PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

December 15, 2015

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Operation West Building Ground Floor Room w

- 12

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



## Petition for Exemption

RE: Petition of On the Wave Productions for an Exemption under Section 333 of the FAA
Modernization and Reform Act of 2012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, LLC., on behalf of On the
Wave Productions for exemption from certain rules of 14 C.F.R. On the Wave Productions requests Exemption in a n effort to be granted permission to operate small Unmanned Aircraft Systems (“sUAS”) commercially in the United States of America. These operations would be subject to the current rules and regulations , not stated herein as rules requested for exemption under Section 333, under the jurisdiction of the Department of Transportation and the Federal Aviation Administration

. Additionally, all operations will adhere to str ict safety rules enforced by On the Wave Productions within their company

. These safety rules will be modeled after recommendations made by t he FAA and community

- based organizations such as the Academy of Model Aeronautics. Specific conditions relating to the safe operations of sUAS by On the Wave Productions will be covered in more detail in the
documentation to come, however basic flight safety parameters often cited by organizations such as the Academy of Model Aeronautics will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach areas to na me a few.



### As was established in Huerta v. Pirker

, an aircraft is, “any” “device” that is “used for flight.” 1 Clearly this broad definition encompasses the types of sUAS the petitioner, On the Wave Productions

, plans on flying commercially within the United States of America and as such, are governed by the rules Petitioner Name: On the Wave Productions Petitioner Contact: Harry Rabin

– Pilot Cert. # 3684221 Petitioner Phone Number: 805

- 886

- 2204 Petitioner Email Address: onthewave@me.com Petitioner Address: 37 Humphrey Road Santa Barbara, CA 93108

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com
We bsite: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 2

of 14 C.F.R. Due to this, in the following Petition for Exemption and associated documentation, On the

Wav e Productions will establish clear reasoning as to why their particular commercial sUAS flights should be granted exemption and why their business should be exempt from certain parameters of 14
C.F.R.

A s has been established by the FAA ov er the last year, sUAS pilots are allowed to petition for exemption from certain aircraft rules that may be inapplicable to sUAS craft or that may place an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. On the Wave Productions would like to request exemption from certain parameters contained in 14 C.F.R. The specific rules for
which On the Wave Productions requests exemption will be covered in further detail in th e documentation to come, but, in summary, On the Wave Productions looks to be exempt from the types of rules that may limit or otherwise prevent their intent of operating sUAS commercially within the
United States.

Furthermore, t hese commercial operations would only be conducted after a granted Section 333 Exemption and within the outlined conditions below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Letter

. With the approval of this exemption, On the Wave Productions will be allowed to commercially operate their sUAS within the United States of America. Specifically, On the Wave Productions will be allowed to fly commercially with the DJI Phantom 3 Professional, DJI Inspire 1

, and DJI Matrice 100

. Furthermore,
On the Wave Productions will be opera ting their sUAS in furtherance of various applications within the following industries; Cinematography

, Closed

- Set Filming, Environmental Protecti on , Fire

, Law
Enforcement

, and Search and Rescue

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, alo ng with these sUAS flight applications, will be expanded upon in
more detail below.

In addition to On the Wave Productions ’s Petition for Exemption pertaining to the use of the
aforementioned aircraft and use

- cases, the gr anting of this Petition will also allow for the commercial operations of sUAS in Clas s G Airspace, below 400 feet Above Ground Level (“AGL”) , nationwide, or as
otherw ise granted in a Certificate of Authorization (“COA”). To start, On the Wave Productions will adhere to the blanket Certificate of Authorization that is granted to each entity receiving an Exemption Number. This COA currently allows for flights nationwide, in Class G Airspace, below 200 f eet AGL. 2 Further flight areas sought by On the Wave Productions will be applied for through the FAA’s COA Portal. Additionally, with the potential hazards and obstacles associated with low

- a ltitude flight

, On the
Wave Productions will adhere to the Visual Flight Rule (“VFR”) minimums which apply to this airspace. Further details on these operational minimums will be discussed in the documentation to come.

In ad dition to the v ariety of Industry

- spaces highlighted above, this Petition for Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications. Specifically, On the Wave Pr oductions will incorporate a variety of sensor payloads on its sUAS in an effort to capture necessary imagery or data types for each specific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not limited to ; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infrared Imagery, LIDAR, Se nsor Technologies , GPS Guidance, Photogrammetry, Semi

- Autonomous and Autonomous Flight Controllers (For safety), Object Avoidance Systems, and more. With t he data collected from these various sensor payloads, On thePETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 3

Wave Productions will be able to provide high quality information and imagery to representatives from the below

- highlighted industries.

 Cinematography: High resolution video can provide a new perspective of a product for potential buyers. By providing an aerial shot to the director of a commercial shoot, these video marketers can more effectively represent a company’s product, which in turn returns value to that commercial customer and provides for a stronger economy through increased demand for products and services.

 Closed

- Set Filming: High resolution video can provide new vantage points for television and movie producers looking for the perfect shot. By providing a sUAS as a tool to capture high definition aerial vantage points, the Petitioner can give customers new ways of filming their movie scenes and television cu t

- aways, thereby improving their end

- product.

 Environmental Protection: High resolution video and imagery captured from the sky can provide various Environmental g roups with more information on their area of study. Near Infrared imagery for example can be used to determine plant stress or deforestation.

 Fire: High resolution imagery captured from the air can help fire departments better assess ongoing fire situations. This c an help the department more effecively fight an ongoing fire and in some situations help the department decide whether or not to approach a blaze that co uld present various hazards.

 Law Enforcement: High quality, high resolution imagery and aerial video can help law enforcment agencies in a wide array of application s, including searching for escapees, documenting accident scenes, and assessing ongoing situations from the air to name a few.

 Search and Rescue: High quality, high resolution imagery and aerial video can provide an incredible vantage point from which search and rescue teams can more effectively scope out an area. Furthermore, with the ability to stitch still images and georeference data, Search and Rescue teams can more effectively map the areas they have already search and more efficently direct their resources to lesser searched areas.

The applications highlighted in this petition obviously p rovide high quality data to a variety of interested parties in vari ous industries. However, sUAS have more to provide than just interesting pictures and efficient operations. There is also the enhanced safety sUAS provide not only for the operators of th ese systems, but also, the people around them, communities as a whole, and the National Airspace System (“NAS”).

Within this Petition for Exemption you will find that the applications highlighted above along with the aircraft systems utilized by On the Wave Productions , satisfy the conditions highlighted by the Federal Aviation Administration as requirements for a successful Section 333 Exemption Petition

. 3 Specifically, the sUAS operating in f urtherance of the industry applications above should;

1. Provide a benefit to the public as a whole, and;PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 4

2. Not adversely affect safety.

To answer these requirements this Petition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as show the positive affect these operations will have on safety. Specifically, it will be shown that the commercial sUAS flights proposed in this Petition further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aerial Vehicle (“UAV”) Intervention

. 4 Basically, the “D” list provides a description of situations in which an unmanned vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial operation is going to be; Dull, Dirty, Dangerous, or Deep

. 5 This list is often associated with early military applications utilizing UAV’s. The UK Ministry o f Defense for example has used th is list in determining the role of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is ; 5

 Dull

- flights require persistence or repetition.  Dangerous

- flights carry a high deg ree of risk.  Dirty

- flights must be carri ed out in hazardous environments, or;  Deep

- flights are beyond the range of manned platforms.

In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of
U AV Intervention and safety attributes of the sUAS Operations proposed in this Petition for Exemption, it is also important to quickly consider the aircraft types utilized by On the Wave Productions

.

As mentioned above, On the Wave Productions seeks exemption for the utilization of the DJI Phantom 3 Professional, DJI Inspire 1

, and DJI Matrice 100

. All of these aircraft ar e small Unmanned Aircraft Systems and are battery

- powered. Operations conducted by On the Wave Productions with these sUAS will adhere to the guidelines set forth by the Federal Aviation Administrat ion and Community

- Based Organizations such as the Academy of Model Aeronautics (“AMA”). Through the adherence of these guidelines On the Wave Productions will c ommercially operate their sUAS with an equivalent level of safet y, if not superior level of safety, as outlined by the Federal Aviation Administration’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by On the Wave Productions in this
Petit ion for Exemption would produce far safer methods of data capture than currently

- used collection methods in which manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of metal, are powered by a combus tion engine, car ry flammable fuel, and are carrying people. Plus, with the type of data

- capture proposed in this Petition, a manned aircraft would have to operate in high

- risk situations, including, in close proximity to the ground where the risk of an accident is highes t and the risk to people and property on the ground is the greatest. Contrasting the two aircraft types, it is clear that a plastic, battery powered, unmanned vehicle operating at low altitudes, would be much safer than a multi

- thousand pound metal aircra ft, powered by a combustion engine, and carrying a person at low altitudes.

This fact is furt her bolstered by the operational and aircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 These directives include ;

1. The size of the aircraft
2. The weight of the aircraft
3. The speed of the aircraftPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 5 4. The operational capability of the aircraft
5. The aircraft operation’s proximity to airports
6. The aircraft operation’s pr oximity to populated areas , and;
7. The aircraft operation’s adherence to Visual Line of Sight Rules

As highlighted above, it is clear that this Petition for Exemption and both the aircraft types and applications state d herein, strictly adhere to the operati onal and aircraft

- specific parameters highlighted by the FAA for a successful Exemption Petition and thus, support the granting of this Exemption. A summary of the reasoning behind this statement can be found below as;

1. All proposed sUAS are Small
2. All proposed sUAS weigh below 55 lbs.
3. All proposed sUAS travel at less than 100 mph (87 Knots)
4. All proposed sUAS are capable flight systems and have been granted Exemptions previously
5. All proposed operations will take place at least 5 miles from an Airport
6. All proposed operations will take place in unpopulated area s (U nless prior approval is given {See Condition #34 [“ Proposed Conditions of the Exemption ”] below})
7. All proposed operations will adhere to the Visual Line of Sight Rules

By adhering to t he parameters published by the FAA and by promoting the public good through the various Industry applications to be highlighted below, this Pe tition for Exemption on behalf of On the Wave Producti ons s trongly supports the granting of this Exemption.

We kindly ask for your consideration of this Petition for Exemption. Please see the table of contents below for all our documentation and for assistance in reviewing this Petition. Thank you for y our efforts in reviewing this document and we look forward to your response. If you have any questions while reviewing this document please do not hesitate to ask. You can contact the Preparer of this document for all questions relating to this petition and they can be reached at 1

- 608

- 370

- 2858 or by email at dmzaerial@gmail.com . Further contact information can be found at th e top of this Petition or on the following website s; www.dronefly.com or www.dmzaerial.com . Once again thank you for your efforts in reviewing this Petition for Exemption and we look forward to your reply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 6



## Contact Information

Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com

Petitioner:

On the Wave Productions 37 Humphrey Road Santa Barbara, CA 93108 Harry Rabin

– Pilot Cert. # 3684221
805

- 886

- 2204 onthewave@me.com



## Disclosure

The Petitioner for this exemption is On the Wave Productions

, a film company that provides production and post services for the film industry in both the indep endent and feature film markets. Additionally, On the Wave Productions also provides these services to the television industry and for government agencies including NSF, NOAA, and USGS. On the Wave Productions also produces its own films and TV shows mostly in the environmental/documentary based sectors. In addition, On the Wave Productions produces safety films for the oil industry and has worked with companies like Exxon and Mobile to produce training films for their employees.

