Cinema & Sound Group
PO Box 6335 Fishers, IN 46038

Web: ExplorersLikeUs.com

Kevin Williams
Senior Managing Partner

Ph: 317.284.1423

Monday, December 07, 2015

U. S. Department of Transportation
U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

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

REGARDING THE MATTER OF THE PETITION FOR EXEMPTION OF:

Explorers Like Us, LLC , herein referred to as “Explorers Like Us”

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS: Part 21 Subpart H, 45.23 (b), 61.113(a) &(b), 91.7 (a), 91.9 (b) (2), 91.103, 91.109 (a), 91.119 (c), 91.121, 91.151 (a), 91.405 (a), 91.407 (a)( 1), 91.409(a)(1) &(a)(2), AND 91.417(a) & (b) CONCERNING
COMMERCIAL OPERATION OF THREE (3 ) DJI PHANTOM 3 , AND TWO (2 ) DJI INSPIRE UNMANNED AIRCRAFT
SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFO RM ACT OF 2012 (PUBLIC LAW
112 95)

Dear Sir (s) or Madam (s) :

Explorers Like Us is petitioning the Federal Aviation Administration (FAA) for an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR Part 11. The exemption is necessary to operate a sma ll unmanned aircraft system ( sUAS ) commercially in FAA airspace . The exemption would allow operation of three (3) DJI Phantom 3 Professional and two (2) DJI Inspire sUAS for the purpose of videography and photography in controlled access areas for the

purp oses of: motion picture aerial photography, film acquisition and digital image acquisition, commercial development, civil planning, economic development, construction planning and/or documentation, corporate marketing and/or promotions, government and/or civic photography, videography and video production. This document will outline requested relief from regulations pertaining to this exemption request.Explorers Like Us agrees to operate within the boundaries set forth by this exemption. Along with

rules and regulations that the FAA has in plac e, Explorers Like Us plans to incorporate additional safety precautions to ensure safe st possible sUAS operations. Implementation of lightweight sUAS can greatly improve the safety standards of or National Airspace System (NAS) while mitigating the necessity of flight operations that traditionally require larger manned aircraft, which carry pilots and flammable fuel. Explorers Like Us is requesting the ability to offer sUAS operations and to promote the safe, efficie nt, and responsible use of sUAS.

Kindest Regards

,

Kevin Williams
Senior Managing Partner
Explorers Like Us, LLC
K.Wlliams@ExplorersLike Us.com

317.284.1423

## Table of Contents

Table of Contents

................................ ................................ ................................ ................................ .......... 3

Section 1: Introduction and Interest of Petitioner

................................ ................................ ....................... 5
Section 2: Unmanned Aircraft Systems

................................ ................................ ................................ ....... 5

General Informa tion Pertaining to All Proposed sUAS

................................ ................................ ............. 5
Equipment List

................................ ................................ ................................ ................................ .............. 6
Section 3: Unmanned Aircraft Pilot in Command (PIC)

................................ ................................ ............... 7
Section 4: Operation of sUAS

................................ ................................ ................................ ....................... 8
Operational Limitations

................................ ................................ ................................ ................................ 8
Operations

................................ ................................ ................................ ................................ .................... 9
Section 5: Requested Exemptions from Regulations

................................ ................................ ................. 11
14 C.F.R. Part 21 Subpart H

- Airworthiness Certificates

................................ ................................ ........ 11
14 C.F.R. § 45.23 (b)

- Display of marks; general.

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

14 C.F.R. § 61.113 (a) & (b)

- Private Pilot Privileges and Limitations: Pilot in Command.

..................... 11
14 C.F.R. § 91.7 (a)

- Civil aircraft a irworthiness.

................................ ................................ .................... 12
14 C.F.R. § 91.9 (b)(2)

- Civil Aircraft Flight Manual in the Aircraft

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

14 C.F.R. § 91.103

- Preflight action.

................................ ................................ ................................ ........ 12
14 C.F.R. § 91.109 (a)

- Flight instruction.

................................ ................................ ............................... 13

14 C.F.R. § 91.119 (c)

- Minimum safe altitudes: General.

