February 23rd 2016

U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJerseyAvenue, SE., Washington, DC 20590 Intrepid Media 3096 Robin Ln Oak Harbor, WA 98277

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations
Dear Sir or Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Actof2012 (the "Reform Act") and 14

### C.F.R. Part 11, Intrepid Media, seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described UnmannedAerial System called in this application the ME System, which includes an Unmanned Aircraft (UA) and ground stationbased equipment and crew: THE UNMANNEDAIRCRAFT (UA):
-A lightweight (20 lb gross weight with all on-board equipment), manufactured by DJI; Phantom 2 Vision plus that includes the following equipment in flight; -An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based transmitter/controller; ·An on-board camera capable of capturing imagery in the form offull color, high definition still photos and video; -Anon-board telemetry system that delivers flightdatafrom the on-board flight computer to the on-board radio transmitter including altitudeAGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site; -A 2.4GHz on-board radio transmitter that transmits live video from the**on~board** camera plus all the flight datafrom the telemetry system described above;
THE GROUD STATION -BASED PART OFTHE SYSTEM:**~A** Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAwhile in the air; -A2.4GHz radio transmitter/controlleroperated bythe PIC to control the UAwhile inflight; -A radio receiver receiving live video andflight datafrom the on-board camera and computer projects it all together onto a screen for the PIC to view during flight; - A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while in flight.The requested exemption would support an application for a commercial Certificate of Authorization to usethe above described ME System for aerial mapping, surveying, inspections, data acquisition for civil engineering/government agencies, photography, cinematography, emergency management damage assessment and agricultural neveroperating over persons not directly involved with the ME system

. The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, 

### it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death orserious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security.
Low 

### level oblique photos and video from several angles are far more effective than**ground~** based imageryfor displaying the characteristics of large, complex properties with several buildings and large trees. The alternative could beto charter a**full~sized** helicopterforthis purpose, which has proven more costly than many potential clients are able to afford. The benefits of reduced cost and improved quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and marine property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, etal., while remaining subjectto all limitations cited inthis application aswe do so. The ME System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations mustoccur in FAAClass G airspace at no more than 400 ftAGL, atan airspeed of no more than 50 knots and nofurtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer {VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; d) Operations will be restricted to flights 

### overproperty with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistentwith 14CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UApilot with a similar UAtype; f) All required permits will beobtained from state and local government prior to operation; g)The ME System will not beoperated over densely populated areas; h) The ME System will not be operated at air shows; 

### i) The ME System 

### will not beoperated 

### overany**open~air** assembly of people; j) The ME System will not beoperated over heavilytrafficked roads; k) Operations will be restricted to dayonly and weather conditions equivalentto VFR; I) The PIC will brief the VO and property owner aboutthe operation and risk before the first flight at each new location; m) Noflight may be made without a**Pre~Fiight** Inspection bythe PIC before each operation to ascertain that the UA is in a condition safe for flight (seeAppendixA).The PIC and VO wilt meet the requirements outlined in FAA Policy N 8900

.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as partoftheir Initial training.
We submit that the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions {a) through (n) listed above, the FAAcan havefull confidence thatthe operation will have an equivalent or greater level ofsafetythan manned aircraft performing the same mission.
The name and contact information ofthe applicant are: Intrepid Media Phone:360-720-3547 Email:al@intrepidmedia360.com
The regulations from which the exemption is requested are listed below. Beside each regulation number isthe page ofthe attached Addendum upon which each may be found together with our proposed equivalent level ofsafetyfor each regulation:

- 14 CFR Part 21

................................. Addendum Page 1

- 14 CFR 91 .203

................................. Addendum Page 1

- 14 CFA 45.23, 45.29

... .......................Addendum Page 2

- 14 CFR 91.9

....................................Addendum Page 2 -14 CFR 61.113, 61.133

.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121

..............Addendum Page 3

- 14 CFA 91.151

.................................Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417)

......Addendum Page 3 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1}

...Addendum 1
We are prepared to modify or amend any part ofthis requestto satisfy the need for an equivalent level of safety. Please contact us at any time if you require additional information or clarification. We lookforward to working with your office. Sincerely,