On the Wave Productions purchased document preparation services through Dronefly, Inc. for the purpose of petitioning the FAA to be allowed to fly their Small Unmanned Aircraft Systems commercially within the United States. Dronefly Inc., contracts DMZ Marketing, LLC. also known as DMZ Aerial, to help formulate these documents and work with the customer to help promote safe flying practices and appropriate operations. This is done through questionnaires, phone conversations, documen t preparation, training module creation, and more. If you have any questions relating to the Petitioner, Dronefly, Inc. or DMZ Marketing, LLC. (“DMZ Aerial”), please do not hesitate to contact us using the contact information provided above.PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 7



## Table of Contents

Petition for Exemption

................................ ................................ ................................ ............................ 1

Contact Information

................................ ................................ ................................ ................................ 6

Disclosure

................................ ................................ ................................ ................................ ................ 6
The Applicant

................................ ................................ ................................ ................................ ........ 10
Commitment to Safety

................................ ................................ ................................ ...................... 10
Experience and Expertise

................................ ................................ ................................ ................... 11

Privacy

................................ ................................ ................................ ................................ ............... 12
Publishable Summary

................................ ................................ ................................ ............................ 12

Petitioner’s Contact Information

................................ ................................ ................................ ........... 14
Proposed sUAS Operations

................................ ................................ ................................ .................... 15
Small Unmanned Aircraft Systems

................................ ................................ ................................ ..... 15

DJI Phantom 3 Professional

................................ ................................ ................................ ............ 15

DJI Inspire 1

................................ ................................ ................................ ................................ ... 16

DJI Matrice 100

................................ ................................ ................................ .............................. 16
Unmanned Flight Crew

................................ ................................ ................................ ...................... 17
Unmanned Flight Conditions

................................ ................................ ................................ .............. 17
Unmanned Flight Operations

................................ ................................ ................................ ............. 18
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ... 19
National Security

................................ ................................ ................................ ................................ ... 19
Proposed Conditions of the Exemption

................................ ................................ ................................ .. 19
Exemptions Requested & Applicable Conditions/Reasoning

................................ ................................ ... 26
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .......................... 26

14 C.F.R. 2 7: Airworthiness Standards

- Normal Category Rotorcraft

................................ .................. 26
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ............... 27
14 C.F.R. 43.11: Dispositions of Records for Inspections

................................ ................................ ..... 27
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ... 27
14 C.F.R. 45.23(b): Display of Marks; General

................................ ................................ ..................... 28
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ .......... 28

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ............ 28

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

................................ .......... 29
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duration

................................ .... 29PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 8

14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ......... 30
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command

.......................... 31
14 C.F.R. 61.315(a) (c): Privileges and Limits of Sport Pilot’s License

................................ ................... 32
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ..................... 35
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ................. 36
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ............... 36
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ....... 36
14 C.F.R. 91.105: Flight Crewmembers at Stations

................................ ................................ ............. 37
14 C.F.R. 91.109: Flight Instruction

................................ ................................ ................................ .... 38
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ............................. 39

14 C.F.R. 91. 119: Minimum Safe Altitudes

................................ ................................ ......................... 39
14 C.F.R. 91.121: Altimeter Settings

................................ ................................ ................................ ... 40
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ...................... 42
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ..................... 42
14 C.F.R. 215: ATC Transponder and Altitude Reporti ng Equipment and Use

................................ ..... 43

14 C.F.R. 91.403: General

................................ ................................ ................................ ................... 45
14 C.F.R. 91.405(a): Maintenance Required

................................ ................................ ....................... 45
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ .................... 46
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ .............................. 46

14 C.F.R. 91. 417(a) and (b): Maintenance Records

................................ ................................ ............. 46

Privacy

................................ ................................ ................................ ................................ .................. 48
Public Interest and Safety

................................ ................................ ................................ ...................... 48
Cinematography

................................ ................................ ................................ ............................ 49

Closed

- Set Filming

................................ ................................ ................................ ......................... 51

Environmental Protection

................................ ................................ ................................ .............. 53

Fire

................................ ................................ ................................ ................................ ................ 55

Law Enforcement

................................ ................................ ................................ ........................... 57

Search and Rescue

................................ ................................ ................................ ......................... 59
Regulations Requested for Exemption

................................ ................................ ................................ ... 61
Appendix 1: Regulations Requested for Exemption

– List

................................ ................................ ... 61

Exhibit List

................................ ................................ ................................ ................................ ............. 61
Exhibit 1: On the Wave Productions Operations Manuals

................................ ................................ .. 61
Standard Operations Manual

................................ ................................ ................................ ......... 62PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

Motion Picture and Televisi on Operations Manual

................................ ................................ ......... 62
Exhibit 2: On the Wave Productions Logbook Example

................................ ................................ ....... 62
Exhibit 3: On the Wave Productions Visual Observer Training Procedures & Guide

............................ 62
Visual Observer Training Procedures

................................ ................................ .............................. 62
Visual Observer Training Guide

................................ ................................ ................................ ...... 63

Exhibit 4: On the Wave Productions Pilot In Command Training Guide

................................ ............... 63
Pilot In Command Training Procedures

................................ ................................ .......................... 63
Pilot in Command Training Guide

................................ ................................ ................................ ... 63

Exhibit 5: DJI Phantom 3 Professional

................................ ................................ ................................ 63

Exhibit 6: DJI Phantom 3 Professional User Manual

................................ ................................ ............ 63

Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

................................ ................................ .... 63

Exhibit 8: DJI Phantom 3 Professional Features

................................ ................................ .................. 63
Exhibit 9: DJI Phantom 3 Professional Specifications

................................ ................................ .......... 64
Exhibit 10: DJI Phantom 3 Professional Flight Controller System

................................ ........................ 64
Exhibit 11: DJI Phantom 3 Professional Smart Battery Manual

................................ ........................... 64

Exh ibit 12: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

................. 64
Exhibit 13: DJI Inspire 1

................................ ................................ ................................ ...................... 64
Exhibit 14: DJI Inspire 1 User Manual

................................ ................................ ................................ . 64
Exhibit 15: DJI Inspire 1 Quick Start Guide

................................ ................................ .......................... 64

Exhibit 1 6: DJI Inspire 1 Features

................................ ................................ ................................ ....... 65
Exhibit 17: DJI Inspire 1 Specifications

................................ ................................ ................................ 65
Exhibit 18: DJI Inspire 1 Flight Controller System

................................ ................................ ................ 65
Exhibit 19: DJI Inspire 1 Smart Battery Manual

................................ ................................ ................... 65

Exhibit 20: DJI Matrice 100

................................ ................................ ................................ ................ 65

Exhibit 21: DJI Matrice 100 User Manual

................................ ................................ ............................ 65

Exhibit 22: DJI Matrice 100 Features

................................ ................................ ................................ .. 65
Exhibit 23: DJI Matrice 100 Specifications

................................ ................................ .......................... 65
Exhibit 24: DJI Matrice 100 Smart Battery Manual

................................ ................................ ............. 66

References

................................ ................................ ................................ ................................ ............ 66
Exemption References

................................ ................................ ................................ ........................... 67

MPTOM Reference

................................ ................................ ................................ ................................ 68PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 10



## The Applicant

The Applicant seeking this Exemption is On the Wave Productions , headquartered at;

37 Humphrey Road Santa Barbara, CA 93108

On the Wave Productions is a film company that provides production and post service s for the film industry in both the independent and feature film markets . Additionally, On the Wave Productions also provides these services to the television industry and for government agencies including NSF, NOAA, and USGS. On the Wave Productions also produces its own films and TV shows mostly in the environmental/documentary based sectors. In addition, On the Wave Productions produces safety films for the oil industry and has worked with companies like Exxon and Mobile to produce trai ning films for

t heir employees.

On the Wave Productions has a highly skilled and versatile staff with over 100 years combined experience in the film industry. From commercials to documentaries to Indie and feature films, On the Wave Productions can provide everything needed for a full

- scale cinemographic production. Furthermore, the company's founder, Harry Rabin, brings a unique set of skills, experience, and expertise.

Mr. Rabin attended the University of California

- Santa Barbara majoring in Biomedical and Electr ical Engineering and Dramatic Arts. He has worked in the capacity of writer, director, cinematographer and producer on dozens of documentaries, Live Concert venues, Indie and Feature Films. As a recognized technologist for cinema workflow and camera hardw are, he has developed and built numerous camera support gear and even an underwater HD capable ROV from scratch. His latest projects included working with Mike deGruy for James Cameron and National Geographic's “Deep

- sea Challenge 3D” and consulting and p roviding footage for Sylvia Earle’s Mission Blue feature documentary which opened the 2014 Santa Barbara International Film Festival. Additionally, Mr. Rabin has worked as an official advisor and liaison between University, Community, and Government entit ies like NOAA, UCSB Marine Sciences OCTOS program, Channel Islands National Marine Sanctuary, Monterey Bay National Marine Sanctuary, Board of Directors DOT GREEN Community and Producer and advisor to Academy of Underwater Arts and Sciences.



### Commitment to Safety

At On the Wave Productions, safety is paramount and for this reason, all personnel involved in film work, whether it be aerial or ground

- based, receive training and have taken safety classes pertaini ng to potentially hazardous environments in which they may be filming. Examples of the types of classes taken by participating personnel include, for example, classes on the effective use and application of respirators, the effective use of personal toxic monitoring devices, and the like. Furthermore, all safety rules and procedures are posted per OSHA requirements at On the Wave Production Facilities. Continued training has also been a big component of On the Wave Production safety practices, with the

c ompany utilizing outside safety

- training entities when further training is required. Additionally, On thePETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 11

Wave Productions trains all personnel in the safe use of camera support gear such as cranes and automobiles, by teaching them best practices. In a h ighly precise environment like a film shoot coupled with highly expensive camera equipment, it is vital for all participating personnel to utilize safe practices not only for the safety of themselves and those around them, but also for the business, whose sustainability is dependent on safe operations and accident

- free work environments.

It should also be noted that On the Wave Productions and its founder, Harry Rabin, are hyper

- focused on safety as some of the business' productions take place in potentiall y hazardous environments, including near or within the ocean, around industrial structures, and the like. For this reason, On the Wave Productions has routinely employed safety practices to minimize any potential risks associated
with the environments in which they shoot. As an example, the business always employs a Safety diver for every shoot happening within a body of water. This practice shows how the business has navigated previous, hazardous environments, like the ocean, and also demonstrates their commitment to safe operations through the utilization of additional safety personnel if needed, in future shoots. This may be a requirement for shoots including the deployment of a UAV, as additional Visual Observers may make the flight more safe. As is highlighted in this petition for exemption, On the Wave Productions will always utilize at least a two

- person flight crew consisting of a licensed Pilot In Command and a Trained
Visual Observer.



### Experience and Expertise

The Team behind On the Wave Productions is highly experienced. Harry Rabin, the founder of the company and the person behind this Petition for Exemption

, has been a cinematographer working in the film industry for over 15 years. He ha s worked on feature films such as Terminator 3, Bernie, and more. Additionally, he has also worked as a cinematographer on National Geographic and Discovery channel shows providing footage on land, in the air, and underwater on shows such as Mission Blue, When Sharks Attack, Shark Week, and Deep

- sea Challenge 3D with James Cameron. Clearly, Mr. Rabin is a highly experienced filmmaker and his work by land, air, and sea in the past shows his versatility across multiple filming environments. Mr. Rabin's kno wledge and extensive experience in the world of cinematography bolsters his request for exemption under Section 333 in that it shows his ability to utilize various types of equipment and effectively manage a film crew consisting of many moving parts

t hat a ll need to be kept safe to accomplish the task at hand.

This type of experience transitions nicely to the world of aerial cinematography and the use of UAV's for filming in general. This is clear when you consider the same types of skills necessary to o perate a ground or underwater shoot, in which many potential hazards are present, are also required for a successful UAV deployment. There are many tools in use at once, such as the UAV, the controller, the ground station, and the like, but also, there ar e many people operating at once as well, with cameramen, directors, produce r s, and the like. For these reasons and for numerous other reasons that will be expanded upon in the Petition to follow, it is clear that On the Wave Productions should receive

an exemption number from the FAA.