................................ ................................ .... 13

14 C.F.R. § 91.121

- Altimeter settings.

................................ ................................ ................................ ... 13
14 C.F.R. § 91.151 (a)

- Fuel requirements for flight in VFR conditions.

................................ ................. 13
14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b)

- Maintenance Inspections

............................ 14
Protection of Rights and Privacy

................................ ................................ ................................ ................. 14

Public Interest

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

Conclusion

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

## Abbreviations Used in This Document

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

ELU Explorers Like Us

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAMS Notices to Airmen

PIC Pilot in Command

RTH Return to Home

SOG Speed Ov er Ground

sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VMC Visual Meteorological Conditions

VLOS Visual Line of Sight

## Section 1: Introduction and Interest of Petitioner

Explorers Like Us is a film production company (photography, videography, audio acquisition) located in Fishers, Indiana. We specialize in video production and documentar y imaging, but also seek to expand our capabilities in other areas of image acquisition and related services. Explorers Like Us utilizes five (5) DJI sUAS platforms for the purpose of photography and videography in controlled access and highly restrictive environments. Explorers Like Us is committed to offering professional, safe and responsible sUAS flight operations while maintaining the highest possible standards of ethics, performance and integrity.

Privacy is a key concern of Explorer’s Like Us operati ons

. Explorers Like Us sUAS operators are not permitted to undertake any operation that would otherwise invade or encumber any person's reasonable expectation of privacy when operating the sUAS. Explorers Like Us’ operators will abide by all FAA Regulation s for flight and receive proper authorization prior to flight by Explorers Like Us and/or the FAA when required

.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for det ails.



## Section 2: Unmanned Aircraft Systems

General Information Pertaining to All Proposed sUAS

Explorers Like Us will operate sUAS weighing less than 55 pounds, for the purpose of conducting aerial videography and photography acquisition with payloads capable of supporting these operations.

Prior to each flight the PIC and VO shall inspect the sUAS to ensure its condition is safe flight. If this inspection reveals a condition that affects the safe operations of the sUAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the sUAS is for safe flight. Ground Control Station will also be included in preflight inspections. Maintenance and alterations must be properly documented and approved

. All processes, maintenance and problems found must be signed off by two individuals independently, with one being the PIC of the operation of the sUAS on the particular mission.
Any maintenance or alterations made to a sUAS must be documented in the appropriate logbook, and the sUAS must undergo a functional test flight prior to it being returned to service. Any repairs or alterati ons must meet the manufacturer’s guidelines, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals. Only authorized personnel shall perform such operations. All maintenance must be signed off by two individuals independently, with one being the PIC of the operation of the sUAS on the particular mission.
Explorers Like Us will follow all sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft an d aircraft components. All maintenance, in spections, and record keeping will be done in accordance with the manufacturer’s operations manual, and will benoted in the appropriate logbook. All processes must be signed off by two individuals independently,

w ith one being the PIC of the operation of the sUAS on the particular mission.

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and Safety Bulletins.

Before conducting any mission or flight operation, the radio freq uency spectrum used for operation and control of the sUAS shall comply with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for det ails.



## Equipment List

DJI Phantom 3 Professional (3)

Explorers Like Us seeks an exemption to operate three (3) DJI Phantom 3 Professional sUAS for compensation and/or hire. The DJI Phantom 3 Professional is comprised of a quadrotor

- unmanned aircraft and a handheld ground control station. The Phantom 3 Professional has a maximum gross weight of approximately 1280 grams and diagonal size of approximately 635mm (including propellers and Explorer’s Like Us mandated safety guards). The Phantom 3 Professional is equipped with four rotors driven by four lithium polymer battery powered e lectr ic motors. Design and operational characteristics are provided in the DJI Phantom 3 Professional User Manual. PIC will conduct preflight inspections as d ocumented in DJI Phantom 3 Professional User Manual and any standard Explorers Like Us may add from tim e to time that exceeds such standards and practices

.
For complete information on the DJI Phantom 3 Professional, including Radio Frequency (RF) spectrum used for control of the sUAS, please reference the attached DJI Phantom 3 Professional User Manual

.

