1

November	2, 2015 U.S.	Department	of	Transportation, Docket Operations West	Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590 RE:	Petition	to	the	FAA	for	Section	333	Exemption
Dear	Sir	or Madam: Chop Shop Pictures, LLC dba Raptor Aerial Systems hereby submits to the Federal Aviation Administration, pursuant to the FAA Modernization and Reform Act of 2012, an exemption for petition,	in accordance with Section 333 of	the	Act. This	letter	provides requested	information	as	listed	in	the	FAA’s	“Public	Guidance for	Petitions	for	Exemptions	Filed	under	Section	333”. **Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	Background:** Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	is	video	production	co mpany that	has	been	in	business	for	more	than	ten	years.	It	is	comprised	of	video	editors, photographers,	videographers,	writers	and	producers	offering	video	creation services	for	corporate	and	broadcast	clients. **Purpose	for	the	Exemption** Chop	Shop Pictures,	LLC	dba	Raptor	Aerial	Systems ’ requested	exemption	would permit	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	to	operate	SUASs	under controlled	conditions	in	airspace	that	is	(1)	limited	(2)	predetermined	(3)	controlled as	to	access,	and	(4) would	provide	safety	enhancements	to	the	already	safe operations	of	those	aircraft	of	similar	size,	weight,	speed,	and	operating capability. Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems ’ exemption	request	would permit	its	commercial	operation	of	S UAS	for	aerial	photography	and	videography	in tightly	controlled	and	limited	airspace.	Aerial	photography	and	videography	services will	be	offered	to	homeowners,	realtors,	builders,	contractors,	and/or	inspectors	for use	in,	but	not	limited	to,	real	estate marketing,	safer	inspections	of	home	and building	exteriors	and	closed	set	filming.	All	operations	will	be	conducted	on	private property	and	with	the	written	and/or	oral	permission	of	the	property	owner(s). Operations	will	always	be	conducted	in	areas	that	are	clear	of	all	people,	except	the pilot	in	command	(PIC)	and	the	Visual	Observer.	Such	operations	will	ensure	that the	SUAS	will	not	create	a	hazard	to	users	of	the	national	airspace	system	or	the public.	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Syste ms	operation	will	not	differ significantly	from	the	situation	described	in	Grant	of	Exemption	No.	12205	(FP AeroSolutions,	LLC).2

**Contact Information**  John	Robinette Chop	Shop	Pictures,	LLC dba	Raptor	Aerial	Systems 324	Crepe	Myrtle	Lane Murphy,	TX	75094 jr@chopshoppictures.com **List	of	Specific	Section	of	14	CFR	for	which	exemption	is	sought:** The	listing	matches	the	list	on	page	7	of	the	FAA’s	“Public	Guidance	for	Petitions Filed	Under	Section	333”,	Rev. 9/25/2014 14	CFR	21,	Subpart	H

– Airworthiness Certificates 14	CFR	61.113	(a)	and	(b),	Certification:	Pilots,	Flight	Instructors,	and Ground Instructors 14	CFR	91.7(a),	Airworthiness	required	for	operation 14	CFR	91.105,	Flight	crewmembers	at	stations 14	CFR	91.119(c),	Minimum	safe	altitudes 14	CFR	9 1.121,	Altimeter	settings 14	CFR	91.151,	Fuel	requirements	for	flights	in	VFR	conditions 14	CFR	91.405	(a),	Maintenance required 14	CFR	91.407	(a)(1),	Operations	after	maintenance 14	CFR	91.409	(a)(1)	and	(2), Inspections 14	CFR	91.417	(a)	and	(b) ,	Mainten ance records Section	333	of	the	Reform	Act	grants	the	Secretary	authority	to	determine	(1)	if	an unmanned	aircraft	system,	as	a	result	of	its	size,	weight,	speed,	operational	capability, proximity	to	airports	and	populated	areas,	and	operation	within	visu al	line	of	sight (VLOS)	does	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to national	security,	and	(2)	whether	a	certificate	of	waiver,	certificate	of	authorization, or	airworthiness	certification	under	49	USC	44704	is	required	f or the operation of civil (non

- governmental)	UASs.	Therefore,	if	the	Secretary	determines	that	such vehicles	may	operate	safely	in	the	national	airspace	system,	the	Secretary	shall establish	requirements	for	the	safe	operation	of	such	aircraft	in	the national	airspace system.3

**Operation Overview**  Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	System s’	SUASs	are	quadcopters weighing	7	or	fewer	lbs.	(including	payload).	The	SUASs	have	the	capability	to hover	and	move	in	the	vertical	and	horizontal	planes simultaneously.	They	will operate	only	in	visual	line	of	slight	(VLOS)	and	will	operate	only	in	tightly controlled	and	limited	airspace.	They	are	capable	of	operating	at	speeds	of	up	to	42 knots,	but	will	be	routinely	operated	at	much	lower	speeds.	They	wi ll	routinely	be operated	below	200	feet	above	ground	level	(AGL),	and	never	above	400	feet	AGL. **Aircraft** Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	operates	In s pire	1	SUASs manufactured	by DJI, a	well