Furthermore, it should also be noted that Harry Rabin, the founder of On the Wave Productions, has extensive experience in conservation and environmental protection. Mr. Rabin has worked andPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 12

volunteered his time with numerou s conservation and environmental groups. In fact, he is currently on the board of Reef Guardians (reefguardians.org), a scientific based nonprofit that works with local communities, universities, business groups and government to study the rapid changes t o coral reefs, surf breaks, beaches, coastal communities and wetlands. In addition, Mr. Rabin is also involved with the National Oceanic and Atmospheric Association as an advisor and liaison with the California Marine Sanctuary Foundation. Mr. Rabin was also the Director of Photography and Producer working on a grant from the National Science Foundation to document the Deepwater Horizon oil spill. On this particular mission, Mr. Rabin provided footage on the environmental disaster from 5000 feet down in the Alvin DSV, a manned submersible owned by the U.S. Navy and operated by the Woods Hole Oceanographic Institution, that provided critical scientific data regarding the use of dispersants and their effect on marine life. Furthermore, Mr. Rabin provided e xpertise as an expert advisor regarding the use of drones, such as the AeroVironment PUMA and DJI UAV systems, by NOAA that are deployed for monitoring both marine life and Cargo/Freighter traffic in the Channel Islands National Marine Sanctuary.

With re gard to the fire and rescue services application contained in this petition for exemption, Mr. Rabin and On the Wave Productions also has experience in this sector. In fact, Mr. Rabin produced First Responders and worked hand in hand with Fire departments in California and Hawaii documenting rescues and emergency response teams portraying their duties and their safety programs. Related to this, Mr. Rabin has also participated in local search and rescue efforts searching for missing volunteer firefighters.

Finally, Mr. Rabin also has significant aerial experience as he has been flying single engine and multi

engine aircraft for over 30 years and has a private pilots license. Due to this he is fully aware of all applicable FARS, rules and regulations rega rding piloting an aircraft. Additionally, Mr. Rabin is currently completing his IFR written exam, which will allow him to fly under Instrument Flight Rules as well as Visual Flight Rules while piloting manned aircraft

. Mr. Rabin’s Pilot Certification N umber for his Private

License is # 3684221.



### Privacy

In terms of privacy, On the Wave Productions requires any area involved in the action of flying a UAV to obtain film footage, an information statement regarding the activity. For an y individual(s) that may be captured on film, On the Wave Productions provides an onsite information and release form that is easily filled out digitally and a copy automatically emailed to the participant. All captured imagery is secured on a backup On t he Wave Productions system and not stored publicly or in the cloud. Furthermore, it is not distributed for public use.



## Publishable SummaryPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 13

DMZ Marketing, LLC. files this petition for exemption on behalf of On the Wave Productions

, a film company that provides production and post services f or the film industry, television industry, and for government agencies including NSF, NOAA, and U SGS. On the Wave Productions also produces its own films and TV shows mostly in the environmental/documentary based sectors. In addition, On the Wave Productions produces safety films for the oil industry and has worked with companies like Exxon and
Mobil e to produce training films for their employees.

On the Wave Productions is seeking exemption from certain parameters of 14 C.F.R. in orde r to commercially operate sUAS within the United States in the following industries ; Cinematography

, Closed

- Set Filming, Environmental Protection

, Fire

, Law Enforcement

, and Search and Rescue

. Specifically, On the Wave Productions requests exemption from the following Federal Aviation Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft
3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products

6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C.F.R. 4 5.27: Marking of the Aircraft

– Rotorcraft
8. 14 C.F.R. 45.29: Size of Marks
9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations

10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5): Recr eational Pilot Privileges and Limitations
12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command
13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

15. 14 C.F.R. 91.9 (b)(2): Civil Aircraft Flight Manual

16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

17. 14 C.F.R. 91.103: Preflight Action

18. 14 C.F.R. 91.105: Flight Crewmembers at Stations
19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Right

- of

- Way Rules
21. 14 C .F.R. 91.119: Minimum Safe Altitudes

22. 14 C.F.R. 91.121: Altimeter Settings
23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required
25. 14 C.F.R. 215: ATC Transponder and Altitude Re porting Equipment and Use

26. 14 C.F.R. 91.403: General
27. 14 C.F.R. 91.405(a): Maintenance Required

28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

29. 14 C.F.R. 409(a)(1) and (2): Inspections

30. 14 C.F.R. 91.417(a) and (b): Maintenance RecordsPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 14

The approval of this Petition for Exemption would allow for the commercial operation of small Unmanned Aircraft Systems by On the Wave Productions

. These commercial operations would strictly
adhere to all Federal Aviation Admini stration rules and regulations not stated herein as rules requested for exemption. The commercial operations flown by On the Wave Productions , if this Petition were granted, would be flown utilizing one of the following airc raft platforms; the DJI Phantom 3 Professional, DJI Inspire 1

, and DJI Matrice 100

. Specifically, the commercial operations utilizing t hese unmanned
aircraft would center around the following industry applications; Cinematography

, Closed

- Set Filming,
Environmental Protection

, Fire

, Law Enforcement

, and Search and Rescue

. Additionally, all the industry applications highlighted above would include one or more of the unmanned
aircraft noted above

, flying no more than 400 feet A bove Ground Level (“AGL”) o r in airspace otherwise

spec ified in a granted Certificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to On the Wave Productions because th e operation of the listed sUAS will provide for commercial operations while maintaining an equivalent level of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the small Unmanned Aircraft utilized by On the Wave Productions will provide methods of aerial data
collection far safer than the alternative of manned aircraft collection of the same data sets. Low altitude
data

- collection flights, in close proximity to people and property, are f ar safer when accomplished using a battery

- pow ered sUAS weighing less than 10 lbs., than with a combustion

- engine

- powered, multi

thousand pound, manned aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted by the FAA as paramet ers for successful Section 333 Exemption Petitions, including; Size, Weight, Speed, Operational Capability, Proximity to Airports, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’s

re quest for exemption relating to each operational and aircraft

- specific parameter . Specifically, the aircraft utilized by On the Wave Productions are in the small

- size category as they are below th e 55 lbs. weight class, they travel at less than 100 mph, they are proven flight platforms based on previously granted petitions, all operations will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise granted permis s ion by the FAA in a granted Certificate of Authorizatio n), and all flights will be conducted within Visual Line of Sight.

In addition, the data collectio n flights provided by the sUAS highlighted in this Petition will promote safer operations for profess ional service providers in the aforementioned industries.



## Petitioner’s Contact InformationPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 15



## Petitioner:

On the Wave Productions Harry Rabin 37 Humphrey Road Santa Barbara, CA 93108
805

- 886

- 2204 onthewave@me.com



## Document Preparer:

DMZ Marketing, LLC.
1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com



## Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will permit the Petitioner to operate the DJI Phantom 3 Professional, DJI Inspire 1

, and DJI Matrice 100

. Further operating characteristics, specifications, and other important craft

- specific information on the DJI Phantom 3 Professional, DJI Inspire 1

, and DJI
Matrice 100 are covered in detail starting with Exhibit 5 . Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption
under Sect ion 333. In the aircraft summaries below , please see the references to previously granted petitions for the use of each specific aircraft type in commercial operations within the United States

.



### DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional Quadcopter for commercial use within the United State s of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Professional has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed
of 16 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold PositionPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 16

 Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phantom 3 Professional

- Specific Exhibits below for more information on the DJI Phantom 3 Professional craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these su pporting documents for the commercial use of the DJI Phantom 3 Professional in the following listed Exemption;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A



### DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Insp ire 1 has a weight of 2935 grams including the battery payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Ver tical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the DJI Inspire 1 craft, its specifications, abilities, and more. Additionally , please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exem ption Number 11587/11587A  Phillip Stiles

– GPS Development, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,

ATO

- Issued COA’s, and the like. The DJI Matrice 100 has a maximum take

- off weight of 3400 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral directionPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

For easy reviewing, please see Matrice 100

- Specific Exhibits below for more information on the DJI Matrice 100 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following listed Exemptions;

 Dan Pham

– Alert5 I nternational, LLC.

– Exemption Number 11814



### Unmanned Flight Crew

The unmanned flight crew ope rating On the Wave Productions flight craft for purposes of commercial operations within the United States under this proposed Exe mption will consist of a Pilot I n Command (“PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously granted Sect ion 333 Exemptions, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U.S. Driver’s License

. 7 Additionally, both the PIC and VO will be trained in
the o peration of sUAS prior to commercial operations. Furthermore, any new information surrounding the aircraft’s efficient, effective, or safe operations, will be disseminated by On the Wave Productions to both the PIC and VO to ensure continued safe flights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight training with the specific sUAS craft they are using for their commercial operation and will be required to receive annual continued educatio n and training moving forward. A specific PIC Training Presentation is contained in the exhibits below and will accompany this Petition for Exemption.

The Visual Observer will also have completed specific trai ning relating to the ir duties during an unmanned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.



### Unmanned Flight Conditions

As has been described above, the sUAS use proposed by the Petitioner in this Petition for Exemption
under Section 333 revolves around the following industries; Cinematography

, Closed

- Set Filming,
Environmental Protection

, Fire

, Law Enforcement

, and Search and Rescue

. Each of these industry applications will be described in further detail below under the “ Unmanned Flight Operations ” Title.

Moving on from the specific use cases, it should also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise permitted in a granted Certificate of Authoriz ation. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model

Aeronautics

. 6 Additionally, the PIC will only operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on severalPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 18

standing classifications developed by the Federal Aviation Administration. These include operations being condu cted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, On the Wave Productions will strictly adhere to the FAA’s V isual

F light R ule s, an d obviously, to be following Vis ual Flig ht Rules, On the Wave Productions will have to first satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary between Visual Meteorological Con ditions, which allow for Visual Flight Rules, and Instrument Meteorological Conditions, which require Instrument use. Specifically, On the
Wave Productions will be considering the VMC Minima pertaining to Visibility, Cloud C eilings, and Cloud Clearances associated with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner will only operate when visibility is at least 3 statute miles from the PIC and at a
minimum of 500 feet below and 2 ,000 feet horizontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the flight crew will always make an assessment of the current situation for each, specific fli ght. This assessment will conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds that the flight will be too dangerous or that there are too many hazards
or risks associat ed with the flight, the flight crew will not take off. Furthermore, in order to maintain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permission is granted to the Petitioner by the landowne r, property owner, or other controlling representative. All current FAA regulations not covered within this petition will be followed as well as all local and state rules surrounding flights near or around people. Additional information on the
parameters dictating flights near people can be found below in the “ Proposed Conditions of the Exemption .”



### Unmanned Flight Operations

When conducting commercial flight operations under the pro posed applications in this Petition for Exemption , a commitment to safety will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, it will be vital for all flights to be safe for
several reasons , including;

 The safety of the On the Wave Productions Flight Crew will be necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the aircraft will be neces sary for continued commercial endeavors.

Furthermore, in an effort to supply the Cinematography

, Closed

- Set Filming, Environmental Protection

, Fire

, Law Enforcement

, and Search and Rescue industries with valuable data, it will be imperative for all
On the Wave Production s flights to be conducted in a safe and professional manner so as to not risk the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or property operating in the National Airspace System or on the ground below.

To ensure the safe and professional execution of each sUAS flight, all flights will be conducted utilizing at least a two person flight crew. This flight crew will consist of an adequately

- trained (“ Unmanned FlightPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 19

Crew ” ) PIC and VO. For specifics pertaining to the standard operating procedures utilized by the Petitioner under the proposed Petition for Exemption and for more details on training, please see
Exhibits 1

- 4

.


## Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Section 333 Exemption Guidelines, Petitioners for Exemption must show that their proposed commercial sUAS operations provide a level of safety at least equal to that provided by the rule from which the Petitioner seeks an exemption

. 6 As will be highlighted below, the request for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of sUAS by the Petitioner, using the previously stated flight crafts and operating within the above

- stated

use

- cases under the rules, regulations, and limitations stated herein, should be permitted under the proposed exemption. Reasoning for this can be derived from the strict adherence to e xisting regulations from the Federal Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the existing rule.



