December 29 , 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590



### A ERI 

### R EEL 

### , LLC’ S 

### P ETITION FOR 

### E XEMPTION

TO 

### O PERATE 

### U NMANNED 

### A IRCRAFT 

### S YSTEMS 

### P URSUANT

TO 

### S ECTION 

### 333 OF THE 

### FAA M ODERNIZATION AND 

### R EFORM 

### A CT OF 

### 2012

Proposed Use: Closed

- Set Filming in the Motion Picture and
Television Industries and
Aerial Data Collection

Proposed Aircraft: D JI Inspire 1, DJI Inspire 1 PRO, DJI Inspire 1 RAW, DJI Phantom 2, DJI Phantom 3 Standard, DJI Phantom 3 Professional, DJI Matrice 100, DJI S900, and DJI S1000

Petitioner’s Contact Information: AeriReel , LLC
83 Geneva Drive #622168 Oviedo, FL 32765

- 9993

Attn: William Ferrara Phone: (213) 700

- 2 70 2
Email: andrewferrara@live.comPetition of AeriReel , LLC | Page 2 of 12

I. Introduction

Dear Sir or Madam:

Pursuant to Section 333(a) through (c) (“Section 333”) of the FAA Modernization and Reform Act of 2012 ("Reform Act") 1 and the Federal Aviation Administrations’ (“FAA”) general exemption authority un der 49 U.S.C. §44701(f), AeriReel , LLC (“Petitioner”) petitions for exemption from 14 Code of Federal Regulations (“CFR”) parts and/or sections: Part 21, Subpart H; Part 27, 45.23(b), 45.27(a), 61.113(a) & (b), 61.133(a), 91.7(a), 91.9 (b)(2), 91.9(c), 91.103(b)(1), 91.109(a), 91.119 (c), 91.121, 91.151, 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b). The proposed exemptions, if granted, would allow Petitioner to operate small unmanned aircraft systems ("UAS") weighing 55 pounds or less for the purposes of closed

- set filming of motion picture s , television

programs , and commercials as well as aerial data collection 2 for the purposes mapping, pho togrammetry, surveying, inspection, photography, videography, real

- estate listings, motorsport

activities , weather observation, and/or insurance underwriting . The proposed UAS shall include the following systems: DJI Insp ire 1, DJI Inspire 1 PRO, DJI Inspire 1 RAW, DJI Phantom 2, DJI Phantom 3 Standard, DJI Phantom 3 Professional, DJI Matrice 100, DJI S900, and DJI S1000

.

Based on the small size of Petitioner’s UAS, the qualifications and experience of Petitioner’s UAS op erators, and controlled access environment within which Petitioner will operate, the requested exemptions fall squarely within the zone of safety envisioned by Congress and set forth in Section 333. Additionally, the enhanced safety achieved by replacing s ignificantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS operations ena bled by this petition are in the public interest. Moreover, the requested exemptions are similar in all material aspects to the requests for which exemptions have been previousl y granted, e.g., Exemption Nos. 11289, 11062, 11109, 11112, and 11213. Thus,
th e requested exemptions should be granted.

II. Identity of Petitioner

AeriReel , LLC
83 Geneva Drive #622168 Oviedo, FL 32765

- 9993

Attn: William Ferrara Phone: (213 ) 700

- 2702
Email: andrewferrara@live.com

1 Pub. L. 112

- 95 (2012), 126 Stat. 11 (2012).

2 Aerial data collection 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 (partic ulate measurement, etc.), or any other gathering of data by an instrument ( s ) aboard the UA.Petition of AeriReel , LLC | Page 3 of 12

III. Statutory Authority for Exemptions

The Administrator of the Federal Aviation Administration possesses both general and specific authority to grant the requested exemption.

First, the FAA Administrator may exempt an operator from FAA safety regulations and
minimum standards when the Administrat or concludes that the exemption is in the public interest.
See 49 U.S.C. §§ 106(f), 40113, 4470 1(±) (permitting exemptions from §§ 44701(a), (b) and §§ 44702

- 44716, et seq.). A party requesting an exemption must explain why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

Second, Section 333 of the Reform Act specifically authori zes the FAA Administrator to grant exemptions for operation of UAS. Indeed, the Reform Act directs the Administrator to (1) undertake formal rulemaking to speed up the integration of UAS into the national airspace (“NAS”) but in the meanwhile, (2) to permi t unmanned aircraft systems to operate in the NAS if doing is in the public interest, does not pose a threat to national security, and does not create a hazard to users of the NAS, taking into consideration the following:

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

• How close the UAS would operate to airports and populated areas;

• That the operator would keep the UAS in his direct, visual line of sight.
Thus, the FAA has the full authority to grant the requested exemptions.

