Korporate Media	LLC c/o	David	R.	Overbeck 14615	Timberidge	Trail Brookfield,	WI	53005

August	31,	2015

United	States	Department	of	Transportation Docket	Management	System West	Building	Ground	Floor	Room	W12

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

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11 of	the	Federal	Aviation	Regulations	from:	14	CFR	21	subpart	H;	14	CFR	45.23(b);	14 CFR	61.113(a);	14	CFR	91.7(a);	14	CFR	91.9(b)(2);	14	CFR	91.103;14	CFR	91.109;

14	CFR 91.119(c);	14	CFR	91.121;	14	CFR	91.151(a);	14	CFR	91.203	(a)	and	(b);	14 CFR	 91.405	 (a);	 14	 CFR	 91.407	 (a)	 (1)	 14	 CFR	 91.409	 (a)(1)	 and	 (2);	 14	 CFR 91.417(a)	and	(b)

Dear	Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2 012	and	14

CFR	Part	11

, Korporate	Media	LLC	and	its	sole	member,	David	R.	Overbeck, operator
of Unmanned	Aeri al	System ( s ) (UAS),	hereby	apply for	an	exemption	from	the	listed Federal	 Aviation	 Regulations	 to	 allow commercial	 operation	 of	 a UAS,	 so	 long	 as

s uch	operations	are	conducted	within	and	under	 the	conditions	outlined	herein	or as	my	be	established	by	the	FAA	as	required	by	Section	333.

Information	of	the	applicant:

Name: Korporate	Media	LLC	c/o David	R.	Overbeck

Phone:	414.581.0109

Email: davidr@kor porate

- media.com

Address: 14615	Timberidge	Trail,	Brookfield,	WI	53005

Background David Overbeck founded Korporate Media LLC in 2004 to help companies and arts organizations produce high quality motion pictures. He has over 15 years of experience producin g media products for businesses such as Miller Coors, Briggs and Stratton, Kohl’s Department Stores

, and arts organizations such as the Milwaukee Ballet and the

U niversity of Wisconsin

- Milwaukee Department of Dance

. In addition to this professional work, David has had a passion for building UAS as a hobbyist , and has built

and safely flown small scale UAS

. Now that small UAS can safely support high quality cameras capable of producing broadcast quality images and photographs

, he is looking to combine his p assion for commercial video production and photography with his passion for operating UAS.Commercial	operation UAS,	as	described	herein,	which	are	equipped	with	cameras and	sensors,	would	operate	in	the	following	manner:

1. Aerial	photography	and/or	video	for	public	and/or	private	use	including	real estate,	 architecture,	 land	 surveying,	 engineering	 and	 other	 related professional	activities.

2. Aerial	 video	 and/or	 photography	 for	 public	 and/or	 private	 use	 including television,	p ublic	events,	and	cinematography.

3. Aerial	 inspection/photography	 of	 residential/commercial	 structures	 under contract	with	the	owners	or	local	government	authority.

4. Aerial	 video/photography	or	providing	live	 video	 feed	 to	assist	with	search and	 rescue	 oper ations	 in	 cases	 of	 an	 emergency	 or	 natural	 disaster	 only when	 the	 local	 authorities	 or	 government	 has	 requested	 it	 by	 contract	 or

donation.

As	 described	 fully	 below,	 the	 requested	 exemption	would	 permit	 the	 operation	 of

UAS	under	controlled	conditions	in the National	Air	Space	 (NAS) that	would	be	a) limited	b)	controlled	c)	predetermined	and	d)	will	provide	safety	enhancements	to the	 already	 safe	 operations	 in	 the	 industry	 presently	 using	 conventional	 aircraft. Approval	of	this	exemption	would	thereby	enh ance	safety	and	fulfill	the	Secretary	of Transportation’s	 (the	 FAA	 Administrator’s)	 responsibilities	 to	 “....establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace system.”