## Nationa l Security

In addition to the arguments supporting the Petitioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commerci a l sUAS flights, will not present a national security threat. As has been stated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUAS must hold, at minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been subject to a security screening by the Department of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks already pr ovided by the FAA and Department of Homeland Security in ensuring secure aircraft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in order to identify ind ividuals that may pose a threat to transportation security and coordinate countermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport Pilot Certified, it can be assumed that adequate security checks by the TSA and FAA have taken place prior to a sUAS Pilot conducting commercial operations.

Additionally, Mr. Rabin, the Founder of On the Wave Productions and one of the company’s designated PICs, has been a pr ivate pilot for over 30 years , flying both single engine and multi

- engine aircraft. This extensive experience shows Mr. Rabin’s knowledge of the National Airspace System and demonstrates his trustworthiness as a Pilot.


## Proposed Conditions of the ExemptionPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 20

As is noted by the Federal Aviation Administration in their, “Section 333 Petition Guidance & Checklist

, ” 3 Section 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions and
Limitatio ns Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exemption closely follow this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish a framework from which the petitioner, On the Wave Productions , will conduct their commercial sUAS operations under a granted petition for exempti on.

1. Proposed operations using Small Unmanned Aircraft Systems in the United States under the granted form of this Petition for Exemption will be limited to the following aircraft, which all weigh less than 55 pounds including batteries and operational/ technical payloads; DJI Phantom 3 Professional, DJI Inspire 1

, and DJI Matrice 100

. Furthermore, any aircraft outside of this comprehensive list for this Petition for Exempti on will have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new flight platform (s)

.

2. The proposed use

- cases/applications contained within this Petition for Exemption under Section
333 are as follows ; Cinematography

, Closed

- Set Filming, Environmental Protection

, Fire

, Law
Enforcement

, and Search and Rescue

. All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an
ATO

- issued Certificate of Waiver or Authorization.

3. All flights conducted by On the Wave Product ions will be below 400 feet AGL, operated within Visual Line of Sight, and have a live, GPS

- based, read

- out of altitude during the flight. Furthermore, each flight will begin with a “Zero Altitude” start point, thus creating an accurate
AGL calculation

.

4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or equivalent valid U.S.A. Driver’s license and a trai ned Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 knot (100 mph) airspeed maximum, highlighted by the FAA in their guidelines.

6. All flights conducted by On the Wave Productions will be conducted within Visual Line of Sight, during daytime flying hours, and adhere to Visual Flight Rules under the Visual Meteorological Conditions associated with 400 foot AGL airspace.

7. The Petitioner will not allow any PIC to o perate a sUAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Minimum

- Sport Pilot’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating t o safe sUAS operations, such as;

a. Evasive ManeuversPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 21 b. Emergency Actions

c. Fail

- Safe Knowledge
d. Flight Skills
i. Maintaining adequate distances from;

1. People
2. Property
3. Structures
4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R . 61.51(b). Additionally, a record of the PIC training will be documented and made available upon request by the Administrator.

9. Training operations will only be conducted during dedicated training sessions. During training, all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distance from nonparticipants in accordance with 14
C.F.R. 91.119.

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be allowed to operate the camera or other instruments on the sUAS during flight operations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera operator.

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this, once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her designation as the PIC through the duration of the flight. Furtherm ore, the PIC is the Captain of the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by On the Wave Productions will be planned for ahead of the flight date. This will be to ensure adequate time for all participants to prepare and to obtain all the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. All flights will be preceded by a meeting at least one day before the flight at which all participants of the flight will be present. This is to ensure adequate knowledge and preparedness prior to the sUAS flight.

13. Aircraft maintenance is obviously vital for any commercial sUAS op eration. It ensures safety and is necessary prior to each flight to maintain safe, efficient, and effective flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight. T he PIC will likely have the most experience of anyone on the flight crew and will be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, includin g the Ground Control System for example, he/she would ground the flight until adequate maintenance is completed and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating them.PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

14. Relating to the above Condition, anytime a flight

- critical component is replaced or anytime there is mission

- critical maintenance on the craft, the PIC will conduct a flight test of the system before completing the intended, commercial mission. Once again this flight test will be logged by the PIC.

15. Routine maintena nce and inspections of the sUAS will be logged by the PIC in accordance with the requirements and suggestions laid out by the aircraft m anufacturer in terms of aircraft component maintenance, overhaul, replacement, inspection, and life limits, which are part of the supporting documents for each aircraft below in the aircraft

- specific exhibits . The logging of these maintenance/inspection checks will be included in the aircraft records and include the total time of service and description of work.

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by any device other than corrective lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communication range. The use of other devices to communicate out of verbal range are not permitted. These devices would include, cell phones, text messaging, walky

- talkies, and the like.

17. No com mercial flight missions will be executed unless it can be determined that the flight crew can complete their mission from take

- off through landing, with a reserve of 25% battery life. The Petitioner’s newest flight crafts have adaptive battery monitors an d

, for this reason

, this condition will be an automated process as the Petitioner can set the default Advisory and Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted battery and engage him/her to fly home and lan d with 25% remaining power. For all On the Wave Productions systems without this automated feature, a watch will be used to monitor flight times to ensure a safe return home with adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generation flight crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize a Smart Battery System.

18. In the case of an unexpected obst acle or in

- flight issue, each sUAS the Petitioner operates will have the ability to abort a mission and take corrective actions.

19. The sUAS utilized by On the Wave Productions will be programmed so that if the sUAS loses
si gnal with the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS location located within the operating area containing the flight crew. Furthermore, this failsafe can also be used in controlled situations, meaning t he failsafe will be able to be engaged should something happen on the ground that disallows the PIC from bringing the sUAS back in a normal fashion. Additionally, in both situations described above, where the failsafe is either a controlled action from th e pilot or an uncontrolled situation, like radio

- link signal loss, the unit will not only fly back to its preprogrammed home point, it also has the ability to land itself. This allows safe operations of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown location.PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the aircra ft anytime the sUAS is operating. Furthermore, these documents will be available for review by the Administrator or other law enforcement officials upon request and are additionally contained in Exhibit 1, with appropriate links to the specific flight man uals of each flight craft requested in this Petition for Exemption.

21. It is always important to specify precedent when determining operating practices. For this reason, if a discrepancy exists between the conditions laid out in this Petition for Exempti on and the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption will take precedent over the conditions laid out in this Petition. Furthermore, if there are no discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Operating Documentation below. Additionally, if any changes are made to the Operating Procedures and Documentation contained in this Petition for Exemption, the Petitioner will present the upd ated docu ments upon request to the Administrator. Also, should the Petitioner determine that an update or change to the procedures or documentation would affect the basis of the approved version of this Petition for Exemption, the Petitioner will either file for a n amendment to the existing Exemption or create a new Petition with the
revisions.

22. As has been noted, the Petitioner will obtain written , digital, and/or oral permission from the landowners, farmers, property owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all required permissions and permits from territorial, state, county or city jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organiz ation (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March of 2015 for flights below 200 feet to all Sec tion 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner after receiving their Section 333 Exemption Number

.

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace requireme nts established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potential;PETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 24 c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference point as noted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with a NOTAM as required by the Operator’s COA.

28. As stated previously, the Petitione r will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet horizon tally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide

, or as otherwise advised in an ATO

- issued COA.

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number which will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that so long as the markings are as large as practicable given the size of a sUAS, an equivalent level of safety can be achieved.

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“FCC”). For this reason, prior to commercial operations under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agency rules and regulations.

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned
aircra ft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC is necessary for safe operations. It is for this reason that the Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These vehicles would include things like;

a. Cars/Trucks/SUVs b. Boats

c. Tractors d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all nonparticipating people, vessels, vehicles, and structures, unl ess the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapnel or debris should there be an accident. Furthermore, should a nonparticipant leave this safe

- zone, the PIC will end the flight

.

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of these properties. In addition to permission, the PICPETITIONER

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c. Non

- participants become official participants by consenting to be involved in the film or television produ ction and they adhere to all the guidelines stated within the Petitioner’s Motion Picture and Television Operating Manual (“MPTOM”).

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, accident, or flight oper ation that occurred outside the horizontal and vertical boundaries of the operational area as defined by the COA under which the flight was operating. Furthermore, the Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, each PIC that is designated as being a potential candidate f or flying a sUAS while towing an object will be required to undergo additional training, on top of their required training and certifications, that will consist of 10 hours of training flights while towing objects. These objects will be dummy banners that weigh no more than the max weight allowable to satisfy the max takeoff weight specifications as highlighted by the manufacturer for each flight craft. Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC adequ ate training time and experience while towing objects with specific flight crafts. This will be necessary to familiarize each PIC with each specific flight craft in order to learn how specific flight craft respond to towing objects, particularly with rega rd to downwash and wind. Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by the manufacturer for each flight craft. Training in these conditions will hon e the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high wind. When conducting actual commercial flights while towing objects, the Petitioner will not conduct flights in conditions where sustained
win ds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for each aircraft.

37. The Petitioner for this Exemption is requesting permission to operate sUAS for the purposes of commercial, closed

- set filming. Due to this the Petitioner will submit a Motion Picture and Television Operations Manual (“MPTOM”) along with this Petition.

38. Relating to the MPTOM, the Petitioner will submit a writte n Plan of Activities to the local Flight Standards District Office (“FSDO”) with jurisdiction over the area of proposed filming, at least three days prior to conducting commercial flights. As referenced in previous grants for exemptions of Closed

- Set Film ing, the three day notification period may be waived with concurrence of the FSDO. Furthermore, the Plan of Activities paperwork submitted to the FSDO will include at least the following;

a. Date and Times for all flights, b. Name and Phone Num ber of the Opera tor of the sUAS Aerial Filming,PETITIONER

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– DMZ Marketing, LLC. 26 c. Name and Phone Number of the person responsible for the on

- scene operation of the sUAS, d. Make, Model, and Serial or N

- Number of the sUAS to be used,

e. Name and Certificate Number of sUAS PICs involved in the aerial filming, f. A s tatement that the operator has obtained permission from the property owners and/or local officials to conduct the aerial filming with the list of those who gave the

perm ission available upon request to the inspector,

g. Signature of the Exemption Holder or Re presentative, and; h. A description of the flight activity, including maps and diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes necessary to accomplish the operation.

39. Flight operations may be condu cted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the Exemption Holder’s
MPTOM.



## Exemptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes procedural requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are a ll applicable to this particular Regulation and the FAA has found in favor of exempting previous Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R. Furthermore, it is the belief of the Petitioner that a sUAS operating wi thout an Airworthiness Certificate but within the conditions stated above would provide an equivalent level of safety to an aircraft operating with an airworthiness certificate not subject to the above conditions or limitations.

Additionally, all the sUAS proposed within this Petition for Exemptio n are small, weigh less than 10 lbs, have a flight speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are
electric

- powered, are operated below 400 feet, are operated at least 5 mil es from an airport, and are flown within unaided, visual line of sight of a trained and licensed Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the proposed aircraft have safety features equivalent to and superior to conventional
aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).



### 14 C.F.R. 27 : Airworthiness Standards

- Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for
airworthiness ce rtification of Normal Category Rotorcraft. Due to the fact that the proposed aircraftPETITIONER

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contained within this Petition for Exemption are multi

- rotor aircraft, the Petitioner seeks exemption from 14 C.F.R 27 for the same reasons stated in the request for exe mption from 14 C.F.R. 21(h).



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration Personnel

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel authorized to approve aircraft, airframes, aircraft engines, propellers , appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. Proposed conditions 13 and 14 are applicable to this particular regulation and the FAA has found in favor of previous Exemption

#1 1208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or otherwise licensed personnel to sign off on an u nconventional flight craft’s maintenance. More clearly, it would be difficult to find a mechanic that specializes in Cessna Repair that is also an expert in small
radio

- controlled multi

- rotors.