# ~£ ft Intrepid

# Medi**e** Everett Addendum containing Exempt1on Requests and EqUivalent Level of SafetyAppendiX A- Flight Manual's Appendix B -Owner's Manual for UAADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVELOF SAFETY Intrepid Media requests an exemption from the following regulations aswell as any additional regulations that may technically apply to the operation ofthe ME System:
14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraftdesign concepts, new aircraft equipment, new aircraft installations, new aircraftoperating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, we would expectthat an experimental certificate would permit our commercial purpose as well.
The aircraft will notcarry persons or property, will not carryfuel, and will onlyfly under strict operational requirements. Combined with the UA's light weight, being constructed primarilyof carbon fiber and plastic, we propose that the UAwill be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission.
If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirementfor an airworthiness certificate in general, citing the equivalent level ofsafetyoutlined inthe previous paragraph.
14CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation providesthat an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."At a maximum gross weightof6.5 pounds, the UA is too small to carry documentation, does not have an entrance, and is notcapable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meetthe intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAAwill be coMiocated with the crew atthe ground control station and availablefor inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plusthe word "EXPERIMENTAL" to satisfythe requirement of 14CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: DJIInnovations, Inc. 950 E BaselineAve. Ste. 210Apache JunctionAZ85119 Models: DJI Phantom 2 vision Plus
14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display 11W and the aircraft's registration number in letters at least3 inches high. Additionally, the aircraft mustdisplaytheword
11EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word 11EXPERIMENTAL" can be placed, and may not have a registration number assigned to it bythe FAA.
We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, asshown above, where the PIC, VO and others in the vicinity ofthe aircraftwhile it is preparing for launch will be able to seethe designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display atthe ground station a high contrastflag or bannerthat containsthewords "UnmannedAircraft Ground Station" in letters 3 inches high or greater. Since the aircraftwill operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.
14CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation providesthat no person mayoperate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intentofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is notonlytoo small to carry documentation, the documentation would not be available to the crew during flightoperations.
To obtain an equivalent level ofsafety and meetthe intent of 91.9, we propose that a current, approved UA Flight Manual (AppendixA) must be available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight.
14CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate mayact as pilot in command ofan aircraftforcompensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight isonly incidental to that business or employment; and (2) The aircraft does notcarry passengers or propertyfor compensation or hire

. Our proposed operations require thatthe PIC musteither
1. Hold a Sport Pilot Certificate issued bythe FAA, and have logged 25 hours offlight experience in this type of UA, or
2. Meetthe requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilotwritten examination." Sincethere are currently no means available for the pilot ofaUAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's license, we propose to generate an equivalent level ofsafety by requiring our pilots to complete, ata minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements. Sincethe aircraft cannot carry passengers or property, we feel we meetthe intent of61.113 Subparagraph (b) even though the intentofthis application is to conduct a business

. 14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that 11

### NO person mayoperate a civil aircraftthat is being used forflight instruction unless that aircraft hasfully functioning dual controls."
The ME System**ground~based** control station consists of a small**hand~held** radio transmitter and while it does not offer a second set of 11Controls", both the student and instructor can, and will, operate the single set ofcontrols simultaneously. With both student and instructor having "hands·on" the controls during flight, wefeel thatthis technique meetsthe intent 91.109 and provides an equivalent level of safety.
14CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating ata maximum of400feetAGL, we cannot comply with this requirement.
In order to provide an equivalent level ofsafety we will onlyfly over private property with permission ofthe ownerofthe propertyflown over. The aircraft will not be operated over congested areas or over any open air assembly of persons. The property owner will be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraft will be operated ata low altitude allowing, 

### if a power unitfails, an emergency landing without undue hazard to persons or property onthe surface.
Therefore we maintain that due

### tothe small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
14 CFR 91.121 Altimeter settings

. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 1 00 NM ofthe aircraft.
The UAwill always fly below 400 feet AGL and will not need to maintain cruising altitudes in order 

### to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above thetakeoff point istransmitted via radio from the UAon·board computer to the display screen held by the PIC, providing a constantly updated AGL readout.
14CFR 91.151 Fuel requirementsfor flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day· VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Wefeel the intention ofthis paragraph isto provide an energy reserve as a safety buffertor delays to landing

.The UA is battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will neverfly more than 314 NM from the pointof intended landing, a full battery charge atlaunch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and askfor an equivalent interpretation with the word "energy''.
14CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance,Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthycondition, including compliance with part39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service bya person authorized under 43.7" after maintenance and inspection.
It is our intention that the PIC perform maintenance and inspection ofthe aircraft and nbe authorized to approve the aircraftfor return to service."As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensure that the aircraft is in an airworthycondition prior to everyflight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer ortheir designated repairfacility. The PIC will documentwork performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.
8900.227 Paragraph 16(c)(4} PIC Medical. and Paragraph 16{e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAAsecond-class medical certificate issued under part67 in orderto perform asa pilot orobserver. The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic andthe PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.
We propose thatthe minimum medical requirements forthe PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and VO can see and avoid airtraffic; a licensed driver is medically qualified to operate a much largervehicle.APPENDIXA- FLIGHT MANUAL
FLIGHT RESTRICTIONS a) Noflight will be madewith a UAGrossweight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restricted to flights 

### overproperty with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UAtype; f) All required permits will beobtained from state and local government prior to operation; g) The ME System will not beoperated over densely populated areas; h) The ME System will not beoperated atair shows; i) The ME System will not be operated over any open-air assembly of people; 

### j) The ME System 

### will not be operated over heavilytrafficked roads; k) The ME System will not beoperated within 5 NM ofan airport or heliport; I) Operationswill be restricted to dayonly and weatherconditions equivalent to VFR; m) The PIC will briefthe VO and propertyowner about the operation and risk before the first flight at each new location; n) Noflight may be made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain that the UA is in a condition safe for flight.
PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted if necessary. 4. Gimbal isfunctioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected to the aircraft. TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Homefeature is activated and will bring the UAV back

### tothe PIC.