Regulations	from	which	the	exemption	is	r equested:	14	CFR	Part	21	subpart	H 14	CFR	45.23	(b) 14	CFR	61.113(a) 14	CFR	91.7	(a) 14	CFR	91.9	(b)	(2)

14	CFR	91.103

14	CFR	91.109 14	CFR	91.119(c)

14	CFR	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b)

The	UAS are	multi

- rotor	cr aft	weighing	no	more	than	55	pounds including	payload. Under	 normal	 conditions	 they	 operate	 at	 speeds	 of	 no	 more	 than	 45	 Mph	 or	 39 Knots	 and	 have	 the	 ability	 hover	 and	 move	 along	 a	 vertical	 and	 horizontal	 plane simultaneously.	They	will be operate d	within line	of	sight and	only by	the	exemp ted

person ,	David	R.	Overbeck, in	obeyance all	other	local	and	federal	laws.Given	the	smal l	size	of	the	UAS	and	its	operation	within	a	controlled	environment,	as outlined	 below,	 the	 proposed	 operation will	 adhere	 to	 the	 Reform	 Act’s	 safety requirements.	The	approval	of	this	application	presen ts	no	national	security	issues. Granting	the	requested	exemption	is	in	the	public’s	best	interest,	due	to	the level	of safety	 sur rounding	 the	 pro posed	 operation	 a nd its	 low	 environmental	 impact, including	 reduced	 emissions	 and	 noise, when	 with	 alternative	 aerial	 video production	methods.

Aircraft	and	Equivalent	Level	of	Safety The	applicant	agrees	to	adhere	to the	 following	safety	conditions when	conducting

commer cial	 opera tions	 under	 the	 FAA issued	 exemption	 as	 set	 forth	 in	 the	 Flight Operations	Manual	(FOM) :
1. The	small	UAS	will	weigh	less	than	55	lbs.

2. Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.

3. Maximum	 flight	 time	 for	 ea ch	 operation al	 flight	will	 be	 20 minutes.	 Fli ghts
will	be	terminated	at	25% battery	power	reserve	o r	20 minutes	of	flight	time

whichever	occurs	first.

4. Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground Level	 (AGL)	 and	 not	 more	 	than	 200	 fee t	 above	 an	 elevated	 platform	 from which	filming	is	planned.

5. Minimum	 crew	 for	 each	 operation	 will	 consist	 of	 the	 small	 UAS	 Pilot	 in Command	(PIC),	the	Visual		Observer	(VO)	when	needed	and	may	include	but not	limited	to	a	Camera	Operator.

6. The UAS will	onl y	be	piloted	by the	PIC, David R. Overbeck ,	as	sole	member	of Korporate	Media	LLC, in	a	commercial	capacity

. 7. A	 briefing	 will	 be	 performed	 regarding	 the	 planned	 small	 UAS	 operati ons prior	to	each	day’s	flight	and	the	proposed production	activities.

8. The	PI C	will	obtain	 verbal/written	consent	of	all	persons	involved	with	 the planned	operation	and		ensure	that	only	consenting	persons	will	be	allowed within	100	feet	of	the	flight	operation,	and	the	radius	may	be	reduced	to	30 feet	 based	 upon	 an	 equivalent	 leve l	 of	 safety	 determination,	 as	 required under	 the	 FOM.	 With	 the	 advanced	 permission	 or	 direction	 of	 the	 FSDO, operations	at	closer	range	may	be	approved.

9. The	PIC	and	VO	will	have	bee n	trained	in	operation	of UAS	and	receive	up

- to

date	 infor mation	 for	 the	 p articular UAS	 to	 be	 operated	 and	 will	 be	 able	 to show	 upon	 request	 their	 compet ent	 ability	 to	 operate	 the UAS	 and/or

Camera.

10. The	PIC	and	VO	will	be	able	to	communicate	by	v oice	or	radio	at	all times.

11. Written	 and/or	 verbal	 permission	 and	 permits	 will	 be	 o btained	 from territorial,	state,	county	or	city		jurisdictions,	including	law	enforcement,	fire or	other	appropriate	governmental	agencies	when	needed.

12. If	the UAS	loses	communications	or	loses	GPS	signal,	the	small	UAS	will	have the	 capability	 to	 	return to	 a	 pre

- determined	 location	 within	 a	 designated location	and	land	autonomously.13. The UAS	 will	 have	 the	 capability	 to	 abort	 a	 flight	 in	 case	 of	 unpredicted obstacles,	weather,	or		emergencies.