Additionally, it is likely that the operator of the sUAS (t he PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mechanic as they likely have past RC flying experience. Particularly, the PICs working for the Petitioner will always have at least 25 hours of RC craft experience,
in which time they will likely have to repair a prop for example. Due to the relative ease of replacing props on a multirotor (screw the broken one off and replace with a new one) it is not necessary for a certified or authorized individual to sign off on th e repair. Instead, the repair can easily be done by authorized personnel working for the Petitioner so long as the conditions and procedures stated above, are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F. R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the disposition of Records for Inspections. Proposed condition number 13 pertains to this particular re gulation and the FAA has found in favor of previous Exemption #11208 which contained this rule. For the reasons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petit ioner that they be exempt from 14 C.F.R. 43.11.



### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing of aircraft and major aircraft components, including, but not limited, a ircraft bodies, aircraft engines, and aircraft propellers. This particular rule requires various procedures for marking each component with fireproof markings and, in a manner acceptable to the Federal Aviation Administration, for purposes of
identificati on. Proposed Condition for Exemption #30 above, pertains to this particular regulation and the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30PETITIONER

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(“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.



### 14 C.F.R. 45.23(b) : Display of Marks; General

Title 14, Part 45, Section 45.23(b) of the Code of Federal Regulations states that;

 “ 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 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.”

In a previous grant of exemption (Exemption #11062) it was determined by the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) markings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is

sta ted in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be exempt from 14 C.F.R. 45.23(b).



### 14 C.F.R. 45.27 : Marking of the Aircraft

– Rotorcraft

According to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail, the marks required by 14 C.F.R. 45.23.

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, which states that the
Petitioner will mark their aircraft with marki ngs as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.27.



### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of an aircraft;

 Must displ ay on markings on the aircraft meeting the size requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/6 th as thick as the characters are highPETITIONER

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 Not less than 1/4 th the character width  Unifor m

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the
Petitioner will mark their aircraft with mar kings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.29.



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authorizations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains t o the need for a Private Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUAS operator to hold a Private Pilot’s License. Clearly, the goal of this particular ru le is to ensure the skill of any Pilot In Command matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and the training that went into it is not necessarily connected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trained in multi

- thousand pound, manned aircraft, flying at hig h altitudes in comparison t o 10 lbs. or less, battery

- powered craft, operated at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as the requirement of a Private Pilot’s license is unnecessary. Furthermore, it is sta ted as such on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

The authorization of Recreational an d Sport Pilot Certificates as an alternative to a Private License points to a Private License as being a non

- requirement according to the FAA’s integration office. This further evidence shows that the Petitioner should be exempt from the aforementioned re gulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or Sport Pilot’s Certificate yields an authorized level of training according to the FAA’s own website and in turn, shows that such a requi rement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commitment to safety and arguments for exemption from this rule.



### 1 4 C.F.R. 61.23(a) and (c) : Medical Certificates

– Requirements and DurationPETITIONER

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According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of an aircraft is required to hold a Medical Certificate in various Pilot In Command Situations. As is stated in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s license, which has been ruled by the FAA in previously granted exemptions as a suitab le alternative to a valid medical certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and the current FAA Policy displayed below, the Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is consistent with the agency’s approach for sport pilot certificate holders, who may f ly light sport aircraft with a driver’s license and no FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Part 61, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA s tates that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in furtherance of a business.

As can be seen on the FAA’s website (https://www.faa. gov/news/updates/?newsId=82485);

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that they should be exe mpt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Propose d Condition #4 above, it is the intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate.PETITIONER

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Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to fly for compensation.

Furthermore, as is stated on the FAA’s own website and as is highlighted below ;

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private

p ilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highly likely that many potential PICs will have these Certificates as they are less costly and easier to obtain than a commercial Pilot’s License as an example. For these reasons, it is clear that the Petitioner should be granted an exem ption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations

– Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) th rough (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command o f an
aircraft.

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial sUAS flights in the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as such they will be operatin g an aircraft (the sUAS) for compensation or hire under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pilot’s license

, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is for
th e expressed purpose of conducting commercial operations of s UAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptio ns to businesses and individuals looking to provide commercial/compensation

- based sUAS flights.

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:PETITIONER

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 The flight is only incidental to that business or employment; and  The aircraft does not carry passengers or property for compensation or hire.

The Petitioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Additionally, the specific provision pertaining to not flying aircraft that carry property for compensation or hire is something the Petitioner would like to be exempt from as well

. Various forms of property may be carried on a s UAS, including; Camera Systems, Digital Imagery,
Sensors , and the like.

For all these reasons

, the Petition er seeks exemption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and L imits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragr aph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.

(2) For compensation or hire.

(3) In furtherance of a busines s.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in
14 C.F.R. 61.325.

(8) Outside the United States, unless you have prior authorization from the country in which you seek to operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO require ments.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a passenger

- carrying airlift sponsored by a charitable organization.PETITIONER

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(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, wh ichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without visual reference to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §61.327(a) or have logged flight time as pilot in command of an airplane with a VH less than or equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.

(16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other limit or endorsement from an authorized instructor.

(17) Contrary to any restr iction or limitation on your U.S. driver's license or any restriction or limitation imposed by judicial or administrative order when using your driver's license to satisfy a requirement of this part.

(18) While towing any object.

(19) As a pilot flight cre wmember on any aircraft for which more than one pilot is required by the type certificate of the aircraft or the regulations under which the flight is conducted.

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)( c). Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 3, 9, and 18. Furthermore, the Petitioner believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditions of the Exemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.

Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both unnecessary burdens on the Petitioner as well as an equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained below.

Subpart (1) of 14 C.F.R. 61.315 (c) states that a Sport

- Certified Pilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. They will not be carrying any pass e ngers as they are flying Unmanned Systems, and;
2. There will be situations in which the Petitioner carries property for compensation.PETITIONER

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The most likely of these situations will happen when a Petitioner is carrying a device or measurement tool owned by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the act ual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. This compensation is related to the risk of loss while the camera is operating on the Unmanned System as

we ll as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible to obtain if th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) are utilized on unmann ed systems. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the information t he client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned by the
Petitioner.

Furthermore, it is the belief of the Petitioner that an e quivalent level of safety would be provided if exempt from this rule because of the extensive trai ning the PIC would have on the s UAS prior to flying commercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’s or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and unmanned aircraft
traini ng to successfully operate the s UAS without endangering the public. The training procedures and training materials for the PIC can b e fou nd in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart (2) which states that an operator with a Sport Pilot’s License may not operate an aircraft for compensation. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into the National Airspace System. Furthermore, in numerous previously filed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate.

This statement, combined with the initiative behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of the idea that commercial UAV operations can be conducted by people who hold a recreational or sport pilot certifi cate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 61.315 (a)(c), which states that a Sport

- Certified Pilot may not operate an aircraft in furtherance of a business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not required by your business or employment, would be considered “in furtherance of a business.” 10

Clearly, based on this description, an aerial operation that is “in furtherance of a business” would be considered a lesser form of commercialization than flights for hire or compensation as these types of flights are incidental to a business as opposed to directly related to the business, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exempt from this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).PETITIONER

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On top of subparts (1), (2 ), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certified Pilot may not operate an aircraft to demonstrate that aircraft for sale. The Petitioner seeks exemption from this rule as they will b e carrying an inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet will turnover from time to time as new aircraft are added and old aircraft are released by the company. In this event it will be important for the Petitioner to have the capability of showing off the aircraft to prospective buyers so that they can get the best price for their used systems. Plus, with PICs already being heavily trained and experienced with comm ercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective buyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC already performs on a fr equent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport

- Certified Pilot may not operate an aircraft while towing an object. It is the belief of the Petiti oner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeoff weight specifications highlighted by the manufacturer. These max takeoff weights are the maximum weight these aircraft can carry (inc luding themselves) and still fly effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to maintain or come under the max takeoff weight specifications highlighted by the ma nufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which objects are tow ed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and additional training necessary for a PIC to become an Object Towing PIC shows the skills that would be required to tow objects.

Furthermore , with the continued innovation in the world of sensors, it will be necessary for the Petitioner to be able to tow objects, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might measure air quality , ca pture imagery, or perform vari ous other data collection task s. Competing vehicles for these tow

- behind sensors would include ATVs, Motorcycles, watercraft, Manned Aircraft, and the like. All of these potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered by combustion engines, and carry flammable fuel. Additionally, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).



### 14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may ope rate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11062, 11063, and 11064, which
contained this rule. For the reasons stated i n Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed condition offers an equivalent level of safety as is c urrently provided by the existing rule.PETITIONER

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### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight Manual

Title 14, Part 91, Section 91.9 (b) (2) of the Code of Federal Regulations states;

No person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any
combination thereof

.

Pro posed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemption s #11062, 11063, and 11064, which contained a request for exemption from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers an equivalent level of safety as is curre ntly provided by the existing rule as the Operating manuals about which this rule pertains are available to the operator at all times on the ground, just as they would be if the aircraft was carrying the operator. Thus, any information the operator desire s about the aircraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digital device, such as a Smart Phone or tablet , easily accessible to the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Pla cards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Conditio n 30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the FAA has previously determined that exemption from these requirements is warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart c, if the mar kings are as large as practicable.” 11



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

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and for ecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;PETITIONER

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(b) For any flight, runway lengths at airports of intended use, and the follow ing takeoff and landing 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; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.103. Furthermore, the proposed conditions offer an equivalent level of safety as is currently provided by the existing rule as Preflight Planning is integral to the Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather, power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations s tates;

(a) During ta keoff and landing, and while en route, each required flight crewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with ph ysiological needs; and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.

Proposed Condition #4 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For the reason stated in Condition #4 (“ Proposed Conditions of the Exemption ”) above, it is the belief of thePETITIONER

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Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really apply to the Petitioner ’s aircraft as all the aircraft requ ested b y the Petitioner weigh below 10 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehicle where a prospective crewmember would harness themselves in. Instead, all operations of the sUAS are

exec uted from the ground from a designated operating area, in which, each crewmember has an assigned position at which they will stand during the operation. Generally, this standing area would be near the ground station for the PIC and in a pre

- designated are a (which is determined by the PIC) for the VO. Utilizing pre

- determined standing areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Flight Instruction

Title 14, Part 91, Section 91.109 of th e Code of Federal Regulations states;

(a) 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. However, instrument flight instruction

may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has determined that the flight can be conducted safely; and

(2 ) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of f ixed, dual controls may be used for flight instruction to conduct a flight review required by§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b) , and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determin ed the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless

—
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class r atings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; andPETITIONER

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(3) Except in the case o f lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

—
(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class rat ings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in
command of the aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FA A has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“ Proposed C onditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 14 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an
aircraft so as to see and avoid other aircraft. When a rule of t his 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.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favo r of previous Exemptions which contained a request for exemption from this rule, including Exemption #11238. For the reasons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”) above, it is th e belief of the Petitioner that they be exempt from 14 C.F.R. 91.113(b). Due to the fact that all the Petitioner’s sUAS operations will take place under the guidance of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalent level of safety as is provided by the existing rule.



### 14 C.F.R. 91.119 : Minimum Safe Altitudes

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:PETITIONER

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(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Ov er any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitud e of 500 feet above 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.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helic opter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Conditions #3, 6, 25, 26, 28, 29, and 34 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the
reasons stated in Condi tions #3, 6, 25, 26, 28, 29, 34 , 3 7, 38, and 39 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with equi valent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousa nds of pounds, carries flammable fuel, and is powered by a combustion engine. Clearly, carrying out a mission utilizing a sUAS would provide for a safer operation than would a
conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Sett ings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, w hen operating

—
(1) Below 18,000 feet MSL, to

—PETITIONER

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– DMZ Marketing, LLC. 41 (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minim um altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000PETITIONER

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Proposed Condition #3 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which c ontained a request for exemption from this rule based on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft was operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altit ude
read

- out. For the reasons stated in Condition #3 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,

GPS

- Altitude read

- out on each flight, they are operating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3, each flight conducted by the Petitioner will begin with a zero

- altitude start point.