- known leader in multirotor technology. DJI strives to bring new perspectives	to	aerial	work to help	companies accomplish	feats	safer, faster and	with	greater	efficiency.	They	have	an	unparalleled	commitment	to	R&D,	a culture	of	constant	innovation,	and	a	focus	on	transforming	complex technology into easy-to
- use devices. The	standard	Inspire	1	quadcopter	package	includes	the	Inspire	1	itself,	camera, gimbal,	propulsion	system,	flight	control	system,	5.8	GHz	remote	controllers,	and 2.4	GHz	Wi

- Fi communication	system.	The	remote	uses	a	5.8	GHz frequency to prevent interference	with	the	video/telemetry	channel.	This	second	channel	allows for	a	constant	connection	with	the	Inspire	1	to	monitor	it	via	an	iPad	that	is	attached to	the	remote	controller. The	Inspire	1	is	about	18	inches	square	in	size.	It	has	a	maximum	ascent	speed	of 10	knots,	a	maximum	descent	speed	of	8	knots,	and	a	maximum	flight	speed	of	42 knots.	While	operating	within	VLOS,	the	remote	control	has	a	range	of	5km.	The total	weight	(including	the	payload)	is approximately 6.5 lbs. Th e Inspire	1 is	equipped	with	a	DJI	flight	control	system.	This	provides	for incredible	ease	of	use	and	stability.	Pilots	can	control	the	Inspire	1’s	movements	in many	directions

– including	pitch	(forward	and	backward),	roll	(left	and	right), elevator	(up and	down),	and	yaw	(turn	left	or	right).	The	flight	control	system	can also	provide	Intelligent	Orientation	Control	(IOC),	failsafe,	battery	level	warnings, and	show	the	aircraft’s	current	heading,	direction,	and	approximate	distance	from home on the	on

- screen radar. The	built

- in	GPS system aids in stabilizing the aircraft and	automatically	and	safely	returns	it	back	to	its	home	point	in	any	case	where communication	between	the	remote	control	and	multirotor	are	lost. The	Inertial	Measurement	Unit	(IMU)	has a	built

- in	inertial	sensor	and	a	barometric altimeter	that	measures	both	attitude	(ATTI)	and	altitude.	The	inertial	measurement tells	the	Inspire	1	how	it’s	tilted.	And	the	gyros	tell	it	if	it’s	rotating	in	any	particular direction.4

The	Inspire	1’s compass	reads	geomagnetic	information	and	assists	the Global Positioning	System	(GPS)	to	accurately	calculate	the	position	and	height	of	the aircraft. The vertical hover accuracy is .5m.	The	horizontal	hover accuracy is	2.5m The	Inspire	1	has	LED	flight indicators	on	the	ends	of	each	of	its	four	rotor	arms.	The LEDs	illuminate	to	indicate	the	status	of	the	flight	control	system	and	alert	the	PIC	of any	possible issues. Such	highly	advanced	capabilities	will	ensure	that	the	SUASs	can	be	safely	operated an d	“not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public.” **Equivalent	Level	of Safety**  In	an	effort	to	join	the	FAA	in	its	mission	to	provide	the	safest,	most	efficient aerospace	system	in	the	world	and	to	minimize	the	risk	to	the	NAS or	to	persons	and property	on	the	ground,	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	agrees to	be	bound	by	the	following	limitations	and	conditions	when	conducting	commercial operations	under	an	FAA	issued	exemption:
A. For	the	purposes	of	ensuring	SUASs	will	be	operated	within	the	standards	that the	FAA	has	allowed	in	the	AMA	National	Model	Aircraft	Safety	Code (Attachment:	“AmaSafetyCode.pdf”	document.):
1. SUASs	will	not	be	flown:

a. In	a	careless	or	reckless	manner. b. At	a	location	where	SUAS	activities are	prohibited.
2. SUAS	pilots will:

a. Yield	the	right	of	way	to	all	human

---carrying aircraf t. b. See	and	avoid	all	aircraft	and	a	spotter	must	be	used	when appropriate.

c. Not	fly	higher	than	400	feet	above	ground	level	or	within three (3)	miles of	an	airport without	notifying	the	airport operator. d. Not	interfere	with	operations	and	traffic	patterns	at	any	airport, heliport	or	seaplane	bas e	except	where	there	is	a	mixed

- use agreement.

e. Not	exceed	a	takeoff	weight	of	55	pounds	(including payload).5 f. Ensure	the aircraft	is	identified	by	affixing	the	owner’s	contact information	to	the	outside	of	the	SUAS.
g. Not	operate	SUASs	while	under	the	influence	of	alcohol	or	while	using any	drug	that	could	adversely	affect	the	PIC’s	ability	to	safely	control	the model. h. Not	o perate	SUASs	carrying	pyrotechnic	devices	that	explode	or	burn,	or any	device that propels	a	projectile	or	drops any	object	that	creates	a hazard	to	persons	or property. 3. SUASs	will	not	be	flown	unless: a. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. b. An	experienced	pilot	assists	an	inexperienced	pilot.
4. All	pilots	shall	avoid	flying	directly	over	unprotected	people,	vessels, vehicles	or	structures	and	shall avoid	endangerment	of	life	and property	of others. 5. A	successful	radio	equipment	ground

- range check in accordance with manufacturer’s	recommendations	will	be	completed	before	the	first	flight	of	a new	or	repaired	model	aircraft. 6. SUASs	must	use	the	radio	control frequencies currently allowed	by	the Federal	Communications	Commission	(FCC). 7. SUASs	will	not	knowingly	operate	within	three	(3)	miles	of	any	pre