Pre

- Flight	Checklist

1. Weather	conditions	are	suitable	for	UAS flight

a. Winds not to exceed	18	miles	per	hour

b. Temperature	is	above	32	degrees	Fahrenheit

c. There	is	no	precipitation	in	the	area

2. Test	Battery

a. Power	on	battery	and	check	voltage

b. Perform	a	battery	self	test	and	check	for	errors

c. Power	down	battery

3. Verify	all wiring	connections	are	secure

4. Check	rotors	for	wear,	cracks,	and	chips

5. Make	sure	rotors	are	tight and	that	they	turn	freely

6. Power	on	controller	and	connect	to	the	tablet	to	check	for	controller	errors

7. Place	UAS	in	a	clear	open	area	free	from	obstructions

8. I nstall	battery	in	UAS	and	power	on

9. Check	for	errors	with	UAS,	Controller,	or	Battery

10. Confirm	radio	connection	to	the	controller are	at	100%

11. Calibrate	compass	if	necessary

12. Make	sure	UAS	is	locked	to	at	least	10	GPS	satellites	before	engaging

motors
13. Make sure	bystanders	are	clear	and verbally announce	“Take	Off”

14. Take	off

a. hover	UAS	at	5	feet

b. confirm	satellite	GPS	lock

c. confirm	ground	sensors	are	functioning

d. confirm	radio	con n ection	to	the	controller

e. confirm	controls	are	responding	correctly

UAS	Informa tion

1. DJI	Inspire	1

UAS Weight	with	Battery

– 6.47	lb Max	Ascent	Speed

– 11.1	mph

Max	Descent Speed

– 8.9	mph Max	Speed

– 49.2	mph Max	Flight	Time

– 18	Minutes Operating	Temperature

- 10 

### ° C to 40° C

Controller Frequency	5.725

- 5.825	GHz	2.400

- 2.483	GHz Transmitting	Distance

– 1.2	miles BatteryCapacity

– 4500	mAH Voltage

- 22.2V Type

– LiPo	65

2. DJI	Phantom	3

UAS Weight	with	Battery

– 2.82	lb Max	Ascent	Speed

– 11.1	mph Mas	Descent	Speed

– 6.71	mph Mas	Speed

– 35.7	mph Max	Flight	Time

– 23	Minutes Operating	Temperature

- 0 

### °C

- 40 °C

Controller Frequency

- 2.400	GHz

- 2.483	GHz Transmitting	Distance

– 1.2	miles Battery Capacity

– 4480mah Voltage	15.2V Type

– LiPo	4S

UAS Safety Features Both	DJI	UAS	have	a	wide	variety	of	safety	features	to	ensure	safe	flights.

1. The	batteries	have	smart	features	which	ensure	they	do	not	operate	if there	is	an	issue	with	the	battery.	If	the	battery	has	an	error ,	the

motors will	not	engage.

1. Once	the	UAS powers	on	i t	goes	through	a	series	of	self

- checks.	If	there are	any	issues	with	the	UAS	the	motors	will	not	engage.

2. If	during	flight	there	are	any	non

- critical	errors	the	PIC	is	informed

i mmediately and	the	pilot	can	bring	the	UAS	to	a	safe	landing

3. If	for	any	reason	the	UAS	loses	radio	control	it	initiates	a	‘return	to home’	function.	During	return	to	home	the	UAS	ascends	to	a	safe altitude	to	avoid	any	ground	obstacles,	then	it	returns	to	the	same	place

where it	took	off	and	automatically	initiates	a	safe	landing.

4. If	the	UAS	ba ttery	gets	to	20%	it	initiates	the ‘return	to	home’	fu nction.

5. If	an	emergency	low	voltage	occurs,	the	UAS	initiates	a	safe	landing	in place.

6. If	the	visual	transmission	to	the	ground	i s	lost	the	UAS	is	easily	landed

7. visually	by	the	PIC.