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

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) 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 the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better measure for safety when using a sUAS because the current battery capa cities achieved by these types of ve hicles (including all the sUAS proposed in this Petition for Exemption) often do not allow for flight times of over 25 minutes, which is
far less than even the reserve time limits mandated by 14 C.F.R. 91.151(a). For th e reasons stated in Condition #17 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of saf ety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:PETITIONER

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(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a c opy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21 .197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter

. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district o ffice.

(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 provided for in§ 47.31(c) , or a registration certification issued under the l aws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit
entrance so tha t it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a request for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in
hard

- copy form or available through a link on the internet, such as a Goog le Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipment and Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter , ATC transponder equipment install ed must meet the performance and environmental requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of TSO

- C112 (Mode S).

(b) All airspace. Unless othe rwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 40 96 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the applicable pro visions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100

- foot incr ements. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;PETITIONER

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(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 f eet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon or glider may cond uct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designated for a n airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glider

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- nautical

- mil e radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the air space as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic pressure altitude repo rting equipment having a Mode C apability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this particular re gulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements contained in anPETITIONER

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ATO

- Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing
rule and ensure adequate compliance with reporting standards as set forth in the rule.



### 14 C.F.R. 91.403 : General

Title 14, Part 91, Section 91.403 of the Code of Federal Regulations states;

(a) The owner or operator of an aircraft is primarily responsible for main taining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions
for continued airworthiness has been issued that contains an airworthiness limitations section unless
the m andatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator underpart 121 or 135 of thi s chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the su pplemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.405(a) : Maintenance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations state s;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed 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 ;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compli ance with maintenance standards as set forth
in the rule.PETITIONER

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### 14 C.F.R. 91.407(a)(1) : Operation after Maintenance or Alteration

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft tha t has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—
(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter.

Proposed Conditions #13, 14, and 15 pertain to this particular regul ation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C. F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 cale ndar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, P art 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;PETITIONER

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(a) Except for work performed in accordance with§§ 91.411 and 91.413 , 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, preventive maintenance, 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 eng ine, propeller, rotor, and appliance of an aircraft.
The records must include

—
(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 inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, f or each, the method of compliance, the AD or safety directive number and revision 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 ch apter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records 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 operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as isPETITIONER

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provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



## Privacy

When discussing the use of s mall Unmanned Aerial Vehicles the question of privacy frequently comes up. The reason for this is clear

, as small unmanned aircraft, despite their incredible uses as a tool, also have the pot ential to be used for nefarious activities, such as spying for example. This presents a risk to the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that w ould comprise someone’s privacy. Due to these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft responsibly and focus on mitigating any of the potential privacy risks their aircraft creates. The

Petition er is particularly aware of the privacy concerns of individuals and due to this is extremely focused on providing privacy not only for individuals, but also for customers.

In terms of privacy, On the Wave Productions requires any area involved in the act ion of flying a UAV to obtain film footage, an information statement regarding the activity. For any individual(s) that may be captured on film, On the Wave Productions provides an onsite information and release form that is easily filled out digitally and a copy automatically emailed to the participant. All captured imagery is secured on a backup On the Wave Productions system and not stored publicly or in the cloud. Furthermore, it is not distributed for public use.


## Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exemptions there are three main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must submit a request for exemption from a rule or set of rules con tained in 14
C

. F

. R

. that the Petitioner believe s will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from which the Petitioner is seeking a n exemption, and;

3. The Petitioner’s req uest must be in the Public Interest.

To satisfy these main guidelines, the following information will cover the justification of the proposed commercial operations under Section 333 requested by this Petition. More clearly, the following arguments will show how each of the proposed applications/use

- cases are in the public interest and promote safety.

Specifically, the sUAS flights proposed in this p etition will increase safety in the following industrie s; Cinematograph y, Closed

- Set Filming, Environmental Protection, Fire, Law Enforcement, and Search and

Rescue. Furthermore, it wi ll be seen that the use of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achiev ed because of the lower risks associated withPETITIONER

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a small, plastic, battery

- powered sUAS, as compared to a manned, multi

- thousand pound, combustion

engine

- powered, flammable

- fuel

- carrying aircraft. Plus, with most sUAS data capture happening at low altitudes, because of the enhanced da ta resolution possible at low altitudes, customers of sUAS services are getting better, more accurate data, while at the same time the public is avoiding the potentially hazardous practice of ultra

- low

- flying manned aircraft. Cl early, the combination of better, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable commercial operation that promotes the public interest. Evidence of this can be found in the industry

specific example s below

. In addition to the aforementioned safety benefits and promotion of public interest s, it should also be
noted that all the sUAS aircraft utilized by the Petitioner satisfy the directives passed to the Federal Aviation Administration by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabilities, proxim ity to airports, proximity to populated areas, and visual line of sight rules and requirements laid out by Congress. Furthermore, due to the FAA precedent of requiring, at minimum, a Sport Pilot’s Certificate, the FAA can be assured that
all commercial fl ights proposed in this Petition do not pose a threat to National Security as all PIC’s will have already been vetted by the Department of Homeland Security. For these reasons and for the numerous arguments contained herein, this Petition for Exemption pro vides strong justification for approval of commercial operations for the above

- stated sUAS in the above

- stated applications and use

cases under Section 333, pursuant to the operating procedures and requirements described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it is definitive that Congress believ es that the integration of commercial sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving policy that promotes the Public Interest. Thus, in addition to the industry

specific examples below, it should also be considered t hat the integration of all sUAS , pursuant to their safe integration to the NAS and providing of at least an equivalent level of safety as is provided by the current FAA rules, is inherently within the public interest.

Please look below to find more detailed descriptions as to why each of the applications highlighted above can provide a benefit to the public as a whole and r easons why the exemption would not adversely affect safe ty

.



### Cinematography

The Aerial Cinematograp hy Industry has been ope rating for many years to provide cinema

- quality footage from low altitudes. Initially this type of cinematography was captured using fixed wings and helicopters, but in more recent years, the business has started to utilize UAVs. First, large, gas

- powered
unmanned helicopters were used and then, in the last couple years, small Unmanned Aerial Vehicles. The reason the industry ha s transitioned to these small aircraft is because newer UAV systems have been able to capture the quality video the industry is looking for but at a much lower cost and with significantly lower risks.PETITIONER

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One of the reasons manned aircraft cinematography is so expensive is because of the dangers associated with flying a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes and over people. The insurance costs alone for these types of activities are high
and accide nts have happened in the industry. Some of these accidents have even lead to casualties. Earlier this year 10 people died when two helicopters crashed while filming the French Realty Show, “Dropped.” 13 Whenever you have manned aircraft operating at low altitudes there are added risks. These risks include ground structures, confined spaces, and more. Additionally, when you have manned aircraft, any accidents are much more catastrophic than if you had the same situation with unmanned aircraft. Once agai n, this is because of the size of manned aircraft and the flammable fuel carried on

board . A small Unmanned Aircraft does not have the se attributes, plus, because there are no people on board, the chances of causalities is lower because there is no pilot.

It is important to remember that the weight of the UAVs utilized by the Petiti oner will weigh no more
than 10 pounds and contain no cr ew, flammable fuel, or combustion engine. This limited weight and size will significantly reduce the potential for casualties or mass property damage in the case of a crash. Furthermore, the use of electric power by the Petitioner’s UAVs is much more env ironmentally

- friendly than that of a manned aircraft, which is carrying a significant amount of unnecessary weight using
carbon

- based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performing aerial cinematography, there is also the added public benefit of a healthier environment.

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and property, it should be pointed out that a UAV is even safer th an the traditional methods because of the limited size, weight, speed, operating conditions, and safety features included on the proposed aircraft within this petition. Additionally, as is highlighted in the FAA Modernization and Reform Act of 2012, the i ntegration of UAS into the National Airspace System is inherently in the public interest so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the uti lization of sUAS in the Aerial Cinematography Industry falls in line wi th the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– Aerial Cinematography is an in dustry that requires repetitive flights. There are often multiple takes of the same scene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to occ ur several times over a time period. This isn’t necessarily efficient for a manned aircraft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in between
shots and use s significantly less power. Plus, because of the in herent risks of flying at low altitudes for manned aircraft (structures, people, obstacles, etc.), repetitive shots require repetitive risky flight operations.

 Dangerous

– Aerial Cinematography is almost always done at very low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore aerial cinematography flights using manned aircraft are more dangerous than if the same manned aircraft were operati ng at higher altitudesPETITIONER

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with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some aerial cinematography is extreme in nature and may include things like airborne obstacles. While the Petitioner’s UAV system would be maintaining a safe distance from these hazards and remaining within line of sight, it is important to consider that unpredictable accidents can happen in which a b ird might fly into a prop as an example. In this situation it would obviously be better to have a small unmanned craft than a large, manned aircraft, carrying a pilot and flammable fuel. As was seen with the Mircle on the Hudson incident, birds
can have a devastating effect even on the most advanced aircraft if they collide with a prop or are sucked into an engine.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned aircraft can perform, such as flying in extremely close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the follow ing previously granted exemptions point to the FAA’s acceptance of sUAS use in the Aerial Cinematography Industry as being within the public interest.

 Exemption Numbers:

o 11540

o 11153

o 12031



### Closed

- Set Filming

Closed

- Set Filming is an industry in which small Unmanned Systems could play a vital role moving forward. The reasons for this are simple. First, due to the significant advancements in video and image quality capable from many UAVs, the utilization of th ese aircraft and UAV camera payloads are practical in the filming industry. With 4k video capabilities, it is clear that the camera systems available for UAVs today are sufficient for many professional filming applications. Furthermore, when you consider the amount of aerial footage common in many of today’s movies, TV shows, and the like, it is clear that aerial imagery is important to this industry. However, until relatively recently, much of this imagery was captured from manned aircraft such as plane s or helicopters. These methods of aerial data capture are acceptable, however, they come at a much higher cost than unmanned aerial imagery and with many
more risks.PETITIONER

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Once again, it is important to consider the size comparison between manned aircraft an d unmanned aircraft. Where all of the Petitioner’s aircraft weigh less than 10 pounds, most manned aircraft weigh thousands of pounds, carry flammable fuel, and are extremely dangerous in the case of a crash. Unmanned aircraft however are very small and p ose much fewer safety risks than their larger cousins. Additionally, they are significantly less expensive to operate and easier/safer to maneuver in close

proximity, low

- altitude situations, where most closed

- set filming occurs.

The aerial views capa ble with a UAV give productions unique vantage points and unique shots. This is because they can be operated safely at very low altitudes in comparison to manned aircraft. This is the case due to their smaller size and superior operating capabilities whe n in close proximity to people, property, structures, natural features and the like.

Capturing imagery at low altitudes with a UAV provides for increased safety of ground personnel. Furthermore, it provides the public good of allowing low altitude filmi ng with a much less deadly aircraft should an accident occur. Even though these film shoots are closed to non

- participants it is important to remember that some of these flights may take place near non

- participating people and property. In the
case of a crash, it would be much safer for the public for the crashing vehicle to be a small, battery

powered UAV, than a large, multi

- thousand pound, manned aircraft.

Additionally, the utilization of sUAS in the Closed

- Set Filming Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Closed

- Set Filming Industry is an industry that requires repetitive flights. Often, multiple flights m ust be performed over the same area to capture multiple shots of the same scene. This could be performed by a manned aircraft, however, it may be more advantageous to utilize a UAV, especially in situations where a flight with a manned aircraft may be ris ky due
to hazards at low

- altitudes. Although one flight in a manned aircraft over the area might be possible, multiple flights repeatedly expose that aircraft and the pilot to ground

- based threats, which over time expose the aircraft to increased chances of an accident.