--- existing flying site without a	frequency---management	agreement. 8. Excluding	takeoff	and	landing,	no	SUAS s	may	be	flown	outdoors	closer	than 25	feet	to	any	individual,	except	for	the	PIC	and	the	Visual Observer	(VO) located	at	the	takeoff site. 9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still under power, except to divert it from striking an individual. 10. The	PIC	of	the	SUAS	shall:

a. Maintain	control	during	the	entire	flight,	maintaining	visual	contact without	enhancement	other	than	by	corrective	lenses	prescribed	for the pilot. b. Fly	using	the	assistance	of	a	camera	or First	Person View (FPV) only	in accordance	with	the	procedures	outlined	in	AMA	Document	#550.

c. Fly	using	the	assistance	of	autopilot	or	stabilization	system	only	in accordance	with	the	procedures	outlined	in	AMA	Document	#560.
11. The	flying	area	must	be	cl ear	of	all	utility	wires	or	poles	and	an	SUAV	will not be6 flown	closer than 50	feet to any	above

- ground electric utility lines. 12. The	flying	area	must	be	clear	before	the	engine	is	started,	except	for	PIC	and	the VO.
B. In	addition	to	the	above	rules outlined	by	the	AMA	National	Model	Aircraft Safety	Code	and	in	an	effort	to	enhance	the	safety	offered	by	the	already	safe operations	mentioned	above,	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial Systems	also	agrees	to	be	bound by	the	following	limitations	an d	conditions:
1. Operations	authorized	by	this	petition	for	exemption	are	limited	to	the following	aircraft	described	in	the	operating	documents,	which	is	the	DJI Inspire	1	Unmanned	Aircraft	System,	a	quadrotor	aircraft	with	a	maximum takeoff	weight	of	less than	7	pounds.	Proposed	operations	of	any	other aircraft	will	require	a	new	petition	or	a	petition	to	amend	this	grant.
2. UAS	operations	under	this	petition	are	limited	to	aerial	photography	and videography	services	will	be	offered	to	homeowners,	realtors, builders, contractors,	and/or	inspectors	for	use	in,	but	not	limited	to,	real	estate marketing,	safer	inspections	of	home	and	building	exteriors	and	closed

- set filming.
3. The	UAS will	not	be	flown	at	an	indicated	airspeed	exceeding	42	knots	(22 m/s).
4. The	UAS will	be	operated	at	an	altitude	of	no	more	than	400	feet	above ground	level	(AGL),	as	indicated	by	the	procedures	specified	in	the operating	documents.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL. 5. The	UAS will	be	operated	within	visual	line	of	si ght	(VLOS)	of	the	PIC	at	all times.	This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAA

- issued airman	medical	certificate.
6. All	operations	will	utilize	a	VO.	The	VO	will	be used	to	satisfy	the	VLOS requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and PIC	will	be	able	to	communicate	verbally	at	all	times.	Electronic	messaging	or texting	will	not	be	permitted	during	flight	operations.	The	PIC	will	be desi gnated	before	the	flight	and	cannot	transfer	his	or	her	designation	for	the duration	of	the flight.
7. The	VO	will	not	perform	any	other	duties	beyond assisting	the	PIC	with seeing	and	avoiding	other	air	traffic	and	other	ground	based obstacles/obstructions	and	is	not	permitted	to	operate	the	camera	or	other instruments.7

8. The	operating	documents	will	be	accessible	during	UAS	operations	and	made available to	the	Administrator	upon	request.	The	operator	will	follow	the procedures	as	outlined	in	its	operating	documents.	The	operator	may	update or	revise	its	operating	documents.	It	is	the	responsibility	of	Chop	Shop Pictures,	LLC	dba	Raptor	Aerial	Systems	to	track	such	revisions	and	present updated	and	revised	documents	to	the	Administrator	upon	request.	Chop Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	will	also	present	updated	and revised	documents	if	it	petitions	for	extension	or	amendment.	If	Chop	Shop Pictures,	LLC	dba	Raptor	Aerial	Systems	determines	that	any	update	or revision	would	affect	the	basis	upon	which	the	FAA	granted	this	exemption, then	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	will	petition	for amendment	to	their	exemption.	The	FAA’s	UAS	Integration	Office	(AFS

- 80) will be contacted if questions arise regarding	updates	or	revisions	to	the operating	documents.
9. Prior	to	each	flight	the	PIC	will	inspect	the	UAS	to	ensure	it	is	in	a	condition for	safe	flight.	If	the	inspection	reveals	a	con dition	that	affects	the	safe operation	of	the	UAS,	the	aircraft	is	prohibited	from	operating	until	the necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a condition	for	safe	flight.	The	Ground	Control	Station	will	be	included	in	the preflight	inspection.	All	maintenance	and	alterations	will	be	properly documented	in	the	aircraft records.
10. Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS operation	or	flight	characteristics,	e.g.	replacement	of	a	flight	critical c omponent,	must	undergo	a	functional	test	flight	in	accordance	with	the operating	documents.	The	PIC	who	conducts	the	functional	test	flight	will make	an	entry	in	the	UAS	aircraft	records	of	the	flight.	The	requirements	and procedures	for	a	functional	test flight	and	aircraft	record	entry	will	be	added to	the	operating	documents.
11. The	preflight	inspection	section	in	the	operating	documents	will	be amended	to	include	the	following	requirement:	The	preflight	inspection	will account	for	all	discrepancies,	i.e. inoperable	components,	items,	or equipment,	not	covered	in	the	relevant	preflight	inspection	sections	of	the operating	documents.
12. The	operator	will	follow	the	manufacturer’s	UAS	aircraft/component, maintenance,	overhaul,	replacement,	inspection,	and	life limit	requirements, with	particular	attention	to	flight	critical	components	that	may	not	be addressed	in	the	manufacturer’s	manuals.
13. The	operator	will	carry	out	their	maintenance,	inspections,	and	record