D JI Inspire (2 )

Explorers Like Us seeks an exemption to operate up to two ( 2 ) DJI Inspire sUAS for compensation and/or hire. The DJI Inspire 1 is comprised of a quad

- rotor unmanned aircraft and a ha ndheld ground control station. A second controller may be used by an addition pers on to operate the camera only. The Inspire 1 has a maximum gross weight of approximately 2935 grams and diagonal size of approximately
581mm

. The Inspire 1 is equipped with four rotors driven by four lithium polymer ba ttery powered electric motors. Design and operational characteristics are provided in the DJI Inspire 1 User Manual. PIC will conduct preflight inspections as documented in the DJI Inspire User Manual and any standard Explorers Like Us may add from time to time that ex ceeds such standards and practices.

For complete information on the DJI Inspire, including Radio Frequency (RF) spectrum used for control of the sUAS, please reference the atta ched DJI Inspire 1 Pro User Manual

.

## Section 3: Unmanned Aircraft Pilot in Comman d (PIC)

Explorers Like Us’ flight crew, including PIC and Visual Observer (VO), will be qualified as directed by Explorers Like Us.

All flight crew members, including PIC and VO, will have an understanding of, and comply with , Title 14 Code of Federal Regulations (CFR), and/or FAA directives and regulations, applicable to airspace where the sUAS will operate. Specifically all flight crew members will receive training on the rules and responsibilities described in 14 CFR Part 91, Sections 91.111, 91.11 3, and 91.115.

All Explorers Like Us PIC must meet current FAA minimum requirements regarding regulations for operator status. To meet current compliance, the PIC must possess at least a current sport pilot certificate and valid driver’s license. The PIC for Explorers Like Us currently maintains a private pilot certification (rotary and single

- engine fixed wing) with VFR and IFR more than 1500 hours fixed

- wing and more than 800 hours rotary flight experience. No violations on record.

All operations utiliz e a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. This condition and limitation is consistent with all FA A approved Exemptions.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for det ails.

## Section 4: Operation of sUAS

Operational Limitations

Explorers Like Us is seeking sUAS operation under the following operational limitations.



### • Unmanned aircraft must weigh less than 55 lbs. (25 kg).



### • Vi sual line

- of

- sight (VLO S) only. T he unmanned aircraft must remain within VLOS of the operator and/or visual observer.



### • At all times the sUAS must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other tha n corrective lenses.



### • The sUAS may not operate over any person(s) not directly involved in the operation of the sUAS

.



### • All operations will be conducted in controlled or restrictive access areas.



### • All Explorers Like Us sUAS operations may be conducted only in d aylight

- only operations (official sunrise to official sunset, local time).



### • All Explorers Like Us sUAS operations m ust yield right

- of

- way to other aircraft, manned or unmanned.



### • All Explorers Like Us sUAS operations m ust use a visual observer (VO) in addition to an authorized PIC

.



### • First

- person view camera on the sUAS cannot sati sfy “see

- and

- avoid” requirement, but can be used as long as requirement is satisfied in other ways.



### • All Explorers Like Us sUAS operations operate under thee a m aximum airspeed of 50 mph (44 knots).



### • All Explorers Like Us sUAS operations operate under a m aximum altitude of 500 feet above ground level (AGL).



### • All Explorers Like Us sUAS operations require a m inimum weather visibility of 3 miles from control station.



### • The s UAS may not operate within five (5) nautical miles of an airport unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA.



### • No person may act as an operator or VO for more than one unmanned aircraft operation at one time.



### • No careless or reckless operations of Explorers Like Us sUAS are permitted under any
circumstances

.



### • The Explorers Like Us sUAS o perator s are responsible for maintaining and inspecting the sUAS to ensure that it can operate safely in terms of maintenance, functionality and flight plan characteristics

.



### • Each sUAS operated r equires preflight inspection by the operator.



### • No person may not operate or be a VO for a sUAS operation if he or she knows or has reason to believe they have any physical or mental condition that would preclude the safe operation of a
sUAS.



### • Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics mush undergo a functional flight test prior to conducting further operation sand be signed off by no fewer than two (2) authorized persons consisting of an authorized PIC

and/or VO.