 Dangerous

– Closed

- Set Aerial Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Closed

- Set Filming using ma nned aircraft is more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the c ase of a crash.

 Dirty

– Some Closed

- Set Filming is captured in potentially hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is importan t to consider that mistakes can happen in unpredictable situations. A flock of birds for example might quickly change directions and come into contact with the aircraft. Usually this isn’t a big deal, however, larger birds, such as geese or cranes, could significantly damage a manned aircraft by breaking a prop, damaging a window, or being sucked into an engine. Each of these situations is dangerous for the crew onboard.PETITIONER

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Therefore, it is the belief of the Petitioner that this same type of impact with a small UAV would
be safer than a manned aircraft because in the worst case scenario there isn’t the loss of human life or significant damage to property on the ground as the sUAS weighs below ten pounds and doesn’t carry flammable fuel.

 Deep

– S ome Clo sed

- Set Filming might require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impos sible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in
the Closed

- Set Filming Industry as being within the public interest.

 Exemption Number:

o 13779



### Environmental Protection

Environmental Protection and Conservation are a vital component of a healthy planet. Throughout the years many conservation efforts have been made based on environmental research captured from the air. Imaging from these elevated altitudes gives research ers on the ground a different vantage point which allows for more detailed information of a broader area. Much like aerial imagery experts in the Agricultural Industry, conservationists use many of the same aerial imaging techniques, including, multispect ral imagery, visible light spectrum imagery, image stitching, 3D mapping, and more. The data sets that can be captured using these various techniques allows for researchers to develop action plans on how to best address potential environmental concerns. It is for this reason that the Petitioner seeks an exemption under Section 333 in an effort to provide services to the Conservation Industry. Clearly, the use of any aerial imagery device is helpful in the fight to protect the environment but especially

w hen that device is inexpensive, efficient to operate, rapidly deployable, safe to operate, and produces a low carbon footprint.

All of these attributes are associated with the types of small unmanned aircraft utilized by the Petitioner. Due to this, it is the Petitioner’s view that the utilization of sUAS in the Conservation Industry is within the Public Interest, as it provides the public good of a healthier planet. Additionally, it is the
belief of the Petitioner that the use of sUAS in the Conservati on Industry would also provide an equivalent level of safety as is provided by current rules governing manned aircraft.

For many years manned aircraft have been utilized to execute a variety of tasks in the Conservation landscape, including, taking popul ation counts of species, examining environmental disasters such as oil spills, taking multispectral imagery to observe invasive species growth, and much more. These types of applications typically require a vehicle that can fly, a couple humans to operate the craft and manage the sensors, and some sort of sensor payload that may include devices such as visible and multispectralPETITIONER

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cameras as an example. This is clearly a large operation and potentially a very expensive one in terms of time and money. Consid er the fact that to own or rent a manned aircraft is highly expensive for the average conservationist. Additionally, consider that many of the types of businesses that operate in this

space are non

- profits who may not have the budgets to fund a full

- scale flyover with an actual plane. Plus, with many of these businesses being donation

- based, their budgets may fluctuate from year to year based on the economy. This could potentially make it very difficult to perform multi

- year studies in which multiple fli ghts over multiple years must be flown. In a good year these example non

- profits might be able to swing it but in bad years, when their donations are down, they may have difficulty funding these manned flights and therefore, may need to end the study or m ove forward with incomplete data.

A small unmanned aircraft, such as the one flown by the Petitioner, avoids many of the pitfalls mentioned above relating to manned aircraft. From a monetary perspective, consider the fact that many small unmanned aircra ft cost less than $5,000, meaning for a one

- time fixed cost, a conservationist can obtain a rapidly deployable, aerial imaging device, that has very low running costs (as it is battery powered). This is a huge advantage for the personal conservationist or the non

- profit. Additionally, from a time standpoint, a sUAS is rapidly deployable, meaning a user can take it out of its case and literally be imaging an area of interest in a couple minutes. This helps in many situations, but especially those situatio ns that are fast moving. In the case of an environmental disaster as an example, the Petitioner may want to capture the immediate aftermath which is likely not possible for a manned aircraft as you have to rent planes ahead of time. Also, in any situatio n where animals are involved, a rapidly deployable system is key. This is because a species that is being target for imaging may be rare and the opportunity to snap a photo is very short

- lived.

From a safety standpoint as well, sUAS provide a safe means of image capture. First, a sUAS is unmanned, meaning if there is a loss of the aircraft due to some sort of accident, only the aircraft is damaged and not the pilot and crew inside, as is the case with manned aircraft. Additionally, because
the sUAS is small and battery

- powered, it poses a lesser risk to people and property on the ground than does a manned aircraft that weighs thousands of pounds and carries flammable fuel. Furthermore, the type of imagery sought by the Petitioner is imagery that is rel atively close to the ground (always below 400 feet AGL). This is a potentially hazardous environment for any aircraft as the chances of collision with a ground

- based object, feature, or structure are significantly increased. Due to this, it is the belief of the Petitioner that it would be safer to have a small unmanned aircraft operating in this sort of environment as it is smaller and has superior maneuverability when compared to a manned aircraft. Finally, it should be noted that the type of small unma nned aircraft utilized by the Petitioner is electric powered, meaning it has a lower carbon footprint than a manned aircraft.

On top of this, the utilization of sUAS in the Environmental Protection/Conservation Industry fal ls in line
with the 4D’s of UAS I ntervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Environmental Protection/Conservation Industry is an industry that requires repetitive flights. Often, as is the cas e in other industries that capture research

- based imagery, multiple flights must be performed of the same area with multiple sensor payloads. This could be performed by a manned aircraft, however, it may be more advantageous to utilize a UAV, especially i n situations where a flight with a manned aircraft may be risky due to hazards at low

-PETITIONER

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altitudes. Although one flight in a manned aircraft over the area might be possible, multiple flights repeatedly expose that aircraft and the pilot to ground

- based threa ts, which over time expose the aircraft to increase chances of an accident. This is particularly the case when it comes to manned aircraft because the chance for human error is possible. When a pilot performs the same dull flight over and over, they may get bored and overlook an obstacle they have previously avoided. This can cause accidents. A UAV on the other hand is a bit more automated, meaning flight routes can be preprogrammed and users have a computer backup.

 Dangerous

– Aerial Conservation Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Conservation flights usin g manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some Conservation Imagery is captured in potentially hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is i mportant to consider that mistakes can happen in unpredictable situations. A flock of birds for example might quickly change directions and come
into contact with the aircraft. Usually this isn’t a big deal, however, larger birds

, such as geese

or cranes , could significantly damage a manned aircraft by breaking a prop, damaging a window, or being sucked into an engine. Each of these situations is dangerous for the crew onboard. Therefore, it is the belief of the Petitioner that this same type of impact with a small UAV would
be safer than a manned aircraft because in the worst case scenario there isn’t the loss of human life or significant damage to property on the ground as the sUAS weighs below ten pounds and doesn’t carry flammable fuel.

 Deep

– S ome Aerial Conservation Imaging might require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned air craft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Environmental Protection/Conservation Indu stry as being within the public interest.

 Exemption Number:

o 13677



### FirePETITIONER

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The Fire Fighting and Fire Response Industries are industries in which small unmanned aircraft will play a vital role moving forward and will offer support services. These industries are known for their rapid response times which are needed in order to save lives and property. Furthermore, the situations and
environments co mmon in these industries require constant visual observance to monitor real

- time changes in a fire’s progression. Currently, much of this is done, especially in forestry fires, using aerial imaging from a manned aircraft flying a safe distance away. The imagery captured on these flights is
vital for t he successful outing of the fire but also for the safety of the people on the ground. A fire can move quickly and change directions on a dime. Due to this it is important for firefighters on the ground
to h ave a constant, real

- time assessment of what is happening aro und them. In most cases a fire fighter may not be able to see everything that is happening around them because they have an inferior vantage point on the ground as compared to the vantage point a n aircraft can capture from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Fire Industry in order to help them in situations where a fire needs to be viewed from the air quickly.
Where a manned aircraft may take a while to get to the scene and expose pilots to a hazardous environment, the type of sUAS utilized by the Petitioner is rapidly deployable, meaning it can be in the air sending a real time feed to a fire captain in minutes. With that information the cap tain can
communicate with his guys on the ground to make sure they don’t get trapped or caught in a difficult situation. This is clearly in the Public Interest as this type of technology keeps firefighters on the ground
safe. For est fires especially, are situations in which firefighters can get trapped if they cannot see where the flames are moving in real time. Back in 2013, 19 elite firefighters were killed in Arizona battling a
forest fire that turned around on them due to a w ind change 14 . Although any aircraft is difficult to fly in
a smoke

- filled situation and the Petitioner will always maintain visual line of sight, an aerial perspective, even from a distance, can be helpful to those on the ground.

While an aerial perspecti ve of a blaze is helpful, the Petitioner understands the value manned aircraft can provide to a fire situation and will not fly the sUAS unless given permission by th e proper authorities and after ensuring they will not be interfering with any manned aircr aft efforts.

In addition to providing the public good of keeping firefighters safe, it should also be noted that the use of a small unmanned aircraft also provides a low

- cost alternative to manned aircraft. This would in turn
drive down the costs to a f ire department for manned aircraft surveillance and potentially help lower the burden on the public who fund the fire departments through taxes.

Furthermore, a UAV is a safer alternative to a manned aircraft in many firefighting situations. This is the

c ase because often these flights will happen at low altitudes where the risk of collision with ground

based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sU AS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety.

On top of th is, the utilization of sUAS in the Firefighting/Fire Response Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Fire Indus try is an industry that requires repetitive flights. Often, especially with
fixed

- wing aircraft, a pilot must fly his plane over a specific area in which the blaze is occurring.PETITIONER

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Due to the fact that planes cannot effectively hover, the pilot must perform the same approach and flyover over and over again in order to keep a constant eye on the situation. The sUAS used by the Petitioner however has the ability to hover in one spot, giving it the ability to maintain
constant visual contact over the area of i nterest. When the pilot of a plane performs the same dull flight over and over, they may get bored and overlook an obstacle they have previously avoided. This can cause accidents. A UAV on the other hand is a bit more automated, meaning
it can hover in place and use its onboard flight controller to automatically adjust for wind and maintain its position.

 Dangerous

– Aerial Fire Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Fire flights using manned aircraf t are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a cr ash as it weighs significantly less and doesn’t carry a
crew or flammable fuel.

 Dirty

– Most Aerial Fire Imagery is captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. If for instance, the wind were to change direction, blowing smoke into the flight path, the pilot of a UAV has automated fail

- safes that will bring the aircraft home automatically. A manned aircraft on the other hand is going to have to rely on a human to get it back safely.

 Deep

– Some Fire Imaging might require capabilities that only an unmanned aircraft can perform, such as flying i n close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally , the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Fire Support Industry as being within the public interest.

 Exemption Number:

o 13677



### Law Enforcement

The Law Enforcement Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is known for its rapid response times which are needed in order to save lives and property. Furthermore, the environments common in this industry require constant visual
observance to monitor real

- time changes in a situation. Currently, much of this is done through the use of helicopters which can provide an aerial vantage p oint in instances of running criminals, hostagePETITIONER

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situations, traffic situations, and more. The imagery captured on these flights is vital in order to communicate with officers on the ground on how to best handle the situation. In many policing

activities you want to be on the high

- ground or have an elevated vantage point from which to assess the conditions below. A UAV can provide this vantage point quickly, inexpensively, and effectively.