-8 keeping	requirements,	in	accordance	with	the	operating documents. Maintenance,	inspection,	and	alterations	will	be noted	in	the	aircraft	logbook, including	total	flight	hours,	description	of	work accomplished,	and	the	signature of	the	authorized	UAS	technician	returning	the	UAS	to	servic e. 14. Each	UAS	operated	will	comply	with	all	manufacturer	Safety Bulletins. 15. An	authorized	person	will	make	a	record	entry	in	the	aircraft	record	of	the corrective	action	taken	against	discrepancies	discovered	between inspections.
16. Qualification	for	the Pilot	in	Command

a. Certifications: A Pilot	in	Command	(PIC)	possessing	at	least	a	private	pilot certificate	and	at	least	a	third

- class	medical	certificate	will	conduct Operations. b. Logged Hours: Prior to operations the PIC will have accumulated and logged 2 0 flights or log 20 hours of flight time (the greater of the two) with	the Inspire	1.

c. Currency:	The	PIC	will	have	accomplished,	during	dedicated training sessions, 3	take

- offs and landings in	the preceding 90 days	(for	currency purposes). d. Flight Training : i. Successfully	learn	and	demonstrate	all	flight	maneuvers	on http://www.dji.com/product/inspire

- 1/video. ii. Study	and	be	familiar	with	all	sections of	the	“Inspire	1	User Manual”

. iii. Study	and	be	familiar	with	all	sections	of	the	“Inspire	1	Safety Guidelines”. (Attachment: “Inspire_1_Safety_Guidelines_en.pdf”	document). iv. Completed	DartDrones,	LLC	training	courses	Drone	Industry	101, Basic	Training	and	Advanced	Missions.

e. Emergency	and	Evasive	Maneuvers:	The	PIC	will	have	demonstrated	the ability	to	s afely	operate	the	Inspire	1	in	a	manner	consistent	with	how	it will	be	operated	in	for	actual	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial Systems	operations,	including	evasive	and emergency maneuvers	and maintaining	appropriate	distances	from	people,	vessels,	vehicles	and structures.	The	logged	hours	referenced	above	will	document	this.9

17. UAS	operations	will	not	be	conducted	during	night,	as	defined	in	14	CFR § 1.1. All	operations	will	be	conducted	under	visual	meteorological	conditions (VMC).	Flights	under	special	visual	flight	rules	(SVFR)	are	not	authorized.
18. The	UAS	will	not	operate	within	5	nautical	miles	of	an	airport	reference point as denoted on	a current	FAA

- published aeronautical chart unless a letter	of	agreement	with	that	airport’s	management	is	obtained,	and	the operation	is	conducted	in	accordance	with	a	NOTAM.	The	letter	of agreement	with	the	airport	management	will	be	made	available	to	the Administrator	upon	request.
19. The	UAS	will	not	be operated	less	than	500	feet	below	or	less	than	2,000 feet	horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute	miles from	the	PIC.
20. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	return	to a predetermined location	within	the	private	or	controlled

- access property and	land	or	be	recovered	in	accordance	with	the	operating	documents.
21. The	PIC	will	abort	the	flight	in	the	event	of	unpredicted	obstacles or emergencies	in	accordance	with	the	operating	documents.
22. The	PIC	is	p rohibited	from	beginning	a	flight	unless	(considering	wind	and forecast	weather	conditions)	there	is	enough	power	to	fly	at	normal cruising	speed	to	the	intended	landing	point	and	land	the	UA	with	30% battery	power	remaining	in	accordance	with	the	operatin g documents.
23. The	operator	will	obtain	an	Air	Traffic	Organization	(ATO)	issued Certificate	of	Waiver	or	Authorization	(COA)	prior	to	conducting	any operations	under	this	petition	for exemption.
24. All	aircraft	operated	in	accordance	with	this	petition	will be	identified by serial	number,	registered	in	accordance	with	14	CFR	part	47,	and	have identification	(N

- Number)	markings	in	accordance	with	14	CFR	part	45, Subpart	C.	Markings	will	be	as	large	as practicable.
25. Before	conducting	operations,	the	radio frequency	spectrum	used	for operation	and	control	of	the	UA	will	comply	with	the Federal Communications	Commission	(FCC)	or	other	appropriate	government oversight	agency	requirements.
26. The	documents	required	under	14	CFR	§§	91.9	and	91.203	will	be	availabl e to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time	the	aircraft	is operating.	These	documents	will	be	made	available	to	the	Administrator	or any	law	enforcement	official	upon	request.10

