## Quad Squad Aerial Productions 18865 State Road 54 #248 Lutz, FL 33558

T 813 477-4826 rick@quadsquadap.com av8ir7@verizon.net

December 16, 2015 US Department Of Transportation

Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, Quad Squad Aerial Productions LLC, owner and operator of Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that Quad Squad Aerial Productions LLC may operate UASs commercially in airspace regulated by the FAA., as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by Section 333. Quad Squad Aerial Productions LLC is owned by Richard L. Vander Werf. Mr Vander Werf holds an Airline Transport Pilot Certificate, #3318045 with the following ratings: Airline Transport Pilot, Airplane Multiengine Land, Commercial Privileges, Airplane Single Engine Land, Rotorcraft-Helicopter: Instrument Helicopter. Mr Vander Werf has been flying over 30 years and has over 9,000 flight hours. He served 10 years in the United States Marine Corps flying UH 1N helicopters, flown for a Commercial Carrier, and is currently flying MedEvac helicopters in Tampa, Florida. He has been flying Drones for 3 years and has a firm grasp of FARs and the importance of safely navigating our national airspace. All of Quad Squad Aerial Productions LLC’s operations will be performed with the public’s safety and right to privacy safeguarded at all times. Quad Squad Aerial Productions LLC plans to utilize the capabilities of the UASs for a number of services including, buy not limited to:

- Aerial photography and videography for corporate, industrial, and commercial clients- Real estate clients

- Event photography and videography As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UAS under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s (the FAA Administrator’s) responsibility to “establish requirements for safe operation of such aircraft systems in national airspace systems.”Section 333(c), of the Reform Act. The purpose of this petition for exemption is to enable Quad Squad Aerial Productions LLC to operate a DJI Inspire 1 (Model #T600) equipped with a two-axis camera gimbal and using a High-Def camera. This UAS has a built-in capability to limit the height it flies above the ground, and to limit the radius of the distance it flies from the operator. The Inspire 1 also has the failsafe function of the autopilot system, which means when the communication between the main controller and the transmitter is disconnected, the controller will automatically trigger the “Return to Home” function and the UAS will return to the point of take-off or the location of the controller, whichever had been selected at the inception of the flight. The DJI Inspire 1 also has a second controller for camera control. The second controller allows for a camera operator to control all camera functions while the pilot in command flies the aircraft. Total weight of the UAS is approximately 6.5 lbs. including the battery, gimbal and camera. Quad Squad Aerial Productions LLC respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91,119, 91.121, 91.151(a), 91.203(a)&(b), 91.405(a), 91.407(a)(1), 91.409(a)&(b). (Quad Squad Aerial Productions LLC is registering it’s DJI Inspire 1 with the FAA on 21 December, 2015.)Therefor the exemption for the UAS to be registered and have a “N” number may not be required.) Quad Squad Aerial Productions LLC submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR’s operating to prevent Quad Squad Aerial Productions LLC ‘s future commercial use of small UASs to operate in the national airspace system as described below The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public’s interest to do so. Quad Squad Aerial Productions LLC UASs meet the definition of “small unmanned aircraft” as defined in Section 331 and therefor the Reform Act expressly contemplates the integration of these UASs. Quad Squad Aerial Productions LLC would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 of the Reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

- The UASs size, speed, weight and operational capability

- Operation of the UASs in close proximity to airports and populated areas

- Operation of the UASs within visual line of sight of the operator Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in the National Airspace System, the secretary shall establish requirements for the safe operation in national airspace. The very small nature of these UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as benefiting the greater public’s interest Accordingly, the applicant requests that the FAA grant the requested exemption without delay. The following will be considered as the binding limitation on operations of Quad Squad Aerial Productions LLC, 1. Flights will only occur in VFR conditions.
2. Flights will be operated in the line of sight of the operator (PIC) and observer (VSO)
3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by manufacturers recommendations.
4. The UASs will weigh less that 55 lbs.
5. Flights will be operated at 400 feet or less AGL.
6. Crew will be at a minimum of operator (PIC) and an observer and/or camera operator (VSO).
7. Operator and crew will remain in contact during the flight operation.
8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area.
9. Consent will be obtained from all persons with in the video capabilities of the UASs to further reduce the chance of violating anyone’s privacy.10. All required FAA clearances will be obtained and distances from airports strictly observed.
11. All UASs will have the capability to return automatically to the operator in a safe

manner with the auto return function checked and working.
12. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining.
13. Flight team will communicate by voice or the use of a two-way radio if the area is too

large to hear voice from all team members.
14. UASs will be used to photograph and video private outings and functions, sporting events and all other events from a safe distance.
15. Flights will yield the right-of-way to other aircraft, manned or unmanned.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91,7(a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Quad Squad Aerial Productions LLC UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform jAct. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act 49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Quad Squad Aerial Productions LLC meets or exceeds each of these elements. As of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” COA for flights at or under 400 feet AGL to any UASs operator with a section 333 exemption. 14 CFR 91.203(a)(b) provides for carrying of civil aircraft certifications and registrations. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Quad Squad Aerial Productions LLC Operations Center. Quad Squad Aerial Productions LLC has contacted the Tampa FSDO and will be registering it’s UAS with the FAA on 21 December, 2015. 14 CFR 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regulation is inapplicable. 14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Quad Squad Aerial Productions LLC Operations Center.The FAA has previously issued exemptions to this regulation in Exemption No’s 8607,8737,8738.9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827. 14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Quad Squad Aerial Productions LLC will only operate its UASs at or below 400 feet AGL. They will be operated on a well defined AOR that has been carefully reviewed for hazards an minimizes. the presence of any persons not essential for these operations. Flights over private property will be conducted with the owner’s consent. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more that 50 lbs., operations below 500 feet AGL with flammable fuel, UAS operations present a far smaller risk to the public. Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery operated and flying below 400 feet AGL, the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by Quad Squad Aerial Productions LLC will give the people and businesses another avenue to express themselves and to have a video or photo record to share with clients, family and friends. Additionally, Quad Squad Aerial Productions LLC requests to use our UASs to benefit first responders who may require assistance, including fire fighters, law enforcement, SAR, et al., while remaining subject to all limitations cited in this application as we do
so. Granting Quad Squad Aerial Productions LLC the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masses. Quad Squad Aerial Productions LLC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Quad Squad Aerial Productions LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the Act).

Sincerely,

Richard L. Vander Werf Quad Squad Aerial Productions LLC