1 UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

FORGET ME KNOT EVENT S , LTD

d.b.a. AERONAUTIC WORKS

FOR AN EXEMPTION, SEEKING RELIEF FROM THE REQUIREM ENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS Part 21, subpart H, Part 27, Sections 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF THE FOLLOWING

UNMANNED AIRCRAFT SYSTEMS:

1) DJI SPREADING WINGS S800 UAS 2) DJI INSPIRE 1 / INPIRE 1PRO UAS 3) DJI PHANTOM 3 UAS 4) 3DR X8 UA S 5) 3DR Solo UAS 6) BIRDSEYEVIEW AEROBOTICS FIREFLY 6 UAS 7) AERYON SKYRANGER UAS 8) AERONAUTIC WORKS Q2 UAS 9) AERONAUTIC WORKS W 21/W22 UAS 10) AERONAUTIC WORKS POLAR UAS

11 ) AERONAUTIC WORKS BOUYANT22 UAS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZA TION AND REFORM ACT OF 2012 (PUBLIC LAW 11295)

Submitted: December 15th, 2015

Edward A. Putnam Forget Me Knot Events, Ltd 15962 Green Springs Drive

Reno, NV 89511 Phone and Email will be sent separately for privacy2 

### TABLE OF CONTENTS

GLOSSARY OF ABBRE VIATIONS: 3

SUMMARY: 5

INTRODUCTION AND INTERESTS OF PETITIONER: 5

UNMANNED AIRCRAFT SYSTEMS BY TYPE: 6

BASIS FOR PETITION: 7

NAME AND ADDRESS OF PETITIONER: 7

THE SPECIFIC SECTIONS OF 14 C .F.R. FROM WHICH APPLIED ART & TECHNOLOGY, LLC SEEKS EXEMPTION: 8

THE EXTENT OF RELIEF FORGET ME KNOT EVENT S LTD. SEEKS AND THE REASON Applied Art & Technology, LLC SEEKS THE RELIEF: 13

THE REASONS WHY GRANTING FORGET ME KNOT EVENT S LTD.

REQUEST WOULD BE IN THE PUBLIC INTEREST: 18

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY: 20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER: 34

CONCLUSION: 36

APPENDICES:

APPEN DIX A

– LISTED UA DESCRITIO NS:

APPENDIX B

- FLIGHT OPERATIONS M ANUAL:

APPENDIX C

– SPECIFIC UAS CHECKL ISTS AND PROCEDURES:

APPENDIX D

– MAINTENANCE LOG:3 

### GLOSSARY OF ABBREVIATIONS

AF: Auto Flight or Automated Mission Conduct

AGL: “Above Ground Level ” measurement of altitude

AOI: Area of Interest

ATC: Air Traffic Control

ATO: Air Traffic Organization

AV: Aerial Vehicle

CFR: Code of Federal Regulations

COA: Certificate of Authorization

DFO: Director of Flight Operations

FAA: Federal Avi ation Administration

FAR: Federal Aviation Regulation

FCC: Federal Communications Commission

FCU: Flight Control Unit (ie, DJI Naza, Pixhawk, etc)

FOM: Flight Operations Manual

FWF: Forward Winged Flight (ie, a traditional airplane mode of flight )

GCS: Ground Control Station

GPS: Global Positioning System

HTOL: Horizontal Takeoff and Land Aircraft (ie, traditional airplane)

LOS: Loss of Signal (GCS communications fail for an unspecified time)

MC: Mission Commander

MINS: Minimum standard s of operation (weather, equipment or personnel)

MSL: Altitude by Reference to Mean Sea Level4 NAS: National Airspace System

NAV: Navigation, in reference to Lateral or Vertical movement

NOTAM: Notice to Airman

NM: Distance, measured in Nautical Mi les

OB: Auxiliary Observer; personnel allowed within 500 feet of operations

OPS: Flight or Ground Technical Operation in support of Commercial UAS Activity

OPS BAN: Halt to all UAS OPS in reaction to Personnel, technical, airspace or

weather restrictio ns or challenges

PIC: Pilot In Command

RTL: Return To Launch (initial launch location) by Auto Command or

Manual Control

SEC333: FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SMS: Safety Management System

