August 5

, 2015

Exemption No. 12338 Regulatory Docket No. FAA

– 20 15

– 1172

Ms. Mina Ghabriall Archangel Drone Services, LLC
11649 Hemlock Street El Monte, CA 91732

De ar Ms. Ghabriall :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated April 16, 2015 , you petitioned the Federal Aviation Administration (FAA) on
behalf of Archangel Drone Services, LLC ( hereinafter petitioner or operator ) for an exemption. The exemption would allow the petitioner to operate an unmanned ai rcraft system (UAS) to conduct sUAS flight training 1 , education, real estate photography, and videography, and demonstration flights

.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations th at the petitioner seeks an exemption

.

1 T he petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize UAS operations for training until a further assessment is completed. When the FAA completes its review, we will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the
other conditions and limitations in th is e xemption.2

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition wo uld be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom, DJI Flamewheel F550, DJI Inspire 1, 3D Robotics Solo, and DJI S1000.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in
reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation
has determined that this aircraf t meets the conditions of Section 333. Therefore, the FAA
finds that the relief from 14 CFR part 21

, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of p art 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 2 . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition.
In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA f ound that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in
addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previo usly requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

2 Aerial data collect ion includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by
instruments aboard the UA.3

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Archangel Drone Serv ices, LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform
aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Archangel Drone Services, LLC is hereafter referred to a s the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom, DJI Flamewheel F550, DJI Inspire 1, 3D Robotics Solo, and DJI S1000 when weighing
less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations f

or the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as spec ified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used

to s atisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;4

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,
the conditions and limitatio ns herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revis ions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the op erator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if quest ions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo
a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and d etermine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and lif e limit requirements for the aircraft and
aircraft components.5

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, rec reational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The P IC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and curr ency must be logged in a manner consistent with
14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner co nsistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, a s defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (AR P) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

managem ent is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less t han 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.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.6

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operation s shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These
documents must be made av ailable to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UA and/or debris in the ev ent of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating clos er to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control le d

- access property with permission from the property owner/controller or authorized representative.7

Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight o peration that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions
contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following a dditional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of
the UA S;
d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming produ ction event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming productio n, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/
John S. Duncan Director, Flight Standards Service1 | Page

– ADV Exemption Request April 16, 2015 April 16 , 2015

Mina Ghabriall
Archangel Drone Services

, LLC

11649 Hemlock Street
El Monte, CA 91732 (323) 844

- 2278 info@archangeldronevideography.com

Petition of Archangel Drone Videography, LLC

For Exemp tion Pursuant to Section 333
Of the FAA Moder nization and Reform Act of 2012

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR
Part 11, Archangel Drone Videography, LLC ( ADV ), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system ( i.e. , sUAS).

This exemption is in accordance with protocols outlined in this petition for ex emption, and any
other requirements established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operation by ADV , which uses DJI Phantoms, 550S Flame Wheels, Inspire 1, 3DR Solos, and S1000 to conduct s UAS flig ht training, education, real estate photography, and videography, film and movi e production, and demonstration flights. ADV ’s operation under the exemption will be subject to strict operating requirements and conditions to ensure an equivale nt level of saf ety to currently authorized operations using
manned aircraft and under c onditions as may be modified by the FAA as required by Section

333.

ADV will be operated under controlled VFR conditions a t low altitude in airspace that is permitted in accordance wi th ADV ’s approved Cert ificate of Authorization (COA). They will operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements . Finally, the

FAA ATC wil l approve the airspace in which the sUAS will operate in advance.

Archangel Drone Videography respectfully submits this request for an exemp tion because it
operates sUAS's . The FAA can have confidence that the operations will b e conducted at an equivalent level or greater level of saf ety. Approval of this exemption would thereby enhance safety and fulfill the Secreta ry of Transportation’s (the FAA Administrator’s) responsibilities2 | Page

– ADV Exemption Request April 16, 2015 under Section 333(c) of the Reform Act to “estab lish requirements for the safe operation of
such aircraft s ystems in the national airspace system.”

For your convenience, ADV has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 33 3 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest

VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

I. Petitioner's Description: Archangel Drone Videography, LLC , headquartered in El Monte

, California, is a company that provides sUAS support to news services , real estate photography, film and movie production, education, and demonstration flights in a compliant and safe environment. ADV plans on providing a wide range of services as the sUAS market expands.

ADV 's goal is to operate in an accident

- free environment by:

• Demonstrating a commitment by management and all employee’s to operator in a compliant manner.

• Identify hazard and risk while eliminating or controlling all these risk.

• They will use steps to intervene and report when unsafe work practices appear to exist.

• Train all employees involved in flight operations to operate at the highest standard
level.

