalentLevelof Safety In an FAA Office ofChiefCounsel's Opinion dated August 8, 2014, and prepared by DeanE. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircrafthas access to the UAS flight manual, registration certificate, and otherrequired documents from the ground control station

13 See Id. at 13-14, 22.U.S Department ofTransportation November 18, 2015 Page 16 fi·om which he or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilothas access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuringthat the pilot has access to the documents at the grotmd control stationfrom which he or she is piloting the UAS. 

### H. 14 C.F.R. § 91.103: Preflight Action Dronemation seeks an exemption from 14 C.F.R. §91.103, which requires a PIC to become familiar with specific informationbefore each flight, including information contained inthe FAA-approved FlightManual onboard the aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extentthat an FAA -approvedFlightManual is required. 

### EquivalentLevelof Safety An equivalent level ofsafety will be provided by following the Dronemation's Operations Manuals <md the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance with the Dronemation's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also berequired to review weather, flight requirements, battery charge, landing and takeoffdistance, UA performance data, and contingency landing areas-beforeinitiation of flight. Dronemation's Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS. 

### I. 14 C.F.R. § 91.109(a): Flight Instruction Dronemation seeks an exemption from 14 C.F.R. §91.109(a), whichprovides inpertinentpart that "[ n]opersonmay operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully fnnctioning dual controls." UASs and remotely piloted aircraft, by their design, do nothave functional dual controls. Instead, flight control is accomplishedthrough the use ofa device that connnunicates withthe aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. §91.109(a). 

### EquivalentLevelof Safety Given the size and speed ofthe UASs that Dronemation intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required by the Dronemation's Operations Manuals, all persons will be a safe distance away inthe event that the UAS experiences any difficulties during flight instruction. Moreover, as required by the Dronemation's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures provided for in Dronemation's Operations Manuals ensure that the proposedUAS operations

14 Memorandum from Mark Bury, FAA Assistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also DocketNo. FAA-2014-0352 at 16-18.U.S Depmiment ofTransportation November 18,2015 Page 17 provide an equivalent or higher level ofsafety than thatprovidedby the flight instruction regulations.



### J. 

### 14 C.F.R. § 91.119(c): Minimum Safe Altitudes Dronemation requests an exemptionfrom the minimum safe altitude requirements of 14 C.F.R. 

### § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure innon-congested areas. See 14 C.F.R. 

### § 91.119(c). Section 91.119(d) allows for a helicopter to operate.at less thanthose minimmn altitudes when it can be operated "without hazard to persons or property onthe surface," provided that "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the proposed DM-UAS operation will normally needto occur below400 feet AGL. In circumstances where the DM-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the DM-UAS will notbe operated more than 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature oftheproposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the DM-UAS. 

### EquivalentLevelof Safety Comparedto flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack offlammable fuel with the above noted UASs, any risk associated withthese operations is far less than those whichpresently exist with conventional aircraft. An equivalentlevel ofsafety will be achieved given the size, weight, and speed ofthe DM-UASs, as well as the controlled location where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point onthat structure and 50 feet horizontally ofthe structure. As set forth in the Operations Manuals, the DM-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless thatperson is in a position where he or she is shieldedfrom the DM-UAS and any possible debris resulting from its failure. Asrequired by the Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe DM-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controllertimely has grantedpermission and the PIC has made a

15 Relieffrom § 91.119(a) will not benecessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event ofa failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant ofExemption No. 11157 to Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15).U.S DepartmentofTransportation November 18,2015 Page 18 safety assessment ofthe risk ofoperating closerto those objects and, operations near the PIC or Observer will notpresent anundue hazardper§ 91.119(a). Adherence to these restrictions in Dronemation's Operations Manuals will ensure operations can be conducted without

compromising public safety. 16 

### K. 14 C.F.R. § 

### 91.121: Altimeter Settings Dronemation seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation ofthe departure airport orbarometricpressure. An exemption is required to the extent thatthe UASs do nothave a barometric altimeter, butrather a GPS altitude read out. 

### EquivalentLevelof Safety The FAA has stated that an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 can be achieved in circumstances where: (1) theUASs will be operated below 400 feet AGL or below17

, (2) within VLOS, (3) where GPS based altitude information is relayed inreal timeto the operator ata ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiation point is established for the PIC to confirm accuracy ofthe onboard GPS. 18 The DM-UAS that Dronemation intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Dronemation's Operations Manuals, the PIC will berequired to calibrate the aircraft's GPS compass priorto each flight operation. Like prior FAA Section 333 Grants ofExemption, the DM-UAS Dronemationintends to use, and the safety mitigationprocedures contained inthe Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemptionto the requirements of § 191.121 is therefore appropriate.

16 See e.g., Grant ofExemption No. I I 138 to Douglas Trudeau (FAA-20I4-048I at I9): "Ifbarriers or structures are presentthat can sufficiently protect nonparticipating persons from the UA ordebris in the event ofan accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. Ifasituation arises where nonparticipating persons leave such protection imd are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concem is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determines that it does not present an undue hazard. 11
17 Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than I00 feet above the highest point on the structure. 18 See Grant ofExemption No. II062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation November 18, 2015 Page 19 L. 14 

### C.F.R. § 91.1Sl(a): FuelRequirements for Flightin VFRConditions Dronemationrequests an exemptionfrom 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No personmay begin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enoughfuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) Atnight, to fly after that for at least45 minutes. Here, the technological limitations onUAS battery power means that no meaningful flight operations canbe conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. 

