DOROSH	DOCUMENTARIES,	LLC

.

- January	19,	2016

- U.S.	Department	of	Transportation	•	Docket	Management	System 1200	New	Jersey	Ave.,	SE	•	Washington,	D.C.	20590

Re: Petition	of	Dorosh	Documentaries,	LLC	for	Exemption	from	Certain Federal	Aviation	Regulations to	Operate	Unmanned	Aircraft Syst ems Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act

To	Whom	It	May	Concern:

Pursuant	to	Section	333	of the FAA	Modernization	and	Reform	Act ("FMRA")	and	14 C.F.R. part	11,	Dorosh	Documentaries,	LLC	here by petitions	the	Federal	Aviation	Administration	("FAA")	for	exemption from 14 C.F

. R. §§ 61.23(a)	and	(c),	61.101(e)(4)	and (5),	6 1.113(a), 61.315(a),	91.7(a),	91.119(c),	91.121,	91.15l(a)(l),	91.405(a), 91.407(a)(l),	91.409(a)(l)	and	(2),	and 91.417( a) an d	(b),	and	any other	rules the FAA	deems	necessary, to	en ab le Dorosh Documentaries,	LLC to	operate unmann ed aircraft systems ("UAS") for	aerial data collection.	Specifically,	Dorosh	Documentaries,	LLC seeks to operate	UAS for newsgathering,	commercial	prod uction, promotional	video,	and	special	events	such	as sporting	events, wedding	ceremonies	and	receptions,	using	the	DJI	Phantom	3.
Becau se this petition is	similar in all	material	respects to	previou s ly

granted Section	333	petitions,	Dorosh	Documentaries, LLC request s expedited	approval	pursuant to the	FAA's	summary	grant	process.

I.	P ROPOSED	OPERATIONS AND PUBLIC INTEREST BENEFITS

Dorosh	Documentaries,	LLC is	a	television	and	post

- production company	that	specializes	in marketing, production

, events
manag ement and	distribution	company .		Dorosh	Documentaries,
LLC has	been	outs ourced	for	aerial	footage	from	the	Pittsburgh Pirates,	Pittsburgh	Penguins,	Root	Sports,	NCAA,	Pitt,	Fox	Sports, and	many	other	companies	for	the	purposes	of	marketing	theirteams,	sch ool,	and	company. Dorosh	Documentaries,	LLC	seeks	to use	UAS	to	conduct	aerial	data	collection	that	will	serve	a	variety	of functions	including	newsgathering,	commercial	production, promotional	video,	and	special	events	such	as	sporting	events, wedding	ce remonies	and	receptions.		Grant	of	this	petition	will enable	Dorosh	Documentaries,	LLC	to	better	serve	its	viewers	across the	country,	as	Dorosh	Documentaries,	LLC	will	be	able	to	obtain key	aerial	footage	for	promotional	videos	and	other	content	and

opera te	its	business	more	safely,	efficiently	and	effectively	than	ever before.

In addition	to	fostering	significant	public	interest	benefits, Dorosh Documentaries,	LLC operations	will	carry	minimal	risk. Dorosh Documentaries,	LLC is	committed	to	the	safe	oper ation	of its	UAS, and	will	adhere	to	stringent	operating	conditions	in	conformity	with	past grants of exemption.	These	conditions	ensure	that Dorosh Documentaries,	LLC will	operate	safely	in	the	national	airspace, mitigate	the	risks of harming	ot her	aircra ft	or	people	or	proper ty	on	the ground,	and	present	no	threat	to	national	security.	Adhering	to	these parameters, Dorosh	Documentaries,	LLC will	be	able	to	safely	and effectively	operate	its	UAS	to	the	benefit of its	viewers,	crewmembers, and	the	general	p ublic.

II.	UAS

Dorosh	Documentaries,	LLC requests	an	exemption	to	operate	the	DJI Phantom	3	which	is	well	below	55	pounds	including	payload.	Through the	Section	333	exemption	process,	the	FAA	has	authorized	use of all UAS	for	which	exemption	is	requested herein.

II I

. REQUEST	FOR	SUMMARY	GRANT

Dorosh	Documentaries,	LLC requests	that	the	FAA	issue	a	summary
grant of exemption	pursuant	to	the	agency's	expedited	summary	grant

process. Dorosh	Documentaries,	LLC will	adhere	to	operatingparameters	that	will	o ffer	the	same	level of safety	as	the	conditions	the FAA	currently	requires	in	its	summary	grants.