27. The	UAS	will	remain	clear	and	yield	the	right	of	way	to	all other	aviation operations	and	activities	at	all	times.
28. The	UAS	will	not	be	operated	by	the	PIC	from	any	moving	device	or vehicle.
29. Flight	operations	will	be	conducted	at	least	500	feet	from	all nonparticipating	persons	(persons	other	than	the	PIC	or	VO), vessels, vehicles,	and	structures unless:

a. Barriers	or	structures	are	present	that	sufficiently	protect nonparticipating	persons	from	debris	in	the	event	of	an	accident.	The operator	will	ensure	that	nonparticipating	persons	remain	under	such protection. If	a	situation	arises	where	nonparticipating	persons	leave	such protection	and	are	within	500	feet	of	the	UAS,	flight	operations	will	cease immediately and/or;
b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the land	owner/controller	h as	granted	permission	and	the	PIC	has	made	a safety	assessment	of	the	risk	of	operating	closer	to	those	objects	and;

c. Operations	near	the	PIC	or	VO	do	not	present	an	undue	hazard	to the	PIC or	VO	per	§	91.119(a).
30. All	operations	will	be conducted over private or	controlled

- access property with	permission	from	the	property	owner/controller	or	authorized representative.	Permission	from	property	owner/controller	or	authorized representative	will	be	obtained	prior	to	the	beginning	of	every flight.
31. Any	inci dent,	accident,	or	flight	operation	that	transgresses	the	lateral	or vertical	boundaries	of	the	operational	area	as	defined	by	the	applicable COA will be	reported	to	the	FAA’s	UAS	Integration	Office	(AFS

- 80) within 24	hours.	Accidents	must	be	reported	to	the	National	Transportation Safety	Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site: www.ntsb.gov. The	operation	of	SUASs,	weighing	less	than	7	lbs.,	conducted	in	the	strict	conditions as	outlined	above, will	provide	an	equivalent	level	of	safety	supporting	the	grant	of exemptions	requested	herein,	including	exempting	the	applicant	from	the requirements	of	Part	21	and	allowing	commercial	operations. These	lightweight	aircraft	operate	at	slow	speeds,	close to	the	ground,	and	in	a tightly	controlled	environment.	As	a	result,	they	offer	a	much	safer	way	to	capture aerial	photography	and	videography.	Furthermore,	the	proposed	operations11

represent	a	safety	enhancement	to	the	already	safe	operations	that	have	be en granted	by	the	FAA	for	the	establishment	of	the	AMA	National	Model	Aircraft	Safety Code. **Preflight	Action	Plan** The PIC will follow a comprehensive	pre

- flight checklist to ensure that the SUAS is in a	condition	for	safe	flight.	This	plan	will	be improved	as	needed	in	order	to	ensure	all known	safety	precautions	and/or	safety	precautions	suggested	by	the	manufacturer are	being	accounted	for. Pre

---fl ight	I ns p ection 1. Check	that	the	remote	control,	Inspire	1	battery	and iPad/smartphone	are	all	fully charged. 2. Verify	that	the	Inspire	1	battery	is	not	swollen	or	damaged	in	any	way. Clean	the	contact	needles	and	pads	if necessary. 3. Turn	the	motor	shafts	with	fingers	and	verify	they	are	smooth without	excessive	play	or binding. 4. Verify	that	the	propellers are	mounted	correctly.	Propellers	with	a	black top	should	be	mounted	on	the	mount	shafts	that	have	a	black	dot. Propellers	with	a	silver	top	should	be	mounted	on	the	mount	shafts	that have	a	silver	dot.	Each	propeller	should	spin	all	the	way	down	onto	the motor	shaft. 5. Run	finger	along	the	edge	of	edge	blade	to	check	for	any	rough edges. 6. Flex	both	sides	of	the	propeller	blades	to	check	for	hairline	cracks	where the	blades	connect	in	the	center	of	the propeller. 7. Verify	that	the	landing	gear	is	secure	(not cracked/broken/loose). 8. Verify	that	the	compass	and	compass	cable	is	firmly	attached	to	the landing gear. 9. Verify th at	the M icro---SD card	has bee n	ins e rted	and	formatted. 10. Verify	that	the	damping	absorbers	are	not	broken	and/or	worn. 11. Verify th at	the anti

---d rop	pins are	in pla c e	an d	locked. 12. Attach	the	gimbal	to	the	Inspire	1. 13. Verify	that	the	camera	is	secure	and	clean.	Inspect	the	camera	ribbon cables	for	tears	and/or	signs	of wear. 14. Verify	that	the	iPad/smartphone	GPS	is	enabled. 15. Set	the	iPad/smartphone	to	do

- not
- disturb	mode	to	prevent	distractions while	flying. 16. Set	the	iPad/smartphone	to	forget	any	Wi

- Fi n etworks i n	range i n order to	p revent th e	Wi

- Fi	connection	from	changing	mid

---fl ight. 17. Verify	that	the	iPad/smartphone	audio is	on	to	ensure	the	low battery	warning	and	other	alarms	can	be	heard.
Power Up 18. Verify	that	S1	and	S2	are	in	the	top	position	on	the	remote	control. 19. Power	on	the	equipment	in	the	following	sequential order:12 a. Remote	Control	(2	beeps	to	indicate	it’s	in	FC C	mode)
b. Insert	and	start	the	Inspire	1	battery.

c. Connect	and	iPad/smartphone
20. Watch	the	Inspire	1	LED	startup	sequence	for	abnormal	indications.	The rear	LEDs should blink green	for	at least 10