The contact information for Petitioner is as follows:

Archangel Drone Videography, LLC
11649 Hemlock Street El Monte, CA 91732

Member Managers:
Mina Ghabriall
Office: (323) 844

- 2278
Email: info@archangeldronevideography.com

II. Relevant Statutory Authority: This petition for exemption is submitted to fulfill Co ngress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft sys tems into the national airspace system." Pursuant to
Section 333 of the Reform A ct, the FAA Administrator is to consider whether certain unmanned3 | Page

– ADV Exemption Request April 16, 2015 aircraft systems may operate safely in the National Airspace ("NAS") before completion of the
form al UAS rulemaking, based on the following considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator. 1

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish require ments for the safe operation of such aircraft in the National Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from i ts saf ety regulations and minimum standards when the Ad ministrator decides a requested exemption is in the public interest. A party requestin g an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would n ot adv ersely affect safety (or how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civ il aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:
The Administ rator may grant an exemption from a requirement

of a regulation prescribed unde r subsection (a) or (b) of this section or any of sections.

III. Qualifications for Approval Under Section 333 of the Reform Act The proposed operations in this petition for exempti on qualify for expedited approval under
Section 333 of the Reform Act. Each of the statut ory criteria and other relevant factors are
satisfied.

The proposed operations would permit ADV the us e of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) co ntrolled as to access; and that (3) provides an increased level of safety beyond that ex isting when fixed or rotor wing aircraft are used to accomplish the same purpose.

ADV uses UASs that are multirotor, weighing less th an 25 pou nds including payload. They operate, under normal conditions, at speeds no t to exceed 45 mph and have the capability to hover, and move in the vertical and horizontal plane. ADV ’s UASs will operate in line of sight, during daylight hours, and wil l only operate within a sterile area. ADV will operate at or below

400 feet AGL and will file a NOTAM for each flight opera ted in controlled airspace. All required

1 A DV’s submission places a duty on the Administrator to not only process applications for exemptions un der Section 333, but for the Administrator, if he deems the conditions proposed herein r equire modification in order to allow approval, to supply
conditions for t he safe operation of the sUAS. A DV welc omes the opportunity to consult with FAA s taff in order to address any issues or concerns that this proposal may rais e that they believe may require modification

.4 | Page

– ADV Exemption Request April 16, 2015 permissions and permits would be obtained fro m territorial, state, county or city jurisdicti ons, including local law enforcem ent, fire, or other appropriate governmental agencies prior to operating a sUAS.

Given the small size of the sUAS’s involved and the restricted sterile environment within which they will operate, this ADV ’s exemption falls within the zone of safety and demonstrate an equivalent level of safety, in wh ich Congress desired the FAA to permit commercial UAS operations by exemption pe nding completion of formal rulemaking. Also, due to the size of the
sUAS’s and the confined area in which the sUAS’s will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significa nt public benefit, the grant of the requested exemptions is also in the public interest.

IV. Description of Proposed Operations
To assist the FAA in its safety assessment of ADV 's proposed sUAS operations, below is a summary of operational limitations and conditions that will ensure an equivalent or highe r level of safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds.

2. Flights will be operated within lin e of sight of the PIC and observer.

3. Maximum total flight time for each ope rational flight will be limited to the amount of
time the sUAS ca n be flown and still maintain a reserve battery power of no less than

25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flights will be operated at a lateral dist ance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who
have not si gned a waiver in advance of the operation.

6. Minimum crew for each ope ration will consist of the sUAS Pilot in Command an d a
Visual Observer. Additional crewmembers consist of a Pilot and a Camera Operator.

7. The sUAS Pilot in Command will have undergone comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements

. 8. ADV will designate a Pilot in Command ("PIC") for each mission.

9. The sUAS will operate only with in a confined "Sterile Area".

10. Prior to the operations at a particular l ocation, a site inspection will have been
conducted. On the da y of the mission the management person with operational con trol
and the PIC will concur on dispatching of the mission.

11. A briefing will be conducted in regard to the planned sUAS operations prior to each
d ay's missions. It will be mandatory that all personne l who will be performing duties within the boundaries of the sterile area be present for this briefing.

12. ADV crew will use the checkli st and callouts required in the Operations Manual.5 | Page

– ADV Exemption Request April 16, 2015 13. All sUAS’s will be maintained in acc ordance with inspection program specified in the manufacturer’s guidelines.

14. In the event of an accident involving an ADV sUAS, they will cease operations and report
the accident to the NTSB and AFS

- 80.

15. Pilot in Command and Visua l Observer will at all times be able to communicate by voice.

16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel
will have been trained and tested in accor dance to FAA, NTSB, and AFS

- 80 best practices

. 17. All required permissions and permits would be obtained from territorial, state, county or city jur isdictions, including local law enforcement, fire or other appropriate governmental agencies.

18. ADV management will submit a written “Plan of Activities” to the local Flight Standards

Dist rict Office (FSDO) having jurisdiction over the area of propos ed filming three days in
advanced of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to return to a

pre

- determined l ocatio n within the Sterile Area and land.