### • All Explorers Like Us sUAS are equipped with GPS and return to home functionality should loss of link occur.



### • The PIC must abort the flight in the ev ent of unpredicted obstacles or emergencies.



### • The sUAS will not be operated less than 500 feet below, or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.



### • The sUAS must be operated within all Feder al, state and local laws and covenants.



### • The sUAS may not be operated in such a manner as to compromise the reasonable expectations of an individual’s privacy.



### • The Explorers Like Us sUAS may not be used for in conjunction with any investigation (private,
ci vil and/or criminal) of any individual or entity.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for det ails.



## Operations

Explorers Like Us is a production company (photography, videography, audio acquisition) located in Fishers, Indiana. Explorers Like Us utilizes two (2) DJI sUAS platforms for the purpose of ph otography and videography in controlled access areas : the DJI Phantom 3 Professional and DJI Inspire . Explorers Like Us is committed to offering safe, responsible and ethical sUAS flight operations.

Current and intended future applications of Explorers L ike Us’ sUAS are flown in low risk, controlled access areas including: motion picture aerial photography, film acquisition and digital image acquisition, commercial development, civil planning, economic development, construction planning and/or documentat ion, corporate marketing and/or promotions, government and/or civic photography, videography and video production

. Protocols and controls are in place to ensure safety of propert y and nonparticipating individuals. These include, but are not limited to: not operating over any persons not directly involved in the operation, conducting all operations in controlled or restricted access areas, and posting warning signs for the public at the perimeter of the controlled access area when necessary . Protocols and co ntrols are executed before, during, and after every flight to ensure safety, and are outlined by the PIC and VO and submitted to Explorers Like Us at the end of each acquisition

.
Explorers Like Us believes that the public can benefit greatly with the add ition of sUAS photography and videography in the local market by providing safer photography and videography than that provided by traditional forms of manned aircraft.
Current use of manned aircraft are noisy and operate with appreciably greater potential risk. Explorers Like Us can perform tasks at a lower risk level while at the same time not disrupt ing the surrounding community. Benefits of sUAS photography and videography include: less noise (electric motors vs gas powered engines), significan tly reduced aircraft size and weight (sUAS are less than 55 lbs; our current aircraft all weigh less than 8 lbs), slower flight speeds (1 MPH to less than 50 MPH), carrying no pilots orcrew, no gallons of flammable fuel onboard, and greater versatility to safely capture closer, lower

altitude shots.
Explorers Like Us’ first priority is safety. All operations performed will meet FAA safety standards, keeping the NAS safe and clear for manned aircraft flight.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for det ails.

## Section 5: Requested Exemptions from Regulations

14 C.F.R. Part 21 Subpart H

- Airworthiness Certificates

[Per RIN: 2120

– AJ60; Docket No.: FAA

- 2015

- 0150; Notice No.: 15

- 01; NPRM 2

- 15

- 2015]

“The FAA believes that treating small UAS as a single category without airworthiness certification would accommodate a large majority of small UAS businesses and other non

- recreational users of UAS. The operational limits in this proposed rule would mitigate risk associated with small UAS operations in a way that would provide an equivalent level of saf ety to the NAS with the least amount of burden to
business and other non

- recreational users of even the smallest UAS.”

- Pages 53

- 54



### 14 C.F.R. § 45.23 (b)

- Display of marks; general.

[Per RIN: 2120

– AJ60; Docket No.: FAA

- 2015

- 0150; Notice No.: 15

- 01; NPRM 2

- 15

- 2015]
“The FAA acknowledges that some small unmanned aircraft may be too small to comply with the
minimum

- display

- size requirements of part 45. However, as mentioned previously, part 45 already contains a provision, § 45.29(f), that would address this issue by allowing the too

- small aircraft to simply display its registration number in as large a manner as practicable. Accordingly, the size of the small unmanned aircraft would not be a barrier to compliance with the provisions of Subpart C of part 45.”

- Page 130



### 14 C.F.R. § 61.113 (a) & (b)

- Private Pilot Privileges and Limitations: Pilot in Command.