- 15	seconds	to indicate that it locked	onto	6+	satellites	and has	marked	the	home	point	(for	use	by	the failsafe feature). 21. Calibrate	the	Inspire	1’s	compass. 22. Place	the	Inspire	1	on	an	open,	flat	ground	with	the	battery	indicators facing	towards	the	PIC	at	least	10	feet away. DJI	Go	Application 23. Launch	the	“DJI	Go”	ap plication	on	the	smartphone.

a. Verify	the	number	of	satellites	is	6+.
b. Verify the	Wi

- Fi si gnal strength.

c. Verify	that	the	Inspire	1	and	remote	control	batteries	are reporting	a	full charge.
d. Verify	that	both	the	PIC’s	and	Inspire	1’s	location	is	the	same before	taking	off	to	ensure	the	home	point	has	been	accurately marked.

e. Verify the location of the Inspire 1 in the “Flight Radar”. If it’s not in the correct position/direction and/or shows a distance of	“N/A”,	it	did	not	mark	the	home	point.

Ready	to Fly 24. Verify	that	the	remote	control	antenna	is	perpendicular	to	the	ground (pointing skyward). 25. Verify	that	the	rear	LEDs	are	still	slowly	blinking	green	and	still connected	to	6+ satellites. 26. Start	the	Inspire	1	motors	using	the	CSC	command	on	the	remote control. 27. Verify	that	the	motors	are	functioning	normally,	are	not	making	any unusual	noises,	and	are	all	spinning	at	the	same	speed. 28. Verify	that	the	area	is	still	clear	of	obstructions,	people,	power	lines, etc. 29. Take	off and hover	at	about	6

- 8	feet	above	the	takeoff	point	to verify that13 the	Inspire	1	has	a	solid	GPS	lock.	If	any	abnormalities	are	noticed (drifting,	flying	in	circles,	etc.),	land	immediately	and	repeat	the	“Pre

flight	Inspection”	and	“Power	Up” sequences. 30. Verify	that	the	Inspire	1	holds	a	steady	position	while	yawing	360 degrees. 31. Verify	that	the	Inspire	1	responds	appropriately	to	all	controls

– yaw left/right,	pitch	forward/backward,	roll	left/right,	and	throttle up/down. **Preventative	Maintenance** A	comprehensive	preventative	maintenance	plan	will	be	followed	in	order	to	ensure the	SUAS’s	software	is	up	to	date,	the	batteries	are	in good health, and the aircraft itself	is	always	ready	for	safe	flight. (Attachment:	“Inspire_1_Maintenance_ManualV1.0_e n .pdf”	document). **Public	Interest** Granting	this	exemption	would	benefit	the	public	as	a	whole.	SUASs	offer	a strong	equivalent	level	of	safety,	a	reduction	in	environmental	impacts,	and	are free	from	the	harmful	emissions	associated	with	the	manned aircraft	that	are currently	used	for	aerial	photography	and	videography.	Due	to	the	size	of	the SUAS	and	the	tightly	controlled	and	limited	airspace	in	which	the	SUAS	will operate,	approval	of	this	application	presents	no	risk	to	the	public. Furthermore,	the	public	will	be	able	to	legally	acquire	aerial	photography	and videography	to	help	in,	but	not	limited	to,	advertising	homes	for	sale, advertising	uninhabited	home	lots,	use	of	photos	and	video	as	an	aid	when researching	homes	for	sale	on	the	market,	or safely	accessing	high	and/or awkward	areas	of	a	home’s	exterior	to	assess	damage	that	needs	to	be	repaired. **Privacy** Since	the	areas	being	photographed	or	filmed	will	be	on	private	property,	accessed only	after	given	written	and/or	oral	consent	by	the	pro perty	owner(s),	and	clear	of all	people,	except	for	the	PIC	and	the	PIC's	helper(s),	approval	of	this	application presents	no	risk	to	the	public privacy. **National Security**  Due	to	the	size	of	the	SUAS	and	the	tightly	controlled	and	limited	airspace	in	whi ch the	SUAS	will	operate,	approval	of	this	application	presents	no	risk	to	national security. **Requested	Exemptions** Chop Shop Pictures, LLC dba Raptor Aerial Systems requests exemption from the following regulations since it’s not possible to fully comply with them, and since attempting	to	follow	them	for	the	purposes	of	operating	a	SUAS	would	be	a	burden:14 **Airworthiness	Certificates** 14	CFR,	Subpart H Part	21	covers	certification	procedures	for	products	and	parts.	Subpart	H specifies	requirements	for	Airworthiness	Certificates	for	various	aircraft types.	Small	unmanned	aircraft	systems	are	not	specifically	called	out	and addressed	in	these	rules.	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems will,	in	lieu	of	airworthiness	certification	by	aforemention ed	rule,	if exemption	is	granted,	ensure	that	the	Inspire	1	system	is	in	compliance	with its	operating	documents	as	described	herein.	The	PIC	will	assure	that	all Preflight	Checks	are	completed	and	documented	and	there	is	full	compliance with	all	manufactu rer’s	operation	and	maintenance	documents.	Due	to consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associated with	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems’	proposed	Inspire	1 we	believe	it	will	not	create	a	hazard	to	users	of the	National	Airspace	System (NAS)	or	the	public.	Therefore,	a	request	is	made	for	exemption	from	14	CFR part	21,	and	any	associated	noise	certification	and	testing	requirements	of part	36. **Private	pilot	privileges	and	limitations:	Pilot	in	command** 14	CF R	61.113 (a) Under	current	regulations,	civil	operations	for	compensation	or	hire require	a	PIC	holding	a	commercial	pilot	certificate	per	14	CFR	Part	61. Based	on	the	Private	Pilot	limitations	in	accordance	with	pertinent	parts	of 14 CFR	§61.113(a),	a	pi lot	holding	a	Private	Pilot	certificate	cannot	act	as	a PIC	of	an	aircraft	for	compensation	or	hire.	However,	in	Grant	of	Exemption No.	11062	to	Astraeus	Aerial	(Astraeus),	the	FAA	determined	that	a	PIC with	a	private	pilot	certificate	operating	the	Astrae us	UAS	would	not adversely	affect	operations	in	the	NAS	or	present	a	hazard	to	persons	or property	on	the	ground. Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	operation	will	not	differ significantly	from	the	situation	described	in	Grant	of	Exemption No.	11062 (Astraeus	Aerial).	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	plans to	operate	over	private	property	with	controlled	access	in	the	NAS.	With	the similar	nature	of	the	proposed	operating	environment	to	that	of	Astraeus, the	parallel	nature of	Private	Pilot	aeronautical	knowledge	requirements	to those	of	commercial	requirements	[ref:	Exemption	No.	11062],	and	the airmanship	skills	necessary	to	operate	the	UAS,	Chop	Shop	Pictures,	LLC	dba Raptor	Aerial	Systems	believes	that	the	additional	airm anship	experience	of a	commercially	certificated	pilot	would	not	correlate	to	the	airmanship	skills necessary	for	the	specific	proposed	operations.	Therefore,	Chop	Shop Pictures,	LLC	dba	Raptor	Aerial	Systems	PICs	will	hold	a	minimum	of	a15 private	pilot	certificate	and a	third