20. Contingency plans will be in place to s afely terminate flight if there is a loss of communication between the pilot and the observer.

21. The sUAS has the capabili ty to abort a flight in case of unpredicted obstacles or

emer gencies.

22. ADV , by following FAA, NTSB, and AFS

- 80 best practices, will assure no individuals’
privacy is violated.

23. Procedures have been established in ADV ’s Operations Manual to contact ATC prior to operating in airspace other than G.

V. Regulations From Which Exemption is Requested

A. 14 CFR § 91.103: Preflight Action

B. 14 CFR § 91.113: Right

- of

- Way Rules

C. 14 CFR § 91.119 (c): Minimum Safe Altitudes

D. 14 CFR § 91.121: Altimeter Settings

E. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

F. 14 CFR § 9 1.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

A. 14 CFR § 91.103: Preflight Action

ADV requests an exemption from the prefl ight actions requirements of 14 CFR 91.113 that prescribes the preflight actions un der which aircraft may operate:

Each pilot in command shall, before beginning a f light, become familiar with all available information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requir ements, alternatives availab le if the6 | Page

– ADV Exemption Request April 16, 2015 planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;
b. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

i. For civil aircraft for which an approve d Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein;
and

ii. For civil aircraft other than those s pecif ied in paragraph (b)(1) of
this section, other reliable information appropria te to the aircraft, relating to aircraft performance under expected values of airport
elevation an d runway slope, aircraft gross weight, and wind and
temperature.

ADV will n ot operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. DJI ’s sUAS’s do not have published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data.

Equ ivalent Level of Safety In adherence to FAA, NTSB, and AFS

- 80 best practices, the PIC along with the person having operational control must follow to assure that the weath er will be adequate to complete the
mission in VFR condition. Since ADV operates in C alifornia where the density altitude is never usually above 20 00 feet, UAS performance is not affected. When ADV is allowed to operate in other par ts of the United States the UAS used in those locations will be test flown at gross weight to test performanc e limitations prior to conducting commercial operations.

B. 14 CFR 91.113: Right

- of

- Way Rules

ADV request an exemption from 14 CFR 91.11 3 Right

- of

- way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

- way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear.

Archangel Drone Videography operates small pilotless UAS’s and cannot comply with these
rules as they have been written.

Equivalent Level of Safety

ADV operates sUAS’s at or below an altitude of 400 feet AGL, well below the normal operating
altitude of other aircraft. ADV management require that a Pilot in Command with experience
will oversee each mission and has knowledge of the avoid rules. A Visual Observer will assist the PIC in looking for a ircraft entering the operations area. It’s the responsibility of the PIC to cease operatio ns and land the UAS immediately whenever and aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until the threat is clear.7 | Page

– ADV Exemption Request April 16, 2015 C. 14 CFR. § 91.119: Minimum Safe Altitudes

ADV requests an exemption from the minimum s afe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe alt itudes under which aircraft may operate:

• Over any congested area of a city, town, or s ettlement, or over any open air assembly of persons, an altitude of 1,000 feet ab ove the hi ghest obstacle within a horizontal radius of 2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface

, except over open water or sparsely populated area s. In those cases, the aircraft may not be operated clos er than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to ope rate at less than those minimum altitudes when it can be operated "without hazar d to persons or property on the surface," provided that "each

p erson operating the heli copter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations, the sUAS is n ormally operated below 400 feet AGL. Additionally, due to the nature of the pro posed operations, the sUAS will maintain a lateral
distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation.

Equivalent Level of Safety Compared to flight normal aircraft, ADV ’ s multi

- ro tor aircraft weigh a maximum of 25 pounds, and given the lack of flammable fuel, a ny risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be
achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As s et forth in the FAA, NTSB, and AFS

- 80 best practices , the sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

o btained consent. Because of the advance notice to the property owners and participants, all
affe cted individuals will be well aware of the planned flight operations prior to commencement of operations.

Furthermore, by operating at such lower altitudes, t he sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulatio ns. Finally, the successful safety record of the
DJI sUAS’s demonstra tes that the sUAS can be safely used at these lower altitudes and closer operating environments.

D. 14 C.F.R. § 91.121: Altimeter Settings

ADV seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by re ference to an altimeter that is set to the elevation of the departure airport or barom etric pressure. An exemption is required because the sUAS
does not have a baromet ric altimeter, but rather a GPS altitude read out.8 | Page

– ADV Exemption Request April 16, 2015 Equivalent Level of Safety An equivalent level of safety will be achieved by follow ing the procedures set forth in the FAA, NTSB, and AFS

- 80 best practices

. ADV will confirm the altit ude of the launch site shown on the GPS altitude indicator before flight. Moreover, th e PIC will use the GPS altitude indicator to constantly monitor the s UAS's height, thus ensuring operation at safe altitudes.