[Per RIN: 2120

– AJ60; Docket No.: FAA

- 2015

- 0150; Notice No.: 15

- 01; NPRM 2

- 15

- 2015]
“The FAA proposes to require that applicants for an unmanned a ircraft operator certificate with a small UAS rating pass an initial knowledge test to demonstrate that they have sufficient aeronautical knowledge to safely operate a small UAS. The FAA proposes a knowledge test rather than a required training course in o rder to provide applicants with flexibility as to the method that they use to acquire aeronautical knowledge. ”

- Page 103
Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations and applicable knowledge level by requiring the PIC operating the sUAS to have at minimum a sport pilot’s certification rather than a commercial pilot’s license to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is remotely contro lled by a ground

- based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 allowing sUAS use by a sport pilot as the PIC exceeds the present level of safety so ught by 14 C.F.R. §61.113 (a) and (b).

### 14 C.F.R. § 91.7 (a)

- Civil aircraft airworthiness.

[Per RIN: 2120

– AJ60; Docket No.: FAA

- 2015

- 0150; Notice No.: 15

- 01; NPRM 2

- 15

- 2015]

“FAA noted that, as mentioned previously, due to their light weight, small unmanned aircraft generally pose a significantly lower risk to people and property on the ground than manned aircraft. This relatively low risk is mitigated even further by the see

- and

- avoid and loss

- of

- positive

- control provisions of this proposed rule, which are discussed above. Accordingly, based on existing information, the FAA believes that requiring small UAS operators to conduct inspection and maintenance of the small UAS pursu ant to the existing regulations of part 43, or to obtain a PTO, would not result in significant safety benefits. As a result, this proposed rule would not require small UAS compliance with part 43 or the application for, or issuance of, a PTO.

Instead, this proposed rule would require, in § 107.21(b), that prior to each flight, the operator must inspect the small UAS to ensure that it is in a condition for safe operation. The operator could do this by, for example, performing a manufacturer

- recommended p reflight inspection or performing an on

- the

ground test of the small UAS to determine whether safety

- critical systems and components are working properly.”

- Page 90
The regulation requires that no person may operate a civil aircraft unless it is in airw orthy 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 the aircraft and the requirements contained in the sUAS User and Maintenance manuals, for maintenance and use of safety check lists prior to each flight, as set forth in Explorers Like Us’ FOM, 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) states that no person may operate a U.S.

- registered civil aircraft ...unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual. The sUAS, 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 man ual at the ground control point where the pilot flying the sUAS will have immediate access to it.



### 14 C.F.R. § 91.103

- Preflight action.

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As FAA ap proved flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before commencement of flight

.

### 14 C.F.R. § 91.109 (a)

- Flight instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircr aft has fully functioning dual controls. SUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio
communica tions. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft.



### 14 C.F.R. § 91.119 (c)

- Minimum safe altitudes: General.

[Per RIN: 2120

– AJ 60; Docket No.: FAA

- 2015

- 0150; Notice No.: 15

- 01; NPRM 2

- 15

- 2015]

“With regard to the vertical boundary, the FAA proposes, in § 107.51(b), to set an altitude ceiling of 500 feet above ground level (AGL) for small UAS operations that would be subject to this proposed rule. The FAA chose to propose 500 feet as the vertical area

- of

- operation boundary because most manned aircraft operations take place above 500 feet. Specifically, most manned aircraft operations conducted over uncongested areas must be flown at an altitude above 500 feet AGL, while most manned aircraft operations conducted over congested areas must be flown at an even higher altitude. Thus, a 500

- foot altitude ceiling for small UAS operations would create a buffer between a small unmanned air craft and most manned aircraft flying in the NAS. Even though some manned aircraft operations take place at an altitude below 500 feet, there is significantly less air traffic at or below 500 feet than there is above 500 feet altitude. As a result of this difference in air

- traffic density, the FAA has determined that small UAS operations would not pose a significant risk to manned aircraft operations taking place below 500 feet altitude if proper precautions are taken by the small UAS operator.”

- Pages 77

- 78



### 14 C.F.R. § 91.121

- Altimeter settings.

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As a sUAS may not have a barometric altimeter, but instead GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the operator confirming
the altitude of the launch site shown on th e GPS altitude indicator and logged in the flight log before flight.