- class	airman medical certificate. **Airworthiness	required	for	operation** 14	CFR 91.7(a) If	the	exemption	from	14	CFR	21,	Subpart	H	(item	1	above)	is	granted,	no airworthiness	certificate	will	be	required.	On	this	basis,	exemption	from 14 CFR	91.7	(a)	is	requested,	presuming	that	airworthy	condition	by	definition in	the	rule	means	having	an	airworthiness	certificate.	Chop	Shop	Pictures, LLC	dba	Raptor	Aerial	Systems	will,	in	lieu	of	airworthiness	certification	by 14	CFR	21,	ensure	that the	Inspire	1	system	is	in	compliance	with	its operating	documents	as	described	herein.	The	PIC	will	assure	that	all Preflight	Checks	are	completed	and	documented	and	execute	full	compliance with	all	manufacturer’s	operation	and	maintenance	documents. **Fli ght	crewmember	at	stations**  14	CFR 91.105 This	part	requires	certain	actions	by	onboard	crewmembers.	Since	the Inspire	1	is	unmanned,	an	exemption	from	this	rule	is requested. **Minimum	Safe Altitudes**  14	CFR 91.119(c) This	regulation	requires	all operation	to	remain	no	closer	than	500	feet from	persons,	vessels,	vehicles,	and	structures.	Chop	Shop	Pictures,	LLC	dba Raptor	Aerial	Systems	requires	relief	from	§	91.119(c)	is	because	all operations	will	be	conducted	below	400	feet	AGL	and	may	be	operated closer	than	500	feet	from	persons,	vessels,	vehicles,	and	structures	as described above. Prior	to	conducting	UAS	specific	operations,	all	persons	not	essential	to	flight operations	(nonparticipating	persons)	must	remain	at	appropriate	distances. In	ope n	areas,	the	UAS	will	remain	500	feet	from	all	persons	other	than essential	flight	personnel	(i.e.	the	PIC	and	VO).	If	barriers	or	structures	are present	that	can	sufficiently	protect	nonparticipating	persons	from	debris	in the	event	of	an	accident	then	th e	UAS	may	operate	closer	than	500	feet	to persons	afforded	such	protection.	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial Systems	will	ensure	that	nonparticipating	persons	remain	under	such protection.	If	a	situation	arises	where	nonparticipating	persons	leave such protection	and	are	within	500	feet	of	the	UAS,	flight	operations	must	cease immediately.	The	primary	concern,	when	considering	how	to	immediately cease	operations,	is	the	safety	of	those	nonparticipating	persons.	Operations may	be	conducted	closer	th an	500	feet	to	vessels,	vehicles	and	structures when	the	land	owner/controller	grants	such	permission	and	the	PIC	makes	a16 safety	assessment	of	the	risk	of	operating	closer	to	those	objects. **Altimeter	settings** 14	CFR 91.121 This	regulation	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	the	SUAS	may	not	have	a	barometric	altimeter,	but	instead	a GPS	altitude	read	out,	an	exemption	may	be	needed.	The	operator	will achieve	an	equivalent	level	of	safety	by	confirming	the	altitude	of	the	launch site	shown	on	the	GPS	altitude	indicator	before flight. **Fuel	Requirements	for	Flight	in	V FR	Conditions**  14	CFR	91.151 (a) This	regulation	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;	or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.” Similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. Chop Shop Pictures, LLC dba Raptor Aerial Systems UAS provides low battery warnings at 30% capacity that indicate the PIC must command the UAS’ return to the launch point when low battery capacity voltage is reached. The UAS also provides critical low battery warnings at 15% battery capacity indicating that the UA will begin to descend and land automatically. These factors provide an equivalent level of safety by prohibiting the from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and	land	the	UA	with	30%	battery	power	remaining. **Maintenance	Inspections** 14	CFR	91.405	(a);	14	CFR	91.40 7	(a)(1);	14	CFR	91.409	(a)(1)	and	(2);	14 CFR	91.417	(a)	and (b) 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	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter...,”	and others	shall	inspect	or	maintain	the	aircraft	in	compliance	with	Part	43. Given	that	these	sections	and	Part	43	apply	only	to	aircraft with	an17 airworthiness	certificate,	these	sections	will	not	apply.	Maintenance	will	be accomplished	by	the	operator	pursuant	to	the	aforementioned	Inspire	1	user manual	and	guide.	An	equivalent	level	of	safety	will	be	achieved	because these	small	SUASs	are very	limited	in	size,	will	carry	a	small	payload,	and operate	only	in	restricted	areas	for	limited	periods	of	time.	If	mechanical issues	arise,	the	SUAS	can	land	immediately	and	will	be	operating	from	no higher than 400 feet AGL. As outlined in the aforem entioned Pre