SO: Safety Observer; an offic ial operational position required for flight

SOP: Standard Operating Procedures

UA: Unmanned Aircraft

UAS: Unmanned Aircraft System

VFR: Visual Flight Rules

VLOS: Visual Line of Site

VMC: Visual Meteorological Conditions

VTOL: Vertical Takeof f and Landing

VTOL2: VTOL capability with Forward Winged Flight (FWF) operational transition capability and HTOL backup landing capability

WX: Weather, referenced via actual, reported or forecast condition5 

### SUMMARY

Forget Me Knot Ltd. seeks exemption f rom the requirements of : 14C.F.R §§ Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4), and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), in order to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA).

This exemption will permit Forget Me Knot Events, Ltd. to operate an Unman ned Aircraft System (UAS) for the commercial purpose of conducting Aerial Video, Photography, Aerial Mapping, Search and Rescue Relief and Inspection Services

over areas of the United States.



### INTRODUCTION AND INTERESTS OF THE PETITIONER

Forget Me Knot E vents, Ltd. provides clients with Event Planning, Event Management, Marketing, Advertising, Videography and Photography. Forget Me Knot Events plans to offer UAS services under the established high quality business practices of this company and also will offer exceptional aviation and UA services based on the Petitioner’s notable operational experience in aviation. We will offer services under the trade name as (registered in the state of Nevada) “AeroNautic Works”. (Forget Me Knot Events, Ltd. d.b.a. Ae roNautic Works). For the purposes of this document, we will refer to ourselves as “Forget Me Knot Events” for simplicity and the fact that our primary legal corporation documents

and business licenses reflect this name.

One of the managing members of For get Me Knot Events is a current FAA Airline Transport Pilot with over Twenty

- Five years of professional aviation experience both domestically and globally. Areas of experience include nearly 15,000 hours of flight operations, airman and crew training, saf ety program management and operational control experience via positions held in air carrier management (Director of flight Operations, Chief Pilot, Safety Program Specialist and Flight Training Officer).

In addition to this professional aviation experienc e, the managing member has been highly active in the Radio Control model aircraft community for over Thirty

Five years. Areas of long standing expertise include Vertical Takeoff and Landing operation (VTOL), Traditional Forward Winged Flight (FWF), Resear ch & Development, Design and Flight Testing of experimental aircraft types. The petitioner has thousands of hours of unique design, fabrication, testing and documenting this kind of aeronautical activity, especially during the last Twenty

years.6 The obje ctive of Forget Me Knot Events Ltd planned UAS Flight Operations is to take part in this revolutionary merging of Commercial Aviation with modern, micro sized UAS systems. Forget Me Knot Events Ltd. would like to be a part of forming a robust, highly rega rded miniature civilian UAS community while setting industry best practices and a sustainable set of SOP’s with a forming and later established training pipeline for future growth.

In the near term, Forget Me Knot Events Ltd. would like to provide high qu ality imaging and UAS services for a variety of clients including, but not limited to:

● Event Filming and Photography

● Promotions / Marketing / Advertising / Economic Development

● Science / Technology / Engineering Innovation

● Real Estate and Construction Services

● Environmental Mapping / Agriculture / Aerial Surveying

● Insurance Servi ces

● Mining Industry

● Infrastructure Inspections

Forget Me Knot Events Ltd. Managing members have extensive experience in UAS and FAA Aviation industry experience. Utilizing the latest technology available, along with anchoring these opportunities with extensive experience in professional aviation of over Twenty

- Five years and miniature aircraft / drone activity for over Thirty

- Five years, will allow Forget Me Knot Events to offer new services to the public. We intend to become a leader in UAS safety a nd innovation while performing outstanding public & commercial service. We envision using special subject matter experts in areas of industry that have not been of long standing experience to Forget Me Knot Events Ltd in serving a

diverse set of customers . This is to enable the safest UAS services with the highest caliber of product delivery to promote a sustainably established presence in this segment of aviation.