### § 91.151(a) is therefore required. Moreover, it is not Dronemation's intentionto fly the DM-UASs at night. 

### EquivalentLevelof Safety Inthe Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight in VFR conditions couldbe achieved by prohibiting the PIC from beginning a DM-UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intendedpoint oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the DM-UAS provide approximately 50 minutes ofpowered flight (with payload) and provided battery level and batterytime remaining inminutes and seconds to the PIC. 19 The FAA also consideredthe fact the DM-UAS operating manual states: "start every flight with a fully charged battery inthe aerial vehicle", and that inthe eventthatthe DM-UAS should run lowonpower, the PIC will be alerted and can safely landthe- DM-UAS as soon as possible. Like the VDOS Grant ofExemption, Dronemation's use ofthe DM-UAS, combined with the requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety can be achieved and infact exceeded. Similarly, in the Grant ofExemption to Alan Pmwin (ExemptionNo. 11161), the FAA determined that an equivalentlevel ofsafety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beghming a flight with the UA unless (considering wind and forecast weather conditions), there was enough power to safely fly at normal cruising speed to the intended landing point and landthe UA with 25% battery power remaining. Dronemation will adhere to this limitation for its DM-UAS flights. The DM-UAS includes a low battery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the DM-UAS to a ground-based-on-screen display. 20 As requiredby Dronemation's Operations

19 Grant ofExemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at I0). 20

. The DM-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and orientation relative to the UAS.U.S Department ofTransportation November 18,2015 Page20 Manuals, the PIC will promptly fly the DM-UAS backto the home launch location or predetermined abort location where it may safely land, while still maintaining a minimum of25% reserve batte1y power. Dronemation submits that the procedures requiring flights to be safely terminated once the batteries fall below25% capacity, combined with therequirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and withinVLOS ofthe PIC and Observer(s), ensure thatthe proposed operationwill provide an equivalent or higher level ofsafety to the public to thatprovided by the regulations from which exemption is sought. 

### VI. DRUG AND ALCOHOL PROGRAM Dronemation will have policies inplace to ensure thatno person may participate inDM-UASs flight operations ifthey are under the influence ofalcohol or any drug. 

### VII. PUBLIC INTEREST The public interest will be served by granting Dronemation's Petitionfor Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-theFAA Administrator's assessment ofwhether certainUAS may operate safely inthe NAS before completion ofthe statutorily required rulemaking. Theproposed DM-UAS operations inthis Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury andproperty damage to the public at large, the property owners from whompermission was granted for use by Petitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers fi·om relevant organizations and all those who may be in the local vicinity. Traditional methods ofinspecting andmonitoring potential locations and relevant sites and facilities requires location personnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated workfor whichthe individual is neither trained nor equipped to perform, which exposes themto unnecessary risk ofserious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposedto hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifYing specific locations for potential recording sites to be used inthe end product. The use ofsmall UASs can eliminate these hazards and ultimately create a much safer method of performing these types ofinspections creating a safer environment for the public as well as Dronemation employees. The use ofsmall UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, inthe unlikely event of an accident, Dronemation's small battery powered DM-UAS presents significantly less danger to persons onthe ground when comparedto operations by conventional manned aircraft.21 As

21 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conductingU.SDepartment ofTransportation November 18,2015 Page 21 Petitioner's DM-UAS are battery powered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing inthe same functions proposed herein. Air quality will naturally be improved with the reduction offuel powered vehicles. Lastly, as recognized by the FAAinprior Section 333 Grants ofExemption to filmmalcers, UASs provide an additional economictool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the current capabilities offeredby manned aircraft.22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry andprovide additionaljobs as the cost ofproviding the neededproduct is greatly reduced while reducing the difficulty witl1 whichthe finished productis created. The demand for the current industrial product is increasing and will continueto increase giventl1e enhanced flexibility ofproduction; therefore, giventhe lower cost, owner/operators and others in the relevant industry will be more inclinedto utilize the services ofcommercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All DM-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate or controlled-access property withpermission from the land owner/controller or authorizedrepresentative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication inthe FEDERAL REGISTER, should itbe determined thatpublication is needed: Petitioner seeks an exemption from the following rules in Title 14 ofthe Code ofFederal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalentfilm work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or other methods.

aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAS will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event ofan incident oraccident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation." 22 See e.g., Grant ofExemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).

### U.S Department ofTransportation November 18,2015 Page 22



### X. CONCLUSION Dronemation's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas; operation within VLOS and national security. The proposed DM-UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. In consideration ofthe foregoing, this Petition for Exemption provides the FAA with more than adequatejustification for granting the requested exemptions allowing Dronemationto use small DM-UAS in the recorded production ofits product. We thank you for your prompt consideration ofour requested exemptions. Respectfully Submitted,



# ~~+ Jasmine Faqih Dronemation 22295 Jessamine Way Corona, CA 92883 Phone: 951.317.3706: Email:jazzyf2293@aol.com (The following attached items containproprietary and commercial information exempt from disclosure underthe Freedom ofInformationAct, 5 U.S.C. 

### § 522 et seq., and should be held in a separate file pursuantto 14 C.F.R. 

### § 11.35(b)). Attachments: I. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist I0. Equipment Checklist II. UAS Manufacturer's Manuals a. UserManuals b. UAS Maintenance Manuals