Household Media Group, LLC

Derek Darmstaedter 3225 Hidden Creek Dr. Antioch, TN 37013 (615) 669

- 7551 derek.darmstaedter@gmail.com Date: October 26, 2015 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey Ave., SE Washington, DC 20590 RE: Petition of Perch Photograph y, LL C for Exemption Pursuant to Section 333 of the FAA Reform Act Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11 , Household Media Group, LLC, operator of Small Unmanned Aircraft Sy stems (“sUASs”) equipped to conduct aerial photography and videograph y, hereb y applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required b y Section 333.1 As described more full y below, the requested exemption would permit the operation of s mall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited (2) predetermined and (3) controlled. The proposed exemption, if granted, would allow Household Media Group, LLC to conduct commercial operations of small unmanned aircraft sy stems (“UAS”) meeting or exceeding all of the operational and safet y requirements Congress has set forth in Section 333. Page 2 Household Media Group, LLC is a media/technology company owned and run by

Derek Darmstaedter. Mr. Darmstaedter has been active in Radio Controlled Aircraft for the past 3 y ears with experience rotary wing aircraft. Household Media Group , L LC plans to exploit the capabilities of Unmanned Aerial Sy stems to offer a multitude of services, including:

- Aeria l surveying

- Event Photograph y/ Videograph y

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photograph y

- Construction site inspections and monitoring
Statutory Authorit y Section 333, titled “Special Rules for Certain Unmanned Aircraft Sy stems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine ifcertain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “exped ited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations. The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested: 14 C.F. R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. ( 91.401

- 91.417) Unmanned Aircraft Sy stem sUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safet y. We are petitioning for exemption to enable Household Media Group, LLC to operate a DJIInspire 1 upgraded to the latest firmware and equipped with a three

- axis camera gimbal and using a 4K camera. This sUAS has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator. The Inspire 1 also has the failsafe function of the autopilot sy stem which means when the communication between the Main Controller and the transmitter is disconnected, the outputs of all command sticks from controller will go to the center position. If the GPS signal is good enough, the sy stem will automatically trigger Return to Home and will land safel y. Please refer to the link to the DJ I Inspire 1 Instruction Manu al for the performance limitations and flight operations. http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf Aircraft weight is 104oz. with battery , 3 Axis Camera Gimbal and Camera A Pre

- flight inspection will be performed b y the PIC in accordance with the factory instruction manual. An added step will be the inspection of the propellers. A propeller will be replaced if it has any nicks and cracks with a manufacturers authorized propeller. The sUAS will be mai ntained in accordance with the manufacturers instruction manual and only manufacturer's authorized replacement parts will be used.**FCC	Information**

This DJIC1 transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) This device may

not cause harmful interference, and (2) this device must accept an y interference received, including interference that may cause undesired operation. The DJ I C1 radio transmitter use d for controlling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GH z to 2.4835GHz frequency range. Antenna Separation Distance when operating our DJ I C1 transmitter, the PI C will maintain a separation distance of at least 5 cm between his bod y (excluding fingers, hands, wrists, ankles and f eet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.
**Pilot	in	Command and	Observer	Qualifications	and	Duties**  The PI C will maintain at least 2 hours fl yi ng time and 3 takeoffs and landings within 30 day s in the t ype of UAS utilized in operations. The PI C will have at least 50 hours total time and at least 30 hours fl yi ng R adio Controlled Model Aircraft of which will be 10 hours flying sUAS's. Training will be conducted at a local Radio Control Club flying field. Perch Photography has the ability

to provide "dual controls" utilizing two DJ I C1 transmitters with a wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all times be able assume control of the sUAS. The PI C is responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, all procedures including but not limited to: Safe in flight operations Risk Mitigatio n to Persons and propert y Airfield Suitability The Observer must have the visual acuity to observe the sUAV and be able to communicate clearl y with the PI C. The Observers duties are; warning the PIC of an y i mpending obstacles in the flight path of the sUAS. warning the PIC of an y deviations in the planned flight path of the sUAS. warning the PIC should any unauthorized personnel appear in the area of the planned flight. The Observer will have the authorit y to order the PIC to terminate the flight should he feel the flight cannot be conducted safel y.**General	Operating	Standards**