IV. Sp ecific Regulations for Which an Exemption is Sought

Petitioner requests exemptions from the following regulations contained in 14 C

. F

. R

. :

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)
The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met with this petition, and
therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014

- 0352 at
13

- 14, 22. If the FAA determines that there are some characteristics of the UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft
14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the UASs would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.Petition of AeriReel , LLC | Page 4 of 12

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requireme nts

14 C.F.R. § 45.23(b) , Markings of the Aircraft states: When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally
certificated a ircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport, “experimental,” or “provisi onal,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

14 C.F.R. § 91.9(c) states:

No person may operate a U. S.

- registered civil aircraft u nl ess that aircraft is identified in accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as prac ticable.” See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 14.

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

Section 61.113 prescribes that “no person who holds a private pilot certificate may act as a pilot in command of an aircraf t that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft,” ( see Section 61.113(a)), and that “a private pilot may, for compensation or hire, act as pilot in co mmand of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire,” ( see Section 61.113(b)).

E. 14 CFR 61.133

- Commercial pilot privileges and limitations.

Section 61.133(a) sets forth privileges for persons holding commercial pilot certificates, including a provision impliedly limiting to persons holding a commercial pilot certificate the ability

to act a s pilot in command of an aircraft “[f]or compensation or hire.”

F. 14 C.F.R. § 91.103: Preflight Action

Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight, to include,

“ For any flight, runway lengths at airports of intended use, and the following t akeoff and landingPetition of AeriReel , LLC | Page 5 of 12

distance information:

... (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance
data contained therein ”

G. 14 C.F.R. § 91.1 19(c): Minimum Safe Altitudes in Uncongested Areas

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: “Over other than congested areas. An altitude
of 500 feet a bove the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

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

Section 91.121 requires, in p ertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.”

I. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during t he day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes.

J. 14 CFR 91.203

- Civil aircraft: Certifications required

Section 91.203 prohibits, in subpart (a) , any person from operating a civil aircraft unl ess it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as pr ovided for in October 1, § 47.31(c). Section 91.203 prescribes, in subpart (b) , that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit

ent rance so that it is legible to passengers or crew.

K. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have
the aircraft ins pected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in Part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under §43.7 of the same chapte r.Petition of AeriReel , LLC | Page 6 of 12

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an
airworthiness certificate in accordance with P art 21 of this cha pter.

Sections 91.417(a) and (b) prescribe, in pertinent part, that

-

(a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventative maintenan ce, and alteration and records
of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must in clude

- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft
for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and
each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspe ction program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety
directive number and revision s date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following reco rds for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and
transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or ope rator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.Petition of AeriReel , LLC | Page 7 of 12

V. Petitioner ’ s Proposed Operations to Satisfy Section 333

A. Unmanned Aircraft System s

The Unmanned Aircraft Systems (UAS ) to be operated under this request are less than 55 lbs. at Maximum Takeoff Weight (MTOW) , will be operated at a speed of no more than 87 knots ( See
, e.g., Exemption No. 11289 (Bird’s Eye Solutions), p. 3, c ondition (3 ), carry neither a pilot nor passenger, carry no explosive materials or flammable liquids, and operate exclusively within a
controlled access area. Petiti oner’s UAS use radio frequencies within the electromagnetic spectrum for operation and control that co mplies with Federal Communications Commission (“FCC”) requirements, and Petitioner has integrated safety features into the UAS, as described in the Motion
Picture and Television Operations Man ual (“ M PTOM ”). Petitioner is tendering the MPTOM under separate cover as a c onfidential and proprietary document as defined in 14 C.F.R. § 11.35(b). The

entire MPTOM contains confidential commercial and proprietary information that the Petitioner has not and shall not share. The operating conditions and procedures cont ained in the MPTOM are not available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements established by the FAA pursuant to Section 333 of
the FAA Reform Act.