IV. APPLICANT	INFORMATION

The	name	and	contact	information of the	applicant	is:

Nazari	Dorosh CEO,	Dorosh	Documentaries

5317	Fieldcrest	dr Pittsburgh,	PA	152 36

Regulations	from	which	exemption	is	requested:

14	C.F.R. §§ 61.23(a)	and	(c);

14 C.F.R. §§ 61.101(e)(4)	and	(5);

14	C.F.R.	§	61.113(a);

14 C.F.R.	§	61.315(a);

14 C.F.R.	§	91.7(a);

14	C.F.R.	§	91.119(c);

14 C.F.R.	§	91.121;

14 C.F.R.	§	91.151(a)(l);

14 C.F.R.	§	91.405(a);

14	C.F.R.	§	91.407(a)(1);

14 C.F.R. §§ 91.409(a)(l) and	(2);

14 C.F.R. §§ 91.417(a)	and	(b).

V.	OPERATING	PARAMETERS

Dorosh	Documentaries,	LLC will	adhere	to	the	following	operatingparameters	when	operating	UAS	pursuant	to	a	grant	of	the requested	exemption:

1. Operations	will	be	conducted	using	the	DJI	Phan tom	3
2. The	UAS	will	not	be	operated	at	a	speed	exceeding	87	knots ( 100 miles	per	hour),	at	an	altitude	greater	than	400	feet	above	ground level,	or,	when	visibility	is	less	than	3	statute	miles,	less	than	500 feet	below	or	2,000	feet	horizontally	from	a	clo ud.	All	operations will	be	conducted	during	the	day	under	visual	meteorological conditions.

3. All	operations	will	be	conducted	in	accordance	with	a	Cettificate	of Waiver	or	Authorization	("CO A'').
4. All	operations	will	use	a	pilot

- in

- command	("PIC")	and	a	visu al observer	("VO"),	and	the	UAS	will	remain	within	the	visual	line	of sight	of	the	PIC	or	the	VO	at	all	times.	The	PIC	will	maintain	VLOS capability	and	the	ability	to	communicate	verbally	with	the	VO	at	all
times.
5. The	PIC	will	hold	an	airline	transport,	c ommercial,	private, recreational,	or	sport	pilot	certificate,	as	well	as	an	FAA	airman medical	certificate	or	a	valid	U.S.	driver's	license.	The	PIC	will	meet the	flight	review	requirements	specified	in	14	C.F.R.	§	61.56	in	an aircraft	in	which	the	PIC	is rated	on	his	or	her	pilot	certificate.

6. Dorosh	Documentaries,	LLC will	ensure	prior	to	operation	that	the PIC	has	demonstrated	the	ability	to safely	operate	the	UAS	in	a

mann er	consistent	with	how	the	UAS	will	be	operated	under	this exemption,	including	eva sive	and	emergency	maneuvers	and maintaining	appropriate	distances	from	pe rsons,	vessels,	vehicles and	stru ctures.	PIC	qualification	flight	hours	and	currency	will	be logged	in	a	manner	consistent	with 14 C.F.R.	§	61.51(b).

7. Dorosh	Documentaries,	LLC operat ing	documents	will be accessible during	UAS	operations	and	made	available	to	the	Administrator upon	request.
8. Prior	to	each	flight,	the	PIC	will	conduct	a	pre

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

revea ls	a	condition	that	affects	the	safe	operation	of	the	UAS,	the UAS	will	not	be	operated	until	the	necessary	maintenance	has	been performed	and	the	U AS is	found	to	be	in	a	condition	for	safe	flight.9. Any	UAS	that	has	undergone	maintenance	or	alterations	that affect the	UAS	operation	or	flight	characteristics,	e.g.,	replacement	of	a flight	critical	component,	will	undergo	a	functional	test	flight	prior to	conducting	further	operations	under	this	exemption.
10

. Any	UAS	that	has	undergone	maintenance	or	alterations	t hat	affect the	UAS	operation	or	flight	characteristics,	e.g.,	replacement	of	a flight	critical	component,	will	undergo	a	functional	tes t	flight	prior to	conducting	fur ther	operations	under	this	exemption.
11. Do rosh	Documentaries,	LLC will	follow	the	UAS	manuf acturer's maintenance,	overhaul,	replacement,	inspection,	and	life	limit requirements,	as	well	as	safety	bulletins,	for	the	aircraft	and	aircraft components. 12. The	PIC	will	a bort	the	f l ight	in	the	event	of	unpredicted	obstacles	or emergencies,	and	will	yield to	all	manned	aviation	activities.
13. Dorosh	Documentaries,	LLC will	register	and	mark	its	UAS	in accordance	with 14 C.P.R.	parts	47	and	45.