- Flight Action Plan,	the	operator	will	ensure	that	the	SUAS	is	in	working	order	prior	to initiating	flight	and	perform	maintenance	as	required.	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 safety. In	accordance	with	14	CFR	Part	11,	the	following	summary	is	provided	for publication	in	the	Federal Register: The	applicant	seeks	an	exemption	from	the	following	rules:	14	CFR Part	21,	Subpart H;	14	CFR	61.113	(a);	14	CFR	91.7(a);	14	CFR	91.105;	14	CFR	91.119(a);	14 CFR 91.121;	14	CFR	91.151;	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)	to	commercially	operate	small	unmanned aircraft	systems	(55	lbs.	or	less)	in	order	to	safely	and	legally	capture	aerial photography	and	videography	for	use	by	homeowners,	realtors,	builders, contractors,	and/or inspectors	and	closed	set	filming. The	operation	of	SUASs	conducted	in	the	strict	c onditions	outlined	above,	will provide	an	equivalent	and/or	greater	level	of	safety	supporting	the	grant	of	the exemptions	requested	herein,	including	exempting	the	applicant	from	the requirements	of	Part	21	and	allowing	commercial	operations.	These	lightweight aircraft	operate	at	slow	speeds,	close	to	the	ground,	and	in	a	sterile	environment,	and as a result, are far safer than existing operations conducted with helicopters operating	in	close	proximity	to	the	ground,	people,	or	other	buildings	in	the	vicin ity. Given	the	small	size	of	the	SUASs	involved,	the	slow	speed	at	which	they	must	be operated	in	order	to	capture	photos	and	videos,	and	the	restricted	environment within	which	they	will	operate,	the	Inspire	1	demonstrates	that	it	can	be	operated within an	equivalent	level	of	safety	in	which	Congress	envisioned	that	the	FAA	must, by	exemption,	allow	commercial	operations	of	SUASs	to	commence	immediately. Also,	due	to	the	size	of	the	SUASs	and	the	restricted	areas	in	which	the	relevant SUASs	will	operate, approval	of	this	application	presents	no	threat	to	national security.	Given	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority contained	in	the	Federal	Aviation	Act,	the	strong	equivalent	level	of	safety surrounding	the	proposed	operations,	the	significant	public	benefit

– including enhanced	safety,	reduction	in	environmental	impacts,	no	emissions,	ability	to	legally obtain	aerial	photography	and	videography	services

– the	grant	of	the	requested exemptions	is	in	the	public	interest.	Accordi ngly,	Chop	Shop	Pictures,	LLC	dba	Raptor Aerial	Systems	respectfully	requests	that	the	FAA	grant	the	requested	exemption without delay.18

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act

– size, weight,	speed,	operating	capability, proximity	to	airports	and	populated	areas, operation	within	the	visual	line	of	sight,	public	safety,	and	national	security

– provide	more	than	adequate	justification	to	grant	Chop	Shop	Pictures,	LLC	dba Raptor	Aerial	Systems	the	requested	exemption,	allowi ng	for	commercial operations	as	described	herewith. **Summary	for	Publication	in	Federal Register**  Petition	for	Exemption Docket	No.: FAA

-2015

-XXXX Petitioner:	Chop	Shop	Pictures,	LLC dba	Raptor	Aerial	Systems Sections	of	14 CFR Description	of	Relief Sought:	The	petitioner	is	seeking	an	exemption	to utilize	an	unmanned	aircraft	system	(UAS)	to	accomplish	aerial	photography and	videography	services	to	homeowners,	realtors,	builders,	contractors, and/or	inspectors	for	use	in,	but	not	limited	to,	real	estate	marketing	and safer	inspections	of	home	and	building exteriors.

Sincerely, /s/	John	Robinette

John	Robinette,	Owner,	Chop	Shop	Pictures,	LLC dba	Raptor	Aerial	Systems
Enclosures (3 )19