Petitioner’s U AS are equipped with redundant safety mechanisms allowing them to operate safely after experiencing certain in

- flight failures. If a lost

- link event occurs, including the loss of ground communications and/or the loss of a GPS signal, Petitioner’s UAS have the ability to perform

a pre

- coordinated, predictable, automated flight maneuver and return to a predetermined location within a designated security perimeter for landing. The UAS further have the ability to abort a flight in the event of unpredicted obsta cles or emergencies. All flights will be terminated so there is at least five minutes of remaining power to operate the UAS safely. Thus, good cause exists for granting Petitioner’s requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requiremen ts for flight in VFR conditions).

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as large as practicable.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter onboard the UAS. Instead, altitude information will be prov ided to the UAS PIC via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- screen display. The altitude information will be generated by equipment installed onboard the UAS, using GPS triangulation, digitally e ncoded barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requested relief from 1 4 C.F.R. § 91.121.

Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the Petitioner , an exemption from 14 C.F.R. Part 21, Subpart H (AirworthinessPetition of AeriReel , LLC | Page 8 of 12

Certificates), subject to certain conditions and limitations, is warranted (if necessary) and meets the requirements for an equivalent level of safety under 14 C.F.R. Part 11 and Section 333. The UAS operated without an airworthiness certificate in the controlled access environment and under the
conditio ns and limitations proposed by Petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not subject to the proposed lim itations and conditions.

Petitioner will strictly comply with safety and maintenance procedures included in all applicable UAS manufacturer’s instructions and operating manuals. To the extent such information is not included in the guidelines developed by the manufacturers, Petitioners will develop and document maintenance, overhaul, replacement, and inspection requirements, procedures to document and maintain maintenance records with regard to Petitioner’s UAS, and UAS technician qualification criteria. P etitioner’s operations manuals will include maintenance requirements for
P etitioner’s UAS, including “on

- condition” maintenance and modifications. In light of these mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) are warranted.

B. UAS Pilot in Command

Petitioner’s U AS pilot in command (PIC) must hold either an airline transport, commercial, private, recreational, or sport pilot certificate, and valid driver’s license to satisfy the medical requirement. According to the FAA, “the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS

- specific flight cycles, flight time, and specific make and model exper ience, culminating in verification through testing.” See Exemption No. 11062, Regulatory Docket No. FAA

- 2014

- 0352, at p. 18. With those factors in mind, Petitioner’s UAS PIC shall be required to meet several conditions and
lim itations as outlined in the MP T OM, including the following:

• The UAS PIC will have accumulated and logged a minimum of 200 flight cycles and 25 hours of total time as a UAS pilot and at least 10 hours logged as a UAS pilot with a s imilar UAS type (single blade, multirotor , or fixed

- win g ).

• The UAS PIC will have accumulated and logged a minimum of five hours of flight time with the specific make and model of the UAS to be utilized for operations under the exemption
and three takeoffs and landings in the preceding 90 days.

• The UAS PIC will have successfully completed the qualification process as specified in the operations manuals, to include a knowledge and skill test.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s understanding that Petitioner’s UAS will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore unnecessary. To the extent such an exemption is deemed necessary, Petitioner asserts that it should be granted in light of the safety procedures proposed herein. In accordance with the pertinent part of 14 C.F.R. § 91.7(b), the operator in command of Petitioner’s UAS shall be responsible for determining whetherPetition of AeriReel , LLC | Page 9 of 12

the aircraft is in a safe condition for fli ght. Petitioner’s manuals for maintenance and operations shall include safety checklists to be used by the operator in command prior to each flight.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft flight manual, marking , and placard requirements and § 91.203(a) and (b), (Civil aircraft: certifications required), it is Petitioner’s understanding that relief from these regulations is no longer necessary in light of the FAA Memorandum “Interpretation regarding whether certa in required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014. To the extent the FAA deems an exemption from this section necessary for Petitioner’s proposed operations, such exemption should be granted in light of the mitigating fact that Petitioner will maintain the documents required under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control station during flights. Additionally, 100% of Petitioner’s operations will utilize a visual observer (“VO”). The VO may be

use d to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and the PIC will be able to communicate verbally at all times during operational flights.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply with the other applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, aircraft performance data, and landing and tak eoff distances before initiation of a flight. The PIC will also
account for all relevant site

- specific conditions in their preflight procedures.