VI.	THE	FAA’S	AUTHORITY	TO	GRANT	THIS	PETITION

The	FAA	has	authority	to	grant	the	exemption	requested	herein under	t he	FMRA	and	the	Federal	Aviation	Act.	Section	333	of	the FMRA	deals	specifically	with	integrating	UAS	into	the	national airspace,	and	directs	the	Secretary	of	Transportation	to	determine which	UAS,	"as	a	result	of	their	size,	weight,	speed,	operational

cap ability,	proximity	to	airports	and	populated	areas,	and	operation within	visual	line	of	sight	do	not	create	a	hazard	to	users	of	the national	airspace	system	or	the	public	or	pose	a	threat	to	national security." 3 Section	333	further	directs	the	Secretary	t o	"establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the national	airspace	system." 4 The	Federal	Aviation	Act	authorizes	the Administrator	of	the	FAA	to	grant	exemptions	from	regulations prescribed	under	certain	provisions	of	the	Ac t	where	such exemptions	are	in	the	public	interest. 5 Part 11 of	the	Federal	Aviation Regulations	governs	the	FAA's	exemption	process	and requirements. 6 The	FAA	has	granted	more	than	1,100	exemptions	todate	pursuant	to	its	Section	333	and	exemption	authori ty,	enabling commercial	UAS	operations	in	a	wide	variety	of	industries.

3 Pub. L. No.	112

- 95,	126	Stat.	75

- 76	(codified	as	a	Note	to	49	U.S.C.	§	40101).

4 Id

5 49	U.S.C.	§	44701	(f)	("The	Administrator	may	grant	an	exemption fr om a requirement	of	a	regu lation	prescribed	under	subsection	(a)	or	(b)	of	this	section	or any	of	sections	44702

- 44716	of	this	title	if	the	Administrator	finds	the	exemption is in	the	public	interest.").

6 See 49	C.F.R.	Part	I	I.

VII.	SUMMARY	TO	BE	PUBLISHED	IN	THE	FEDERAL	REGISTE R

Should	the	FAA	determine	that	publication	in	the	Federal	Register	is required, Dorosh	Documentaries,	LLC offers	the	following	summary pursuant	to	section	11.81 of the	FAA's	rules: 7

Petitioner: Dorosh	Documentaries,	LLC

Sections 

### o	f 14 C. FR.	Affected: 14 C.F.R.	§§	61.23(a)	and	(c);	14	C.F.R.	§§ 61.101(e)(4)	and	(5);	14	C.F.R.	§	61.113(a);	14	C.F.R.	§	61.315(a);	14
C.F.R. § 91.7(a);	14	C.F.R. § 91.119(c);	14	C.F.R.	§	91.121;	14	C.F.R. § 91.15l(a)(l);	14	C.F.R. § 91.405(a);	14	C.F.R. § 91.407(a)(l);	14	C.F. R. §§ 91.409(a)(1)	and	(2);	14	C.F.R.	§§	91.417(a)	and	(b).

Description 

### of Relief	Sought: Petitioner	seeks	relief	from	the requirements of 14	C.F.R.	§§	61.23(a)	and	(c);	14	C.F.R.	§§	61.101(e)(4) and	(5);	14	C.F.R.	§	61.113(a);	14	C.F.R.	§	61.315(a);	14	C. F.R.	§	91.7(a); 14C.F.R.	§	91.119(c);	14	C.F.R.	§	91.121;	14	C.F.R. § 91.151(a)(l);	14	C.F.R. §	91.405(a);	14	C.F.R.	§	91.407(a)(1);	14	C.F.R.	§§	91.409(a)(l)	and	(2); 14	C.F.R.	§§	91.417(a)	and	(b)	to	operate	unmanned	aerial	systems	for newsgathering,	com mercial	production,	promotional	video,	and special	events	such	as	sporting	events,	wedding	ceremonies	and receptions

.

VIII.	CONCLUSIONAs	demonstrated	above,	the	UAS	operations Dorosh Documentaries,
LLC has	proposed	in	this	petition	for	exemption	will	garn er	significant public	benefits	while	presenting	minimal	safety	risks. Dorosh Documentaries,	LLC petition	satisfies	the	criteria of Section	333 of the FMRA	and	is	substantially	similar	to	previous	petitions	the	FAA	has granted,	meriting	a	summary	grant o f exemption. Dorosh Documentaries,	LLC respectfully	requests	that	the	FAA	grant	this petition	to	enhance Dorosh	Documentaries,	LLC ability	to	provide
content	to	its viewership.

Please	do	not	hesitate	to	contact	Nazari	Dorosh, Dorosh Documentaries,	LLC

, CEO	at doroshdocumentaries@gmail.com with any	questions	about	this	filing.

Sincerely,

Nazari	Dorosh

Dorosh	Documentaries,	LLC

7 id.§ 11.81(f).