August 03, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., S.E. Washington, DC 20590

RE: Petition of FlyteTime Aerial Images, LLC/Sirrah Media Group for Exemption pursuant

to Section 333 of the FAA Reform Act

Attn: To Whom it may concern

This petition is being submitted pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, FlyteTime Aerial Images/Sirrah Media Group hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as all opera tions are conducted with and under the conditions outlined and established by the FAA as required by Section 333.1.

As described in detail below, FlyteTime Aerial Images/Sirrah Media Group requests an exemption to pursue its commercial interests in providing services to clients using the DJI PHANTOM 3Professional quadcop ter unmanned aircraft system (UAS) for the limited purpose of conducting aerial photography and videography be low 400 feet AGL and further than 5 miles from any airport or heliport, in order to sa fely and legally capture aerial photography and videography for use by owners of commercial an d residential properties, building contractors and inspectors, developers, rea lty agents, marketing/aerial im agery and for the inspection and surveying of land for compensation or hire. FlyteTime Aerial Images/Sirrah Media Group will also offer at no charge aerial phot o/video services to all first responders (including fire, police and rescue crews) if requested.

Statutory Authority Section 333, titled "Special Rules for Cert ain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorizati on of safe civil UAS operations in the NAS. Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may operate safely in the national airspace system be fore completion of the (comprehensive) plan and rule making required by section 332(b)(1) of this Act or the guidance required by section 334of this Act. In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The petitioner requests relief from the following regulations:

14 C.F.R 21 14 C.F.R. 45.23(b)

14 C.F.R. 61.113 14 C.F.R. 91.7(a)

14 C.F.R. 91.9

14 C.F.R. 91.109

14 C.F.R. 91.11914 C.F.R. 91.121

14 C.F.R. 91.151 14 C.F.R. 91.203(a) & (b) 14 C.F.R. (91.401-91.417)



### Unmanned Aircraft System
sUAVs are frequently viewed as superior to helic opters due to being sma ller in size, a reduction in cost (including operation and personnel), reduced noise and fuel pollution in addition to an overall reduction in safety. FlyteTime Aerial Images /Sirrah Media Group is petitioning for an exemption to operate UAV flights over private or controlled access prope rty with the property owner’s consent and knowledge and that only pe ople who have consented or otherwise have agreed to be in the area where photography/vide ography will take place in the following scopes:

• Construction Photography/Videography

 Real Estate Photography/Videography • Special Events Photography/Videography • Surveying and Inspections • Marketing and Aerial Imagery

FlyteTime Aerial Images /Sirrah Media Group uses UASs that are multirotor, weighing less than 25 pounds including payload. They operate, under normal conditions, at speeds not to exceed 45 mph and have the capability to hover, a nd move in the vertical and horizontal plane. FlyteTime Aerial Images /Sirrah Media Group UASs will operate in line of sight, during daylight hours, and will only operate within a st erile area. The sUAS operated by the petitioner weighs less than 25 pounds, including all payloads (i.e. camera, lens, and stabilized gimbal). Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS as the onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low batter y state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state and it is anticipated that flights will usually last less than 20 minutes . The sUAS will be programmed so it will not be operated at an altitude th at exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which photography/videography is planned.

The above specifications meet with the Model Ai rcraft Operating Standards and ensure that operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public."



### Preflight Action Plan
The petitioner will follow a pre

- flight checklist to ensure that the SUAS is in a condition for safe flight. This pl an will be revised as needed in order to ensure all known safety precautions and/or safety precauti ons suggested by the ma nufacturer are being

accounted for.A. Pre

- flight Inspection 1. Check that the control items (remote control, aircraft battery and smartphone) are all fully charged.

2. Verify that the propellers are mounted correc tly with each propeller spinning completely

onto the motor shaft

. 3. Check each rotor blade for hairline cracks.

4

. Verify that the landing gear is secure (not cracked/broken/loose)

. 5. Verify that the Micro-SD card ha s been inserted and formatted

. 6. Remove the gimbal guard and camera lens cap. 7. Verify that the camera is secure and clea n. Inspect the camera ribbon cables for signs of

wear or cuts/tears. 8. Verify that the smartphone's/ tablet’s GPS is enabled and set the smartphone or tablet to do-not-disturb mode to preven t distractions while flying. 9. Set the smartphone or tablet to forget any Wi -Fi networks in range in order to prevent the Wi-Fi connection from changing mid

- flight. 10. Verify that the smartphone/tablet’s audio is on to ensure the low battery warning and

other alarms can be heard.

