US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA

Reform Act and Part 11 of the Federal Aviation October 18 , 2015 Keith Dezmin 111 Vakerich Place South Plainfield, NJ 07080 (908) 246

- 0481 kdezmin@gmail.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590
Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR91.417(a) and (b)
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 CFR Part 11, Dezmin Media, operator of Unmanned Aircr aft Sy stems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be es tablished by the FAA as required by Section 333. The pilot, Keith Dezmin, has been flying since he was 16 years old and is well acquainted with FAA rules and regulations. He looks to couple his years of flying into a service that provides clients with hi gh quality digital content for use in their commercial and personal multimedia endeavors.

Thank you in advance for your consideration.**Aircraft**

Dezmin Media seeks an exemption to operate the following UAS devices

- all of which have been approved in previous 333 petitions: DJIPhantom 3 Professional http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf DJIPhantom 2 DJIPhantom 3 Advanced

– http://download.dji

innovations.com/downloads/phantom_3/en/Pha ntom_3_Advanced_User_Manual_v1.2_en.pdf
DJIInspire 1

– http://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pd f
DJIPhantom 2 DJIPhantom 2 Vision+, DJIInspire 1 DJIS1000+ DJIS900 

### Freefl y Cinestar 8 Tarot 68 0 Sport UAS 3D Robotics IRIS+ https://3drobotics.com/wp

- content/uploads/2014/04/IRIS

- Operation

- Manual

- v6.pdf 3D Robotics Solo https://3drobotics.com/kb/solo

- user - manual/ 3D Robotics X8+ http://3drobotics.com/wp

- content/uploads/2014/11/X8+

- Operation

- Manual

- vA.pdf 3D Robotics X8

- M when weighing less than 55 pounds including payload https://3drobotics.com/wp

- content/uploads/2014/10/X8M

- Operation

- Manual

- v1.pdf Gryphon Dynamics X8 Foxtech Kraken 130 Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption THE UNMANNED AIRCRAFT mentioned above would all meet the below criteria for flights.

• All have weights less than 8 pounds and would weight no more than 55 pounds including payload. • An on

- board flight computer with GPS navigation and location ability that receives signals for flight controls from a groun d

- based transmitter/controller• An on

- board camera capable of capturing imagery in the form of full color, high definitio n still photos

an d video • An on

- board telemetry system that delivers flight data from the on

- board flight computer to the on

board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site

• A 2.4GHz or 5.8GHz on - board radio transmitter that transmits live video from the on

- board camera plus all the flight data from the telemetry system described above; THE GROU N D ST ATION

- BASED PART OF THE SYSTEM • A Pilot in Command (PIC) in operational co ntrol of a flight operation from beginning to end and who co ntrols the UA while in the air • A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight • A radio receiver receiving live video and flight data from the on

- board camera and computer projects it all together onto a screen for the PIC to view during flight • A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while in flight. All aircraft will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. The sUAS will be maintained in accordance with the manufacturers instruction manual and only manufacturer's authorized replacement parts will be used. All sUAS Pilots in Command (“PICs”) acting as an employee or agent of Dezmin Media for its sUAS operations will have at least a private pilot certificate from the FAA an d a valid driver’s license (or appropriate medical certificate) with additional experience in unmanned aircraft operations.
Commercial operation of an UAS, as described herein, which are equipped with camera(s) And sensors, would provide professional services in the following areas: 1. Aerial photography and/or video for public and/or private use including real estate, architecture, golf courses, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and newsgathering. 1. Aerial inspection/photography of residential/commercial structures under contract with the owner s or local government authority. 2. Aerial video/photography for agriculture activities.
As described fully below, the requested exemption would permit the operation of designated UAS as set forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) saf e. Approval of this exemption would increase public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibilities to " .... establish requirementsfor the safe operation of such aircraft systems in the national airspace system."

**Benefit Public** Approval of these 333 exemptions in general would all ow commercial operations of small UAS to provide numerous s ervices that would benefit from aerial imaging and data collection while great ly enhancing safety by reducing the overall risk associated with traditional aircr aft. Traditional aerial imaging requires large aircraft, such as helicopters, with flammable fuel to fly in close proximity of populated areas and people and often in sub

- optimal states of their height

- velocity curves. With the use of sm all UAS of 55 lbs. or less that are battery operated and flying below 400 feet AG L, the risk of injury of people on the ground or the crew is greatly minimized in comparison. Conduct ing aerial acquisitions with UAS, i nstead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. Aside from the la ck of flight crew members located o nboard the aircraft, the THE AIRCRAFT UAS (weighing no more than 10 pound s and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