• Household Media Group, LLC will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace s ys tem or the public." • Before an operation of a sUAV within 5NM of an airport with a control tower, the control tower will be called to gain per mission to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. The sUAS will not be operated at an altitude of over 150 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. Before an operation of a sUAS within 5NM of a non

- tower controlled, airport operators will be notified and the PIC will give the right of way to avoid fl yi ng in the proximity of full

- scale aircraft. At no time will the sUAV be operated within the final approach co urse and the takeoff course of any runway . The sUAV will not be operated at an altitude of over 150 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. • Maximum flight time for each operational flight will be a maximum of 25 m inutes. • Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit. • The sUAV will be programmed so that it will not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet abov e an elevated platform from which filming is planned. • Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer. • The sUAV operated b y the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals). • The sUAV will operate at speeds of no more than 60 knots, can hover, and can simultaneously

move vertically

and horizontally

. • Given the small size of the sUAV and the restricted sterile environment within which they will operate, our sUAV operations adhere to the Reform Act's safet y requirements. The UAS, powered b y batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereb y reduce current risk levels and thereb y enhance safety and diminish the likelihood of death or serious bodily injury . With a small payload and maximum flight time of onl y 25 minutes, this is offers little or no risk to national security. Low level oblique photos and video from several angles are far more effective than ground based imagery

for displaying the characteristics of large, complex properties withseveral buildings and large trees. The applicants in the past have chartered 2

- seat full

sized helicopters for this purpose, which has proven more costly than many

potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit man y bu ye rs and sell ers of real propert y. Additionally , we request that we be allowed to use our sy stem to benefit first responders nearb y who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cite d in this application as we do so. (a) No flight will be made with a Gross weight exceeding 15 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no more than 60 knots and no further than 1 NM fr om the PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate b y voice at all times during a flight operation; (d) Operations will be restricted to flights over private property with the permission of th e propert y owner; (e) All required permits will be obtained from state and local government prior to operation; (f) Household Media Group , LLC will not be operated over densel y populated areas; (g) Household Media Group , LLC will not be operating over an y open - air assembly of people; (h) Household Media Group , LLC will not be operating over heavily trafficked roads; **EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY** Household Media Group , L LC requests an exemption from the following regulations as well as an y additional regulations that may technically

appl y to the operation of the sUAV Sy stem: **14	CFR	Part	21,	Airworthiness	Certificates** This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Sy stems, we request an experimental certificate be issued for the DJ I Inspire 1 under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes:**(a) Research	and	development** 

. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, o r new uses for aircraft. **(b) Showing	compliance	with	regulations** 

. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of t yp e and supplemental ty pe certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market survey s, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial p urpose as well. The aircraft will not carry persons or propert y, will not carry fuel, and will only

fly under strict operational requirements. Combined with the UA's light weight, being constructed primaril y of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. I f an experimental airworthiness certificate is not appropriate for this application, then we request an exemptio n of 14 CFR Part 21, Subp art H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety

outlined in the previous paragraph. **14	CFR	45.23	Display	of	marks;	general	and	45.29	Size	of	marks.** These regulations provide that each aircra ft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally , the aircraft must display the word "EXPERI MENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The s UAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safet y b y including the word "EXPERIMENTAL" in the placard on the t op of the aircraft, as shown above, where the PI C (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally , we feel that the permanent placard dis cussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally , we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to any one that observes the aircraft and chooses to investigate its point of origin. **14	CFR	61.113	Private	pilot	privileges	and	l imitations:	Pilot	in	Command	and**  **61.133	Commercial	pilot	privileges	and	limitations.** The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employ ment 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 hi re. Our proposedoperations require that the PI C must hold at least a Private Pilot Certificate with a Class