B. Maintenance

1. All sUAS’s will be maintained in accordan ce with inspection program specified in the manufacturer’s guidelines. 2. In the event of an accident involving Flyt eTime Aerial Images/Sirrah Media Group sUAS operations will be ceased immediately.



### Equipment
The DJI Phantom 3 Professional is a proven consum er grade small rotorcraft in the quadcopter configuration with a documented weight of 1280g designed primarily to carry a high definition camera. It has a maximum ascent speed of 5m/s and a maximum descent speed of 3 m/s. It is powered by four electric motors w ith a distance between motors of less than 14 inches (350mm). It utilizes an internal global positioning sy stem (GPS/GLONASS) to maintain its geospatial orientation and position. It is c ontrolled primarily through an F CC certified radio control (RC) unit. Real time video and telemetry informati on is transmitted back to a ground control station allowing the operator to monitor battery level, GPS signal strength, altitude (AGL), distance from the operator, camera imagery, and control came ra angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude that will be preprogrammed by the operator. The remote control operates on a 2,400 GHz-2.483 GHz operating frequency.



### Operations

 Minimum crew for each operation will consist of the sUAS Pilot and Visual Observer.

 All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC.

 All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation. Operations will be restricted to flights over private property with the permission of the property owner and abutters.

 All-required-permits will be obtained from state and local go vernment prior to operation.

 FlyteTime Aerial Images /Sirrah Media Group will be operated within line of sight of the

PIC and observer.

 FlyteTime Aerial Images /Sirrah Media Group will not be operate over densely populated

areas

 FlyteTime Aerial Images /Sirrah Media Group will not be operating over heavily trafficked

roads

 FlyteTime Aerial Images /Sirrah Media Group will not be operating within 5 NM of an airport or heliport having an operational control tower.



### Intended UAS operation

The "sUAVs), powered by batteries, is smaller, lighter and more maneuverable than larger
aircraft running on combustible fu el. It operates at lower altit udes with no humans on board and
will thereby reduce current risk le vels and thereby enhance safety and diminish the likelihood of
death or serious bodily injury. With a small payl oad and maximum flight time of 22 minutes, this

is offers little or no risk to national security. Lower-l evel non-traditional ph otos and video from
several angles are far more effective than ground based imagery for displaying the characteristics
of large, complex properties w ith several buildings and large trees and other features. The
benefits of reduced cost and improved quality of presentation from the sUAV will be valuable to
and benefit many buyers and sellers of real pr operty, construction companies, developers,
inspectors and event marketers. Safety and co mpliance issues in the co nstruction of buildings

would now be verified in real time with the Phantoms (sUAV's) real time video and still imaging
capabilities.

Regards,

Wilmark Harris FlyteTime Aerial Images /Sirrah Media Group

PO Box 724316 Atlanta, GA 31139

678.592.5856 FlyteTimeAerial@gmail.comRegulations from Which Exemption Is Requested

FlyteTime Aerial Images /Sirrah Media Group requests an exemption from the following regulations as well as any additi onal regulations that may techni cally apply to the operation of the sUAV System:

14-CF-H Part 2-1, Airwor thiness-Certificates This part establishes the procedures for the issu ance of an airworthiness certificate. While the FAA continues to work to develop airworthines s standards for Unmanned Aerial Systems, we request an experimental certificat e be issued for the DJI Phantom 3 professional under either or both of the following provisions:

21.191 Experimental certificates Experimental certificates are is sued for the following purposes:

(a) Research and development. Testing new airc raft design concepts, ne w aircraft equipment, new aircraft installations, ne w aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducti ng flight tests and other operations to show compliance with the airworthiness regulations in cluding flights to show compliance for issuance of type and supplemental type certificates, fli ghts to substantiate major design changes, and flights to show compliance with the function an d reliability requirements of the regulations. Since the experimental certificate can be used fo r commercial purposes such as market surveys, sales demonstrations, and customer crew traini ng, we would expect th at an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, w ill not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft perfor ming the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certifi cate in general, citing the equivalent level of safety out lined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks These regulations provide that each aircraft mu st display "N" and the aircraft's registration number in letters at least 3 inches-high. Add itionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches hi gh near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entr ance in which the word "EXPERIMENTAL" can be placed, and may not have a registration numbe r assigned to it by the FAA. We propose toachieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is prep aring for launch will be able to see the designation. Additionally, we feel that the permanent placa rd discussed in the previous paragraph will provide the aircraft's registrati on information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words

“Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, th e banner should be visible to anyone that

observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations The petitioner requests relief in order to facilit ate the utilization of an experienced UAS operator with the addition of a trained observer. All pr e-flight inspection, mainte nance and flight logs

will be saved and made available to the FAA a nd Secretary of Transportation (SoT) for review; with purpose of safely integrating civil UAS operation in the National Airspace System

14 CFR 91.7 Prohibits the Operation of an ai rcraft without an airw orthiness certificate As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manua l, marking, and placard requirements This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight

manual information is available to the aircre w while operating the airc raft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the

documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the in tent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully func tioning dual controls." The sUAS System ground

based control station consists of a small hand-h eld radio transmitter and while it does not offer a second set of "controls", both the student and inst ructor can, and will, operate the single set of controls simultaneously. With both student and in structor having "hands-on" the controls during flight, we feel that this tec hnique meets the intent 91.109 and pr ovides an equivalent level of safety.

91 .119 Minimum safe altitudes: General The regulation states that over sparsely populated areas the aircraft ca nnot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items lis ted. Operations will only be flown over property or persons where permission has been obtained a nd careful pre-planned ha s been performed. Theaircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on th e surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. In addition, the SUAS will be programmed so that it will not be operate d at an altitude of no more than 400 feet AGL.

CFR 91.1 ~1 Altimeter settings The regulation requires that aircraft,shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft . The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151- Fuel requirements for flight in VFR conditions The regulation provides that no person may begi n a flight in an airplane under day-vFR conditions unless there is enough fuel to fly to the firs t point of intended landing and to fly after

that for at least 30 minutes. We feel the inten tion of this paragraph is to provide an energy reserve as a safety buffer for delays to landi ng. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly more th an 3/4 NM from the point of in tended landing, a full battery charge

at launch will ensure that we meet the rese rve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircr aft: Certifications required The regulation provides that an airworthiness ce rtificate, with the registration number assigned to the aircraft and a registration certificat e must be aboard the aircraft. Additionally, subparagraph (b) provides that th e airworthiness certificate be "dis played at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equiva lent level of safety and meet the intent of 91.20.3, we propose that documents deemed appropriate for this aircraft by the FAA will be collocated with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information f ound on airworthiness and registration certificates be permanently affixe d to the aircraft via placard containing the following information plus the word "EXPERIMEN TAL" to satisfy the requirement of 14 CFR

45.23.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primar ily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspec tion. It is our inten tion that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircra ft for return to service." The

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in additionconduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electr ical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS FlyteTime Aerial Images /Sirrah Media Group will be using the UAS in a variety of applications that generally require expensive full-size manne d aircraft to complete . Small, light, unmanned aerial vehicles offer multiple benefits over the use of full-sized manned aircraft for property and land inspection, construction and real estate assess ment in addition to video and still photography to name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew crea tes a much greater margin of safety for all involved. By granting FlyteTime Aerial Images /Sirrah Media Group the requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Thus, the FAA has good cause to grant this Petition.

Conclusion As pointed out in this application, all th e SUAs which our company would use, under authorization by the US DOT-FAA, are small, light-weight devices operated within the line of sight of the Pilot-in-Command (P IC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seap lane base, spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight

within a radius of this distance.

For the foregoing reasons, the exemptions reque sted herein should be granted and FlyteTime Aerial Images /Sirrah Media Group should be permitted to conduct small UAS operations in accordance with its manuals and all other ope rating parameters deemed necessary and appropriate by the FAA. The submission of this application and its c ontents is the best

demonstration that indeed it is possible to pursue the authoriza tion process so that some SUAs may be used for legitimate commercial ac tivities and under reasona bly safe conditions.