Tuesday, April 21, 2015

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

by/for Cedarmeade Studios, LLC

429 Beechcroft Road Winchester, VA 22601

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam,

This petition is being submitted with no legal counsel or consulting services.

This document constitutes an exemption Request under Section 333 of the

FAA Modernization and Reform Act of 2012 for Aviation Unmanned to perform Aerial Photography by/for Cedarmeade Studios, LLC. The main use of this UAS would be obtaining aerial video and still images for clients (categories listed below) and obtaining aerial still images for sale to the general public through online galleries. The UAS systems that I plan to use is a DJI Inspire 1 and will be referenced in this document and also in the

attached user manual.

The requested exemption would permit Cedarmeade Studios, LLC to pursue its commercial interests in providing services to clients using a small advanced UAS in the following areas:

• Real Estate /Architecture

• Marketing

• Surveying /Mapping

• Industrial Surveying

• Sporting Events

• Special Events /Festivals

Page of 1 8Regulations from which exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.401 – 91.417

Unmanned Aircraft System UAS are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices, more affordable equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety.

Cedarmeade Studios, LLC is petitioning for an exemption to operate a DJI Inspire 1 with a built-in stabilized HD camera and the following GPS safety

features :

• Restricts the height above ground level (AGL) to a specified usergenerated height.

• Restricts the radius of flight from the ground station to a user-generated

radius.

• Restricts operations within designated Class B, C and D airspace including a no-fly zone feature.

The DJI Inspire 1 also has a failsafe function that is triggered in the event

communications are lost between the UAS and the main controller transmitter. In the unlikely event this occurs, the UAS will return to its point of takeoff and land safety. If communications are restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards (AC 91-57) as set below:

1. The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and will operate at sites that are ‘sufficient distance’ from populated areas within the sterile area described in the FOPM. Such operations will ensure that the UAS will “not create a hazard to users of the national airspace system or the public.” The orientation of flights will

Page of 2 8be such that the pilot in command (PIC) always has a visual on the rear mounted LED flight Indicator. Additional safety features on the DJI Inspire 1 include, return to home, low battery energy level, enhanced failsafe along with operating in the less populated 5.8 GHZ frequency

range.

2. When flying the UAS within three (3) miles of an airport, airport operators will be notified and the operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft.

3. Pre-flight inspection would be checking battery condition/level in both the transmitter and UAS, a visual/operational check of the propellers, a visual/operational check of the aircraft, a visual/operational check of the motors, a full compass and IMU calibration, a visual/operational check of the transmitting radio control unit, a visual/operational check of the camera and gimbal unit and a visual/operational check of the vision positioning system. A check for power-lines, antennas and other overhead objects would also be performed. Wind conditions would be monitored and be a factor for flying.

4. The radio frequency of the DJI Inspire 1 is in 5.725~5.825 GHz range the FC350 camera 2.400~2.483 GHz. Maximum take-off weight approximately 3000g. Max Ascent/decent speed 5 m/s. Maximum flight Velocity 22 m/s. The UAS operated by the petitioner weighs less than 15 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

5. The PIC will be only myself and I have a minimum of 55 hours flying time with DJI equipment, approximately 10 of those hours with this specific model (DJI Inspire 1). I’m a freelance video producer and photographer with over 10 years of photography/videography experience. Testing, updating and programming the DJI Inspire 1 firmware would be done on a monthly schedule

. 6. Flights will be terminated when battery energy levels reach 25%, allowing sufficient reserve flight time to safely land the UAS.

7. The UAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 150 feet above a significantly elevated geographic position from which videography/ photography is planned.

8. I’m in good medical health and sound mental health with no arrests or
felonies.

9. The intended use of this DJI Inspire 1 is to supplement my existing photography business with aerial photographs and video. The aerial vantage point/perspective would allow my studio to provide a service to local advertising clients that is different/unique and competitive.

Page of 3 810. All photo/video flights would have the date, time, GPS coordinates along

with the camera metadata recorded in an in-app flight log on the mobile device serving as the in-flight monitor. This flight log records flight path, altitude, flight time, number of images shot, amount of video shot, date, time, and total flight distance. Each individual flight has the capability of playing back (in-app) in real time and is synced across devices via DJI’s in-app User Center.

11. Given the small size of the UAS and the restricted sterile environment within which it will operate, Cedarmeade Studios, LLC’s operations will adhere to the Reform Act’s safety requirements.

12. The DJI Inspire 1 will never be flown in the flight path of manned aircraft. with the first condition listed, always keeping a visual line of sight, being of utmost importance to providing a significant level of public safety.

I respectfully request exemption under Section 333 to enable Cedarmeade Studios, LLC to operate efficient, limited, low-risk commercial UAS operations for the activities stated respecting at all times the space and privacy of citizens and property while keeping airspace safe.

Respectfully,

Cedarmeade Studios, LLC
429 Beechcroft Road Winchester, VA 22601 Home/Cell: (540)533-3775

www.cedarmeadestudios.com

Page of 4 8EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Cedarmeade Studios, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the UAS System:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DJI Inspire 1 under either, or both, of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

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

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will 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 performing 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 certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS

Page of 5 8does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in a placard on the top of the aircraft where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration 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 adhering to the specifications of at least 2 inches and less than 6 inches. Since the aircraft will operate in close proximity (not more than 1/2 NM) to the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.7 Prohibits the Operation of an aircraft without an

airworthiness 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 manual, 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 aircrew while operating the aircraft. 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 intent of 91.9, we propose that the manual be kept in a digital format on a mobile device at the ground station. A hard copy will also be kept inside the equipment carrying case ( in the event the digital version is unavailable ) and available to the crew at the ground station anytime the aircraft is in, or preparing for, flight

.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAS would be photography or survey of persons, vessels, vehicles or structures it would, at times, be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful

Page of 6 8pre-planning has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the 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.

CFR 91.121 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 UAS 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 UAS 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 begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first pointof intended landing and to fly after that for at least 30 minutes and nightVFR conditions an additional 45 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAS is battery operated and the maximum duration of flight from a single battery charge is approximately 15 minutes with an additional 25% reserve. Since the aircraft will never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. The PIC has a visual reference to the remaining battery energy level and an estimated “return to home” energy requirement. 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 aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed 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 UAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co-located 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

Page of 7 8found on airworthiness and registration certificates be permanently affixed to the aircraft containing such information plus the word "EXPERIMENTAL" 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 primarily 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 inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or a

manufacturer- 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.

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