8. All	UAS	information	such	as	altitude	and	airspeed	is	transmitted	to	the ground	for	the	PIC	to	see	at	all	times.

Petitions for	Exemption14	 C.F.R.	Part	21,	 Subpart	H:	Airworthiness	 Certificates 14	 C.F.R.	 §91.203	 (a) (1) Subpart	 H,	 entitled	 Airworthiness	 Certificates,	 establishes	 the	 procedural requirements	 for	 the	 issuance	 of	 airworthiness	 certificates	 as	 required	 by	 FAR §91.203	 (a)	 (1).	 Given	 the	 size	 and	 limited	 operating	 area	 associated	 with	 t he aircraft	to	be	utilized	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H	meets the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of the	Reform	Act.	The	Federal	Aviation	Act	 (49	U.S.C.§44701	 (f))	and	Section	333	of

the Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for an	 airworthiness	 certificate,	 upon	 consideration	 of	 the	 size,	 weight,	 speed, operational	 capability,	 and	 proximity	 to	 airports	 and	 populated	 areas	 of	 the particular	small	UAS.	In all	cases,	an	analysis	of	these	criteria	demonstrates	that	the small	 UAS	 operated	 without	 an	 airworthiness	 certificate,	 in	 the	 restricted environment	 and	 under	 the	 conditions	 proposed	 will	 be	 at	 least	 as	 safe,	 or	 safer, than	 a	 conventional	 aircraft	 (fixed wing	 or	 rotorcraft)	 operating	 with	 an airworthiness	certificate	without	the	restrictions	and	conditions	proposed.

The	 small	 UAS	 to	 be	 operated	 hereunder	 is	 less	 than	 55	 lbs.	 fully	 loaded,	 carries neither	 a	 pilot	 nor	 passenger,	 carries	 no	 explosive	 materi als	 or	 flammable	 liquid fuels,	and	 operates	exclusively	within	a	 secured	and	designated	area.	Unlike	 other civil	 aircraft,	 operations	 under	 this	 exemption	 will	 be	 tightly	 controlled	 and monitored	by	both	the	operator	and	under	the	requirements	and	in	compl iance	with local	 public	 safety	 requirements.	 These	 safety	 enhancements	 provide	 a	 greater degree	 of	 safety	 to	 the	 public	 and	 property	 owners	 than	 conventional	 operations conducted	with	airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.

La stly,	 application	 of	 these	 same	 criteria	 demonstrates	 that	 there	 is	 no	 credible threat	 to	 national	 security	 posed	 by	 the	 small	 UAS,	 due	 to	 its	 size,	 speed	 of operation,	 location	 of	 operation,	 lack	 of	 explosive	 materials	 or	 flammable	 liquid fuels,	and	inabi lity	to	carry	a	substantial	external	load.

14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft The	regulation	requires:	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.

Even	though	the	small	UAS	will	have	no	airworthiness	certificate,	an	exemption	may be	 needed	 as	 the	 small	 UAS	 will	 have	 no	 entrance	 to	 the	 cabin,	 cockpit	 or	 pilot

station	on	w hich	the	word	“Experimental”	can	be	placed.	Given	the	size	of	the	small
UAS,	two

- inch	lettering	will	be	impossible.	The	word	“Experimental”	will	be	placed on	the	fuselage	in	compliance	with	§45.29	(f).	The	equivalent	level	of	safety	will	be provided	by	hav ing	the	small	UAS	marked	on	its	fuselage	as	required	by	§45.29	(f) where	 the	 pilot,	 observer	 and	 others	 working	 with	 the	 small	 UAS	 will	 see	 the identification	of	the	small	UAS	as	“Experimental.”14	 C.F.R.	 §	 61.113(a):	 Private	 Pilot	 Privileges	 and	 Limitati ons:	 Pilot	 in

Command. Pursuant	to	14	CFR	61.113	(a),	no	person	who	holds	a	private	pilot	certificate	may act	as	a	pilot	in	command	of	an	aircraft	that	is	carrying	passengers	or	property	 for compensation	 or	 hire.	 Our	 small	 UAS	 do	 not	 carry	 any	 pilots	 or	 pa ssengers	 nor property	 therefore	 I	 am	 seeking	 an	 exemption	 to	 14	 CFR	 61.113(a).	 Although helpful,	 a	 pilot’s	 license	 will	 not	 ensure	 remote	 control	 piloting	 skills.	 The	 risks attendant	to	the	operation	of	small	UAS	is	far	less	than	the	risk	levels	inherent	i n	the commercial	activities	outlined	in	14	CFR	61.	I	feel	the	operation	and	limitations	set forth	in	the	FOM	will	equate	to	the	safe	operation	of	the	small	UAS.