C. Operating Parameters of Petitioner’s UAS
Petitioner’s UAS operations will be conducted within a sterile environment of closed

- se t filming. In this controlled environment, Petitioner’s operations will remain within VLOS of the PIC and VO, below 400 feet AGL, and at speeds below 87 knots. See Exemption No. 11289, p. 3, C. 3, 4) Only participating pers ons will be permitted within the operating area. Consistent with the relief typically provided to manned operations under FAA Order 8900.1, Volume 3, Chapter 8, Section 1, Petitioner requests relief from 14 C.F.R. § 91.119(c) with respect to those particip ating persons, vehicles, and structures directly involved in the performance of the actual filming. Regarding distance from participating persons, the operations manuals set forth safety factors for authorized and consenting production personnel. Because t hose procedures are specific to participating persons, no further FSDO or aviation safety inspector approval is necessary for reductions to the distances specified in Petitioner’s manuals.

Regarding the distance from nonparticipating persons, Petitioner w ill ensure that no persons are allowed within 500 feet of the operating area except those consenting to be involved and necessary for the filming production, with the possibility of reducing this distance to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. This is consistent with FAA Order 8900.1, V3, C8, S1.

Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center of

a non

- towered airport unless a letter o f agreement wi th that airport’s management is obtained and the operation is conducted in accordance with a Notice to Airmen (“NOTAM”). Additionally,
Petitioner will no t operate in Class B, C, or D airspace without prior written approval from thePetition of AeriReel , LLC | Page 10 of 12

respective tower . Nor wi ll Petitioner operate the UAS less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

Petitioner’s UAS will remain clear and yield the right of way to all manned operations a nd activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, and hangliders).

Although Petitioner seeks to comply with the waiver process as described in FAA Order 8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion Picture and Television Filming), the current section of Order 8900.1 has specific processes that preclude a jurisdictional FAA FSDO from issuing the required Certificate of Waiver, because the section did not originally provide for UAS operations. Thus, Petitioner seeks exemption from the applicable regulations normally waived during that process. Petitioner proposes that the FAA include the required notifications and coordination with jurisdictional FS DOs through the conditions and limitations accompanying the requested exemption, and that the exemption sought herein will take the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 8900.1. Under this rubric, Petitioner will notify every FSDO with jurisdiction over the area that Petitioner plans to operate, just as with manned filming operations, and those FSDOs will have the ability to coordinate further conditions and limitations with the UAS Integration Office to address a ny local concerns.

Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting any operations under this grant of exemption. In fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to the operation.

D. The Requested Exemption Promotes the Public Interest
The enhanced safety achieved by replacing significantly larger manned aircraft c arrying crew and flammable fuel with small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS operations enabled by the instant Petition are in t he public interest. Moreover, as the FAA has already recognized, “UAS provide an additional tool for the filmmaking industry, Agriculture and Conservation adding a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft.” See Exemption No. 11062, Regulatory Docket No. FAA

- 2014

- 0352, at p.
22.

VI. Privacy
All flights will be conducted over private or controlled access areas with the permission from the property owner/controller or authorized representative.Petition of AeriReel , LLC | Page 11 of 12

VII. Summary for the Federal Register
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules to allow for UAS operations for the purposes of closed

- set filming of motion picture s , television programs
, and commercials as well as
aerial data collection for the purposes mapping, photogrammetry, s urveying, inspection, photography, videograp hy, and/or insurance underwriting: 14 C.F.R. Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C .F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

VIII. Conclusion

For the reas ons explained above, the regulatory exemptions requested should be granted, and Petitioner should be permitted to conduct smal l UAS operations for the purpose s of closed

- set filming
of motion picture s , television programs
, and commercials as well as aerial data collection for the

purposes mapping, photogrammetry, surveying, inspection, photography, videograp hy, and/or insurance underwriting using the DJI Inspire 1, DJI Inspire 1 PRO, DJI Inspire 1 RAW, DJI Phantom 2, DJI Phantom 3 Standard, DJI Phantom 3 Professional, DJI Matrice 100, DJI S900, and
DJI S1000

.

Petitioner has satisfied the requirements of Section 333 of the Reform Act to permit operation
the UAS proposed here. This petition warrants review by the FAA under the “summary grant” process for im mediate approval as this petition would not set a precedent, and any delay in acting on this petition would be detrimental to the Petitioner

.

If you have any questions or require any additional information, please do not hesit ate to contact the undersigne d representative of the Petitioner

.

Respectfully submitted,

A ERI R EEL , LLC
83 Geneva Drive #622168 Oviedo, FL 32765

- 9993

/s/ William Ferrara
William Ferrara
PresidentPetition of AeriReel , LLC | Page 12 of 12

Attachments

(The following attached items will be submitted under separate cover as they contain proprietary and commercial information exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments:

Motion Picture and Tel evision Operations Manual