The Petitioner seeks exemption under Section 333 in an effort to g ain the right to provide services to the Law Enforcement Industry in order to help them in situations where conditions on the ground need to be viewed from the air quickly. Where a manned aircraft may take a while to get to the scene and expose pilots to a hazardous environment, the type of sUAS utilized by the Petitioner is rapidly deployable, meaning it can be in the air sending a real time feed to the police in minutes. With the information captured during these flights, support personnel can relay inf ormation to officers on the ground in order to make sure they don’t get caught in a difficult situation. This is clearly in the Public Interest as this type of technology keeps police officers on the ground safe.

While an aerial perspective of a police situation is valuable, the Petitioner understands the value manned aircraft can provide to a situation as well and will not fly the sUAS unless given permission by the proper authorities and after ensuring they will not be interfering with any manned aircr aft efforts.

In addition to providing the public good of keeping police officers safe, it should also be noted that the use of a small unmanned aircraft also provides a low

- cost alternative to manned aircraft. This would in
turn drive down the costs to a police department for manned aircraft surveillance and potentially help lower the burden on the public who fund the police departments through taxes.

Furthermore, a UAV is a safer alternative to a manned aircraft in many situations. This is the case
be cause often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like, are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, t hey carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety.

Furthermore, aerial data may be collected more by a Police Department if that department had a low cost solution. This is valuable to the public as more data can lead to better policing which in turn keeps communities safer. Additionally, situations that would be nice to h ave an aerial vantage point but do not warrant the price of higher a helicopter or plane, may be imaged with a UAV. For example, consider a car accident. It would be nice to have an aerial perspective after the accident has happened. Based on the imager y the officers could study the skid marks and determine what exactly happened. Plus, all of the data is then in digital form and can be saved for any future litigation or insurance claims.

On top of this, the utilization of sUAS in the Law Enforcemen t Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Law Enforcement Industry is an industry that requires potentially dull flights. Often, especially with helicopters, a pilot must maneuver their helicopter into position and then hover. Once the pilot begins to hover the actual flying can become dull as the situation on the ground is more interesting. This may take away th e pilot’s attention which could lead to accidents if the helicopter drifts into a ground

- based obstacle, such as a powerline for example. The sUAS usedPETITIONER

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by the Petitioner however has the ability to hover in one spot without human controls, giving it
the ab ility to maintain constant visual contact over the area of interest. This automated function means the UAV can hover in place and use its onboard flight controller to automatically adjust for wind and maintain its GPS position within a few feet.

 Danger ous

– Aerial Law Enforcement Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Law Enforcement flights usin g manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Most Aerial Law Enforcement Imagery is captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance f rom these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. If for instance, a criminal were to shoot at the aircraft, the results would be much less dangerous with an u nmanned aircraft than a manned aircraft because there is no crew to get injured and if the UAV were to crash, the damage would be minimal due to its small size in comparison to a manned aircraft.

 Deep

– Some Aerial Law Enforcement Imaging might require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Law Enforcement Industry as being within the public interest.

 Exemption Number

o 11419



### Search and Rescue

The Search and Rescue Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is known for its rapid response times which are needed in order to save lives. Furthermore, the situations and environment s common in this industry require documented visual observance over broad areas. Currently, much of this is done using aerial imaging from a manned aircraft. The imagery captured on these flights is vital not only when it comes to finding lost people butPETITIONER

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also in documenting areas that have already been searched. In a searching effort this is important because searchers don’t want to waste time looking in areas that have already been searched. Utilizing a UAV allows for searchers to get an aerial vantag e point as well as document areas that have been searched accurately. For instance, a search crew could map the areas of interest using their UAV, stitching the images they get from the camera and have a georeferenced map of the area in question. In

most cases this map is laid over Google Earth and can clearly mark an area that has already been searched. Additionally, because the map is georeferenced, if the user can pinpoint locations or objects of interest and pull a latitude and longitude for a more d etailed search. This is a highly valuable attribute of stitched imagery from a UAV.

In addition, a UAV can provide a superior vantage point for searchers operating on the ground. The UAV utilized by the Petitioner offers long

- range, high definition FPV which can be used by a team leader to relay to his ground searchers where to move next and if he sees anything of interest from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the
Search and Rescue Industry in order to help in situations where a visual inspection from the air is necessary. The Petitioner seeks this exemption because they believe the use of unmanned aircraft in this industry will provide a public good while maintaining the sa fety of the National Airspace System.

The Petitioner’s UAV is rapidly deployable meaning it can help in time

- sensitive rescue efforts. Additionally, with its ability to take high definition video and pictures while georeferencing all of its images, the Petitioner’s UAV can be a valuable asset to a Search and Rescue Team. Plus, with the aerial perspective this type of UAV can provide, the chances of finding a lost or periled individual increase. Clearly, finding and saving lost people is a public good a nd one that can be bolstered through the use of

a UAV.

Furthermore, utilizing a UAV for this type of work is a safer alternative when compared to manned aircraft. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammabl e fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety to the Search and Rescue Industry.

On top of this, the utilization of sUAS in the Searc h and Rescue Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Search and Rescue Industry is an industry that requires dul l flights. Often, especially
with fixed

- wing aircraft, a pilot must fly his plane over a specific area of interest in a very specific and straight line patter. This is to ensure complete coverage of the search zone. This causes the pilot to fly the same straight line routes, one next to the other, over and over. The “dullness” of this flight might cause a pilot’s mind to wander which can lead to accidents. The sUAS used by the Petitioner however has the ability to utilize preprogrammed flight routes, w hich can automate the process and allow for safer operations.PETITIONER

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 Dangerous

– Aerial Search and Rescue Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low
alti tudes and less margin for error. Therefore, Search and Rescue flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alte rnative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Aerial Search and Rescue Imagery is sometimes captured in hazardous envir onments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. For instance, if a UAV is b eing used to provide a live

- feed view of a rescue situation, there may be a host of unpredictable hazards such as rock

- falls, crashing waves, avalanches, or the like. In each of these situations it would be better to have an expendable UAV system rather t han a manned aircraft with lives onboard.

 Deep

– Some Search and Rescue imaging may require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS u se in the Search and Rescue Industry as being within the public interest.

 Exemption Number:

o 11419



## Regulations Requested for Exemption

Appendix 1: Regu lations Requested for Exemption

– List

https://drive.google.com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1: On the Wave Productions Operations Manual sPETITIONER

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### Standard Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMckdEdGVFWVhvdE k/view?usp=sharing



### Motion Picture and Television Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMM011Q2pDOGs3ODg/view?usp=sharing



### Exhibit 2: On the Wave Productions Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The specific flight logs pictured are just an example and not specifi c to the Petitioner’s prior flights. In addition to the logbook, please see the linked video ( https://www.youtube.com/watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utiliz ing the same logging app for each flight.



### Exhibit 3: On the Wave Productions Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/open?id=0B8sknt2zpxhMNFllQVJZdHVsQ0EPETITIONER

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### Visual Observer Training Guide

https://drive.google.com/open?id=0B8sknt2zpxhMbElBZTcwUi02aHM



### Exhibit 4: On the Wave Productions Pilot In Command Training Guide

Pilot In Command Training Procedures

https://drive.google.c om/open?id=0B8sknt2zpxhMNFllQVJZdHVsQ0E



### Pilot in Command Training Guide

https://drive.google.com/open?id=0B8sknt2zpxhMREF0OHZLZ25Jc2M



### Exhibit 5: DJI Phantom 3 Professional

http://www.dji.com/product/phantom

- 3



### Exhibit 6: DJI Phantom 3 Professional User M anual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf



### Exhibit 7: DJI Phant om 3 Professional Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Gu ide_en.pdf



### Exhibit 8: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom

- 3/featurePETITIONER

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### Exhibit 9: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 10: DJI Phantom 3 Professional Flight Controller System

http://www.dji.com/produ ct/phantom

- 3/flight

- system



### Exhibit 11: DJI Phantom 3 Professional Smart Battery Manual

http://download.dji

innovations.com/down loads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 12: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Exhibit 13 : DJI Inspire 1

http://www.dji.com/product/inspire

- 1



### Exhibit 14 : DJI Inspir e 1 User Manual

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf



### Exhibit 15 : DJI Inspire 1 Quick Start Guide

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdfPETITIONER

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### Exhibit 16 : DJI Inspire 1 Features

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 17 : DJI Inspire 1 Specifications

http://www.dji.com/product/inspire

- 1/spec



### Exhibi t 1 8 : DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire

- 1/flight

- control



### Exhibit 19 : DJI Inspire 1 Smart Battery Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 2 0 : DJI Matrice 100

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 21 : DJI Matrice 100 User Manual

http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 22 : DJI Matrice 100 Features

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/features



### Exhibit 23 : DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100 /specsPETITIONER

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### Exhibit 24 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads/dev/Matrice/en/Intelli gent_Flight_Battery_Safety_Guidelines_en.pdf



## References

1.) 

### NTSB. Michael P. Huerta, Administrator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC: National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft Definition.

2.) 

### Administratio n, Federal Aviation. "FAA Streamlines UAS COAs for Section 333." FAA.gov

.

Federal Aviation Administration, 24 Mar. 2015. Web. 5 Nov. 2015.

3.) 

### Administration, Federal Aviation. "Section 333 Petition Guidance & Checklist." (n.d.): n.

pag. FAA.gov . Federal Aviation Administration. Web. Conditions for a successful Exemption.

4.) 

### Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft

Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland:

w ww.mdpi.com/journal/remotesensing, 8 June 2012. PDF. "D's" of Unmanned
Aircraft Use.

5.) 

### SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety. N.p., n.d. Web.

20 July 2015.

6.) 

### Administration, Federal Aviation. "Public Guidance for Petitions for Exemption under

Section 333." FAA.gov . Federal Av iation Administration, n.d. Web.

7.) 

### "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptions. Federal Aviation Administration, n.d. Web. 20 July 2015. Permitting
Recreat ional and Sport Pilot Certificates.

8.) 

### FAR Part 91

- Basic VFR Weather Minimums, Code of Federal Regulations § 91.155

(2004). Print.

9.) 

### Administration, Transportation Security. "Vetting of Airmen Certificates and General

Aviation Airport Access and Security Procedures." Department of HomelandPETITIONER

– On the Wave Productions DOCUMENT PREPARER

– DMZ Marketing, LLC. 67 

### Security . Office of Inspector General, 7 July 2011. Web. 5 Nov. 2015.

10.) 

### MacPherson, Rebecca B. "U.S. DOT / FAA

- Office of the Chief Counsel." Letter to Mr.

Timothy John Gilbert. 25 Feb. 2011. MS. 800 Independence Ave. S.W., Washington, DC, Maryland. Clarification on "Furtherance of a business."

11.) 

### Federal Aviation Administration . "Exemption No. 11062A Regulatory Docket No. FAA

2014

- 0352." Department of T ransportation, 23 July 2015. PDF

.

12.) 

### Jensen, Warren, PhD. Ground

- Based Visual Observer/Crewmember Training for UAS

.

New York, NY: Slideserve.com, 9 July 2008. PPT. Visual Observer and Pilot In Command Training Guidance and Format.

13.) 

### "Olympic Medalists among 10 Dead as Reality TV Choppers Collide." NBC News

.

NBC, n.d.Web. 20 July 2015.

14.) 

### “ 19 Firefighters Killed in Arizona Blaze; 'Our Entire Crew Was Lost'

- CNN.com." CNN

.

Cable News Network, 2 July 2013. Web. 27 Nov. 2015.



## Exemption R eferences

Exemption # 11467

Exemption # 11905

Exemption # 11797

Exemption # 12031

Exemption # 11865

Exemption # 11364

Exemption # 11587

Exemption # 11857

Exemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 11345PETITIONER

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– DMZ Marketing, LLC. 68



## MPTOM Reference

1.) 

### H5 Productions, Inc

. Motion Picture and Television Flight Operations Manual.

Scottsdale

, AZ: H5 Productions, Inc., 2 Dec. 2015

. PDF.