14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness. The	 regulation	 requires	 that	 no	 person	 may operate	 a	 civil	 aircraft	 unless	 it	 is	 in airworthy	 condition.	 As	 there	 will	 be	 no	 airworthiness	 certificate	 issued	 for	 the aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for determining	airworthiness.	Given	the	size	of	th e	aircraft	for	maintenance	and	use	of safety	checklists	prior	to	each	flight	an	equivalent	level	of	safety	will	be	provided.

14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft. Section	91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S

. - registered	civil	aircraft ...	(2)	For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of this	chapter,	unless	there	is	available	in	the	aircraft	a	current	approved	airplane	or Rotorcraft	Flight	Manual,	approved	manual	material,	mar kings,	and	placards,	or	any combination	 thereof.	The	small	UAS,	given	its	size	and	configuration	has	no	ability or	place	 to	carry	such	a	 flight	manual	on	 the	aircraft,	not	only	because	 there	is	no pilot	on	board,	but	because	there	is	no	room	or	capacity	to carry	such	an	item	on	the aircraft.	 The	 equivalent	 level	 of	 safety	 will	 be	 maintained	 by	 keeping	 the	 flight manual	at	 the	ground	control	point	where	 the	pilot	 flying	 the	 small	UAS	will	have

immediate	access	to	it.

14	C.F.R.	§	91.103:	Preflight	Action.

Th is	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight to	insure	the	safety	of	 flight.	As	FAA	approved	rotorcraft	 flight	manuals	will	not	be provided	for	the	aircraft	an	exemption	will	be	needed.	The	OPERATOR	will	take	all

actio ns	 including	 reviewing	 weather,	 flight	 battery	 requirements,	 landing	 and takeoff	distances	and	aircraft	performance	data	before	initiation	of	flight.

14	C.F.R.	§91.109:	Flight	Instruction. Section	 91.103	 provides	 that	 no	 person	 may	 operate	 a	 civil	 aircraf t	 (except	 a manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has fully	 functioning	 dual	 controls.	 Small	 UAS	 and	 remotely	 piloted	 aircraft,	 by	 their design	 do	 not	 have	 fully	 functional	 dual	 controls.	 Flight	 control	 is	 acco mplished through	 the	 use	 of	 a	 control	 box	 that	 communicates	 with	 the	 aircraft	 via	 radio communications.	The	FAA	has	approved	exemptions	for	flight	training	without	fully functional	 dual	 controls	 for	 a	 number	 of	 aircraft	 and	 for	 flight	 instruction	 inexperi mental	aircraft.	The	equivalent	level	of	safety	provided	by	the	fact	that	neither a	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by	the	size	and	speed	of	the

aircraft.

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

Section	 91.119	 establishes	 safe altitudes	 for	 operation	 of	 civil	 aircraft.	 Section 91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed, provided	 the	person	operating	 the	helicopter	complies	with	any	 route	or	altitudes prescribed	for	helicopters	by	the	FAA.	A s	this	exemption	is	for	a	small	UAS	that	is	a helicopter	and	 the	exemption	 requests	authority	 to	 operate	at	altitudes	 up	 to	 400 AGL,	 or	 not	 more	 than	 200	 above	 an	 elevated	 platform	 from	 which	 filming	 is planned,	an	exemption	may	be	needed	to	allow	such	ope rations.	As	set	forth	herein, the	small	UAS	will	never	operate	at	higher	than	400	AGL	with	the	exception	that	in circumstances	 where	 the	 small	 UAS	 is	 used	 to	 survey	 or	 photograph	 a	 structure whose	height	exceeds	400	 feet	AGL,	 the	small	UAS	will	not	be	oper ated	more	 than 100'	 above	 the	 highest	 point	 on	 the	 structure.	 It	 will	 however	 be	 operated	 in	 a restricted	 area	 with	 security	 perimeter,	 where	 buildings	 and	 people	 will	 not	 be exposed	 to	 operations	without	 their	 pre