### Privacy All flights will occur over private or controlled

- access property with the property owner’s or controlling authority’s prior consent and knowledge. Aerial photography and video capture will be of people who have provided their written consent to being phot ographed or have been authorized to be in the area where flight operations are taking place. Establishing and maintaining tight controls over access to the flight operations area will minimize privacy issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Dezmin Media’s proposed operation of the sUAS will not implicate any privacy issues. Specifically, sUAS will be operated under detailed operational protocols designed to ensure client or property owner invo lvement as well as local law enforcement notification. **Safety** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. Th ese limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The UAS will weigh significantly less than 55 lbs. The UAS being used all have weights of less than 10 lbs. 2. The UAS, depending on the model in operation, will have a maximum operating speed of no more than 50mph. 3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. 5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crew for each operation will consist of the UAS Pilot and at least one VisualObserver (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a minimum of 20 hours on the designated UAS. 8. A safety briefing will be performed prior to each day's flights consisting of all the days' production activities. 9. All flight activities will be logged. 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 11. The flights will occur in Class G airspace no closer than a Smile radius of the geographic center/ Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius of the geographic center/ Airport. 13. The operator will fi le FAA Form 77111, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 14. The operator will obtain v erbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety dete rmination, as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 15. The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate by voice and/or radio at all times. 17. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabili ty to return to a predetermined location w ithin a designated location and land autonomously. 19. The UAS will have the capability to abort a flight in case of emergencies with an automated "Return Home and Land" function. 20. The UAS will have the capability to abort a flight in case of unpredicte d obstacles, weather, or emergencies such as low battery.
14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescrib ed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the small UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operato r is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be perform ed in accordance with the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure that the small UAS is in working order prior toinitiating flight and perform required mainte nance needed.

**Exemptions wanting relief from:** CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of s afety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement capability, and proximity to airports and populated ar eas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a co nventional aircraft (fixed

- wing or multi

- rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a Pilot nor Observers, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the Operator , pursuant to safety requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional tools. The FAA will have advance notice of all operation s. These safety enhancements, which already apply to civil aircraft operated in connection with Videography and Photography production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airw orthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 CFR §45.23 (B): Marking of the Aircraft The regulation requires: The registration number is displayed on limited, restricted or light

- sport c ategory aircraft or experimental or provisionally certificated aircraft, 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 “provisional,” as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be D placed. Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the Operator (PIC) and Observers and others working with the sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations

- Pilot in Command (PIC) Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a Pilot or Observers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than acommercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the

Operator (PIC) and Observers, the UAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b). 14 CFR §91.7 (a): Civil Aircraft Airworthiness T he regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for det ermining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists and a preflight inspection, all maintenance and alterations will be properly documented in the aircraft reco rds prior to each flight, an equivalent level of safety will be provided. 14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airpl ane or Multi

- rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Multi

- rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 860 7, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700 14 CFR §91.103: Preflight Action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved multi

- r otorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 CFR §91.109: Flight Instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft v ia radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that aircraft. 14 CFR §91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, prov ided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a fixed

- wing or multi

- rotorcraft requests authority to operateat altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which filming

inspections is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 ft. AGL. It will however be operated in restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or multi

- rotorcraft weighing far more than the max imum 55 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 ft. AGL in this industry. In addition, the low

- altitud e operations of the UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an a ircraft 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.” As the small UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 CFR This regulation requires 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 befo re departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the a ltitude of the launch site shown on the GPS altitude indicator before flight. 14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “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 the day, to fly after that for at least 30 minutes; or (2) At night, to fly aft er that for at least 45 minutes.” The battery powering the UAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given th e limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property own ers or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. Additio nally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or25% of battery power whichever happens first. This restriction would be more than adequate return the

UAS to its planned landing zone from anywhere in its limited operating area. 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provi des in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (b) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passen gers or crew. The UAS fully loaded weighs no more than 10 lbs. and is operated without an onboard Pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safet y will be achieved by keeping these documents at the ground control point where the Pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspec tions These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph © of this section, have discrepancies repaired as prescribed in Part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not appl y to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manufactures Manual. An equivalent level of safety will be achieved because these small UASs are very limited i n size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 ft. AGL. As provided in the Manual, the operato r will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. **Publication in the Federal Register** The following summary is provided for publication in the Federal Register, should it be determined that publication is needed. Dezmin Media seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 from the requirements of 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CF R 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR91.417(a) and (b). Thi s exemption request will permit Dezmin Media to operate its UAS device s commercially for the purpose of aerial filming and photographing to include: commercial and residential real estate, infrastructure inspections, construction, architecture, scientific research, environmental assessment, land surveying and mapping. Dezmi n Media will provide a service that is beneficial to industries and organizations that are already using, and/or seeking to use, sUAS’s for these purposes with a legal and safe option. This will benefit the public with the controlled operation of sUASs and increase their integration into the NAS. The requested exemption should be granted because the proposed operation of the small UAS (sUAS) weighing no more than 10 lbs ., inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent or better level of safety, as Congress intended, while still allowing commercialoperations. The lightweight aircraft covered by the exemption is far safer than conventional operations

conducted with helicopters and fixed

- wing air craft operating in close proximity to the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

- each support the request. In particular, the aircraft is small, and will operate at slow speeds, close to the ground, far from airports and in a low risk, low and controlled population environment. Enclo sures:
 DJIS1000 User Manual
 Phantom 2 User Manual
 Cinestar 8 Manual
 GD

- x8 User Manual
 K130 v2 User Manual