III Medical issued b y the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) ev en though the intent of this application is to conduct a business. **14	CFR	91.7	Prohibits	the	Operation	of	an	aircraft	without	an	airworthiness certificate**  . As no such certificate will be applicable in the form contemplated b y the FARs, this Regulation is inapplicable. **14	CFR	91.9	Civil	aircraft	flight	manual,	marking,	and	placard	requirements**

. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this req uirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be avail able to the crew during flight operations. To obtain an equivalent level of safet y and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station an yt ime the aircraft is in, or prepar ing for, flight. **14	CFR	91.109	Flight	Instruction;	Simulated	instrument	flight	and	certain flight	tests**  The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has full y functioni ng dual controls." Training will be conducted at a local Radio Control Club flying field. Perch Photography has the ability

to provide "dual controls" utilizing two DJ I C1 transmitters with a wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PI C instructor, utilizing the master transmitter, will be at all times be able assume control of the sUAV.
**91.119	Minimum	safe	altitudes** : General. The regulation states that over sparsel y populated areas the aircraft cannot be operated closer than 500 feet to an y person, vessel, vehicle, or structure. Since the t ypical mission of the sUAS would be photograph y or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only

be flown over propert y or persons where permission has been obtained and careful pre

- planned flight path has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or propert y on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. **CFR	91.121	Altimeter	settings**

. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will alway s fl y below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above thetakeoff point is transmitted via radio from the sUAS on

- board computer to the display

screen held b y the PI C, providing a constantly updated AGL readout. **14	CFR	91.151	Fuel	requirements	for	flight	in	VFR	conditions**

. The regulation provides that no person may begin a flight in an airplane under day

- vFR conditions unless there is enough fuel to fl y to the first point of intended landing and to fly after that for at least 20 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety

buffer for delay s to landing. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 15 minutes with a 20% reserve. Since the aircraft will never fl y more than 1 NM from the point of intended landing, a full battery

charge at launch will ensure that we meet the reserve ene rgy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy ". **14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certifications	required**

. The regulation provides that an airworthiness c ertificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally , subparagraph (b) provides that the airworthiness certificate be "display ed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety

and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information fo und on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. **14	CFR	Subpart	E	(91.401**
**- 91.417)** 
**- Maintenance,	Preventive	Maintenance,**  **Alterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworth y condition, including compliance with part 39 and 43. Paragr aphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PI C perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworth y condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed b y the PI C is limit ed to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility . The PI C will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safet y.**Safety	and	Benefits	of	the	UAS**

Household Media Group , L LC will be using the UAS in a variet y of applications that generall y require expensive full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer m yri ad benefits over the use of full

- sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photograph y, just to name a few. Replacing significantly larger manned aircraft carry ing crew and flammable fuel with small UAS carrying no passengers or crew creates a much gre ater margin of safet y for the pilots and crew. By granting Household Media Group s requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Hou sehold Media Group , LLC is committed to promoting the UAS research efforts of policy

makers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.
**Conclusion** As pointed out in this application, all the SUAs which our compan y would use, under authorization by

the US DOT

- FAA, are small, light

- weight devices operated within the line of sight of the Pilot

- in

- Co mmand (PI C), less than 400 feet above the ground and outside 5 miles from any

airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized e ach flight within a radius of this distance. All our SUAs have proven capability for controlled flight. They are devices offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain that th e studies conducted until now by the FAA, about Section 332, Public L aw 112

- 95, 2014, have already provided y ou with the assurances on the airworthiness of SUAs such as ours. For the foregoing reasons, the exemptions requested herein should be granted an d Household Media Group , L LC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate b y the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some SUAs may

be used for legitimate commercial activities and under reasonably safe conditions. Signed

Derek Darmstaedter Household Media Group , L LC