- obtained	 consent.	 The	 equivalent	level	 of safety	will	be	achieved	given	the	size,	weight,	speed	of	the	small	UAS	as	well	as	the location	where	it	is	operated.	No	 flight	will	be	taken	without	the	permission	of	the property	 owner	 or	 local	 officials.	 Because	 of	 the	 advance	 notice	 to	 the	 property

own er	and	participants	in	the	filming	activity,	all	affected	individuals	will	be	aware of	 the	 planned	 flight	 operations.	 Compared	 to	 flight	 operations	 with	 aircraft	 or rotorcraft	 weighting	 far	 more	 than	 the	 maximum	 55lbs.	 proposed	 herein	 and	 the

lack	 of	 flamm able	 fuel,	 any	 risk	 associated	 with	 these	 operations	 is	 far	 less	 than those	presently	presented	with	conventional	aircraft	operating	at	or	below	500	AGL. In	 addition,	 the	 low

- altitude	 operations	 of	 the	 small	 UAS	 will	 ensure	 separation

between	 these	 small

- UAS	 operations	 and	 the	 operations	 of	 conventional	 aircraft that	must	comply	with	Section	91.119.

14	C.F.R.	§91.121	Altimeter	Settings. This	 regulation	 requires	 each	 person	 operating	 an	 aircraft	 to	 maintain	 cruising altitude	by	reference	 to	an	altimeter	 th at	is	set	“...to	 the	elevation	of	 the	departure airport	or	an	appropriate	altimeter	setting	available	before	departure.”	As	the	small UAS	may	 not	 have	 a	 barometric	 altimeter,	 but	instead	 a	 GPS	 altitude	 read	 out,	 an exemption	 may	 be	 needed.	 An	 equivalent	 le vel	 of	 safety	 will	 be	 achieved	 by	 the operator,	 pursuant	 to	 the	 safety	 check	 list	 and	 live	 flight	 data	 monitoring, confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before flight.

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	F light	in	VFR	Conditions Section	 91.151	 (a)	 prohibits	 an	 individual	 from	 beginning	 “a	 flight	 in	 an	 airplane under	 VFR	 conditions	 unless	 (considering	 wind	 and	 forecast	 weather	 conditions) there	 is	 enough	 fuel	 to	 fly	 to	 the	 first	 point	 of	 intended	 landing,	 an d,	 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.”	The	battery	powering	 thesmall	 UAS	 provides	 approximately	 30	 minutes	 of	 powered	 flight.	 To	 meet the	 30 minute	reserve	requirement	in	14	CFR	§91.151,	small	UAS	flights	would	be	limited to	 approximately	 10	 minutes	 in	 length.	 Given	 the	 limitations	 on	 the	 small	 UAS’s proposed	 flight	 area	 and	 the	 location	 of	 its	 proposed	 operations	 within	 a predetermined area,	 a	 longer	 time	 frame	 for	 flight	 in	 daylight	 or	 twilight	 VFR conditions	 is	 reasonable.	 Applicant	 believes	 that	 an	 exemption	 from	 14	 CFR §91.151(a)	falls	within	the	scope	of	prior	exemptions.	Operating	the	small	UAS,	in	a tightly	 controlled	 area	 where	 o nly	 people	 and	 property	 owners	 or	 official representatives	who	have	signed	waivers	will	be	allowed,	with	less	than	30	minutes of	 reserve	 fuel,	 does	 not	 engender	 the	 type	 of	 risks	 that	 Section	 91.151(a)	 was intended	to	alleviate	given	the	size	and	speed	of the	small	UAS.	Additionally,	limiting small	 UAS	 flights	 to	 10	 minutes	 would	 greatly reduce	 the	 utility	 for	 which	 the exemption	will	be	granted.	Applicant	believes	that	an	equivalent	level	of	safety	can be	achieved	by	limiting	flights	to	30	minutes	or	25%	o f	battery	power

— whichever happens	first.	This	restriction	would	be	more	than	adequate	to	return	the	small	UAS to	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area.