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

ADV requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR
conditions. Section 91.151 states:

a. No person may begin a flight in a n airplane under VFR conditions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to
the first point of intended landing, and assuming normal cruising speed

– i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes.

The batteries powering ADV ’s UAS’s provide approximately 10

- 25 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flights could not be

c onducted. Given the limitation s on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve am ount of battery life is needed. ADV will not be conducting any sUAS flights at night.

Equivalent Level of Safety An equivalent level of safety will be achieved because t he operations will be conducted on

- site without significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% reserve battery power st ill available. This restriction would be more than adequate to
return the sUAS saf ely to its planned landing zone from anywhere in its confined area of operation eve n in the event of an unexpected occurrence. Operation of the sUAS with less than

30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was

inten ded to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, operation will be limited to co ntrolled areas where only people and property owners, or official representatives who have signed waivers will be
allowed.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

ADV also seeks an exemption from the main tenance in spection requirements contained in 14 CFR 91.405(a), 91.407(a ) ( 1), 91.409(a ) ( 2), 91.41 7(a) and (b). These regulations specify maintenance and inspection standards in refe rence to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or oper ator of an ai rcraft "shall have the aircraft inspected as prescribed in subpart E of this part and sha ll between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because
Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the
sUAS will not have.9 | Page

– ADV Exemption Request April 16, 2015 Equivalent Level of Safety An equivalent level of safety will be achieved beca use maintenance and ins pections will be performed in accordance with FAA, NTSB, and AFS

- 80 best practices. The operator will ensure
that the sUAS is in working order prior to initiating flight, pe rform required maintenance, and keep a log of any maintenance performed. The opera t or is the person most familiar with the
aircraft and best suited to maintain the aircra ft in an airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the sUAS's size and carrying cap acity, and the fact that flight operations will only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional roto rcraft performing the same operation.

VI. PUBLIC INTEREST Granting Archangel Drone Videography, LLC an exemption further s the public interest. National policy set by Congress favors early integration of UA S into the national airspace in controlled, safe working environments such as those propose in this petition. The one vision of ADV is to help fac ilitate safe integratio n of sUAS’s into mainstream USA in the following areas:

• Movies and Videography

o Whether the shot requires unique views and expansive panning or ex treme altitude with radical views, the UAS is desi gned to hold up under demanding conditions. Because of the autopilot fe ature with pre

- designed mission management and R/C control interrupt, the pilot and camera operator can easily
create the ultimate shot with HD video or HD s till photos. When working close in
on a closed set the hazar ds to the actors are gre atly reduced due to the size of
the sUAS.

• News Gathering

o Similar to movies and videography, eac h news assignment may require a completely different shot or view of a scen e. With budgets for traditional helicopter use being greatly r educed, the UAS is th e perfect solution to allow for easy news gathering for a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, w hile the traditional helicopter must
hover over persons and property increasing the danger to individuals.

• Real Estate

o The sUAS can be used in all areas of rea l estate, including commercial, residential and industrial properties. Using a sUAS , real estate professionals can create promotional videos, photos and unique s hots that normal camera aspects cannot capture. ADV ’s easy

- to

- use video and ph oto platform enables properties to stand out, providing dazzling views that ar e typically shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high

- rise condo in stunning high definition tha t shows your potential customer
the actual view from the residence. The r emote platform is great for new planning, zoning and large developments. S imple and easy

- to

- use video and photos allow for multiple height p ictures and elevation views.10 | Page

– ADV Exemption Request April 16, 2015 VII. Privacy Archangel Drone Videography is deeply committed to protect ing public privacy. ADV knows that many individual have concerns about privacy from the operations of sUAS’s. ADV has created a privacy notice that informs residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property.

VIII. Federal Registry Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Archangel Drone Videography, LLC seeks an exemption from the following rules: 14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.405(a), 91.407(a ) ( 1), 91.409(a ) ( 2); 91.417(a) and (b).

Approval of this exemption request allows ADV to conduct commercial operations with small and lightweight unmanned aerial systems. ADV’s singular vi sion is to enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners.

The DJI sUAS, weighing less than 25 pounds and powered by batteries, eliminates virtually all of that risk given the reduced mass and la ck of combustible fuel carried on bard. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The opera tion of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.

If additional information is req uired, or if you have any questions regarding this Petition for Exemption, please contact the undersigned at:

With Best Regards,

Mina Ghabriall, Director Archangel Drone Videography, LLC Office: (323) 844

- 2278
Email: info@archangeldronevideography.com11 | Page

– ADV Exemption Request April 16, 2015 IX. Conclusion For the foregoing reasons, it is requested that the regulatory exemptions requested herein be respectfully granted

, and the Petitioner be permitted to conduct small UAS operations aforementioned purposes

.