### 14 C.F.R. § 91.151 (a)

- Fuel requirements for flight 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, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes . . . .”Proposed relief would b e that Explorers Like Us be prohibited from beginning a flight unless

(considering wind and forecast weather conditions) there is enough available power for the sUAS to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.



### 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b)

- Maintenance Inspections

[Per RIN: 2120

– AJ60; Docket No.: FAA

- 2015

- 0150; Notice No.: 15

- 01; NPRM 2

- 15

- 2015]

“FAA noted that, as mentioned previously, due to their light weight, small unmanned aircraft generally pose a significantly lower risk to people and property on the ground than manned aircraft. This relatively low risk is mitigated even further by the see

- and

- avoid and loss

- of

- positive

- control provisions of this proposed rule, which are discussed above. Accordingly, based on existing information, the FAA believes that requiring small UAS operators to conduct inspection and maintenance of the small UAS pursuant to the existing regulations of part 43, or to obtain a PTO, would not result in significant safety benefits. As a result, this proposed rule would not require small UAS compliance with part 43 or the application for, or issuance of, a PTO.

Instead, this proposed rule w ould require, in § 107.21(b), that prior to each flight, the operator must inspect the small UAS to ensure that it is in a condition for safe operation. The operator could do this by, for example, performing a manufacturer

- recommended preflight inspection or performing an on

the

- ground test of the small UAS to determine whether safety

- critical systems and components are working properly.”

- Page 90
Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these
section s will not apply. Maintenance will be accomplished by the operator. An equivalent level of safety will be achieved because the sUASs are limited in size, will carry a small payload and operate only in controlled access areas for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 500 feet AGL. As provided in the FOM, the operator will ensure that the s UAS is in working order prior to flight, perform any required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition.



## Protection of Rights and Privacy

sUAS PIC, VO, or any other person involved in flight mission a re to observe privacy rights or expectations of the public. Any person involved in any unlawful flights that may jeopardize someone's privacy right or expectations will be held accountable for their actions and is ground for immediate
termination

. Explorer ’s Like Us has voluntarily adopted a stringent privacy policy that expressly prohibits any use of our sUAS vehicles in any manner inconsistent with the protections and respect of the reasonable rights of privacy of any and all individual’s incidental to th e filming, photographic, research or otherrelated sUAS activity. We also do not permit any Explorers Like Us sUAS to take part in any private, civil

or Federal criminal, civil or any other investigation of any individual or entity.



## Public Interest

As established by the sUAS exemptions already granted by the FAA, allowing commercial operations of sUASs for aerial videography and photography will enhance safety by reducing risk. Conventional aerial operations, using turbine aircraft, operate at low al titudes and present the risks associated with aircraft that weigh around 4,000 pounds, and which carry large amounts of fuel. Such aircraft must also fly to and from the location. In contrast, a sUAS weighing fewer than 55 pounds and powered by batteries e liminates virtually all of that risk given the small size and lack of combustible fuel. The sUAS is carried, and not flown, to a location. In this regard, the sUAS carries no passengers or crew and, therefore, will not expose them to the risks associated w ith manned flights.

The operation of sUASs conducted under Explorers Like Us’ strict flight conditions in addition to the FAA requirements and manufacturer recommendations will provide an equivalent level of safety supporting the grant of the exemption r equested herein. The sUASs operate at slow speeds, close to the ground, and in a controlled access environment. As a result, they are far safer than conventional operations conducted with turbine helicopters flying near the ground and people.



## Conclusion

Explorers Like Us is committed to supporting and promoting the safe responsible and ethical implementation of sUAS into our National Airspace System (NAS). Explorers Like Us can and will perform safe, efficient, ethical and responsible sUAS flight operat ions and promote legal flight operations to ensure greater public safety and discouraging unlawful use, while lessening the risk to pi lots, property, and civilians.
Should you have any questions or requests for other informati on, please contact us directly. We will be happy to get the requested information a s soon as possible.

Kevin Williams Senior Partner, Explorers Like Us LLC K.Williams@ExplorersLikeUs.com
317.284. 1423