14	 C.F.R.	 §91.203	 (a)	 and	 (b):	 Carrying	 Civil	 Aircraft	 Certification	 an d Registration The	regulation	provides	in	pertinent	part: (a)	 Except	 as	 provided	 in	 §	 91.715,	 no	 person	 may	 operate	 a	 civil	 aircraft

unless	it	has	within	it	the following: (1)	An	appropriate	and	current	airworthiness	certificate.	.	.	. (b)	No	person	may operate	a	civil	aircraft	unless	the	airworthiness	certificate required	 by	 paragraph	 (a) of	 this	 section	 or	 a	 special	 flight	 authorization	 issued under	 §91.715	is	 displayed	at	 the	 cabin	 or	 cockpit	entrance	 so	 that	it	is	legible	 to

passengers	or	crew.

The UAS	 fully	 loaded	 weighs	 no	 more	 than	 55	 lbs.	 and	 is	 operated	 without	 an onboard	 pilot.	 As	 such,	 there	 is	 no	 ability	 or	 place	 to	 carry	 certification	 and registration	documents	or	to	display	them	on	the	small	UAS.

An	 equivalent	 level	 of	 safety	 will	 be	 achi eved	 by	 keeping	 these	 documents	 at	 the ground	 control	 point	 where	 the	 pilot	 flying	 the	 small	 UAS	 will	 have	 immediate access	to	them;	to	the	extent	t hey	are	applicable	to	the UAS.

14	 C.F.R.	 §91.405	 (a);	 407	 (a)	 (1);	 409	 (a)	 (2);	 417(a)	 &	 (b):	 Maintenanc e Inspections. These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft inspected	 as	 prescribed	 in	 subpart	 E	 of	 this	 part	 and	 shall	 between	 required inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discre pancies repaired	 as	 prescribed	 in	 part	 43	 of	 this	 chapter...,”	 and	 others	 shall	 inspect	 ormaintain	the	aircraft	in	compliance	with	Part	43.	Given	that	these	section	and	Part 43	 apply	 only	 to	 aircraft	 with	 an	 airworthiness	 certificate,	 these	 sections	 will not apply	to	the	applicant.	Maintenance	will	be	accomplished	by	the	operator	pursuant to	 the	 flight	manual	and	 operating	 handbook.	An	equivalent	level	 of	 safety	will be

achieved	because	these UASs	are	very	limited	in	size	and	will	carry	a	small	payload

and operate	only	in	restricted	areas	for	limited	periods	of	time.	If	mechanica l	issues

arise	the UAS	can	land	immediately	and	will	be	operating	from	no	higher	than	400 feet	 AGL.	 The	 ope rator	 will	 ensure	 that	 the UAS	 is	 in	 working	 order	 prior	 to initiating	 fli ght,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance performed.	Moreover,	the	operator	is	the	person	most	familiar	with	the	aircraft	and best	 suited	 to	 maintain	 the	 aircraft	 in	 an	 airworthy	 condition	 to	 provide	 the equivalent	level	of	safet y.

An	equivalent	level	of	safety	will	be	achieved	because	maintenance	and	inspections will	be	p erformed	in	accordance	with	the UAS	Manufacturer's	Manual,	as	referenced in	the	Aircraft	Operations	Manual	(AOM).	As	provided	in	the	FOM,	the	oper ator	will

ensu re	 that	 the UAS	 is	 in	 working	 order	 prior	 to	 initiating	 flight	 and	 perform required	maintenance	needed.

Additional	Supporting	Information Several	documents	are	provided	with	this	petition in	support request. They	include: DJI	Phantom	3	Users	Manual DJI	P hantom	3	Safety	Guidelines

Thank	you	for	your	consideration	of	these	exemptions.

Sincerely,

David	R.	Overbe c k Korporate	Media	LLC