### UNMANNED AIRCRAFT SYSTEMS:

Forget Me Knot Events Ltd. seeks an exemption to operate the f ollowing aircraft for compensation or hire within the NAS:

1) DJI SPREADING WINGS S800 UAS 2) DJI INSPIRE 1 / INPIRE 1PRO UAS 3) DJI PHANTOM 3 UAS 4) 3DR X8 UAS 5) 3DR Solo UAS 6) BIRDSEYEVIEW AEROBOTICS FIREFLY 6 UAS7 7) AERYON SKYRANGER UAS 8) AERONA UTIC WORKS Q2 UAS 9) AERONAUTIC WORKS W 21/W22 UAS 10) AERONAUTIC WORKS POLAR UAS

11 ) AERONAUTIC WORKS BOUYANT22 UAS

Additional descriptions and specifications of these systems will be described in Appendix A. For the purposes of this document, all appro ved UAS systems will be referred to as “listed UA’s” or “Approved UAS” when referring to multiple aircraft types, as applicable.



### BASIS FOR PETITION

Petitioner, Forget Me Knot Events Ltd., pursuant to the provisions of the Federal Aviation Regulations (1 4 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI INSPIRE 1 / INPIRE 1PRO UAS, DJI PHANTOM 3 UAS, 3DR X8 UAS, 3DR

Solo UAS, BIRDSEYEVIEW AEROBOTICS FIREFLY 6 UAS, AERYON SKYRANGER UAS, AVALOFT Q2 UAS, AVALOFT W 21/W22 UAS, AVALOFT

POLAR UAS and AVALOFT BOUYANT22 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 1 4 C.F.R §§ Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)( 2), and 91.417(a) & (b).

The operations outlined herein, and in the Petitioner's manuals, clearly define UAS operations in the NAS that are under appropriately controlled conditions and within secure and sterile zones of operation and pose no significant safety risk to persons or property on the ground, no risk to National Security, and would not constitute as an invasion of any persons reasonable expectation of privacy.



### A. Name And Address Of The Petitioner:

The name and address of the Petitioner and p oint of contact is:

Edward A. Putnam Forget Me Knot Events 15962 Green Springs Drive

Reno, NV 89511

Phone and Email Will be sent separately for privacy8 

### B. Specific Sections Of 14 C.F.R. Forget Me Knot Events, Ltd. Seeks Exemption From:

1. Forget Me Knot Events, Ltd. Seeks Exemption From The Requirements Of 14 C.F.R. Part 21, Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuanc e of airworthiness certificates as required by FAR §91.203 (a) (1). Section 91.203 entitled Civil aircraft: Certifications required, subsections (a) and (b) state the following, in part: (a) Except as provided in section 91.715, no person may operate a ci vil aircraft unless it has within it the following, in part: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable opera tions specifications issued under section 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under section 21.197(c), or an authorization under section 91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after t hat number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district

office. ( 2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in section 47.31(c), or a registration certification

issued under the law s of a foreign country. (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 section 91.715 is displayed at the cabin or cockpit entrance s o that it is legible to passengers or crew. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft.

2. Forget Me Knot Events Ltd. Seeks Exemption From The Requirement Of Sections 91.9(b), 45.23(b) and and 45.27(a). Section 91.9 entitled Civil aircraft flight manual, marking, and placard requirements, subsection (b) states the following, in part: (b) No person may operate a U.S. registered civil aircraft 1) For which an Airplane or Rotorcraft Flight Man ual is required by section 21.5 of this chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in section 121.141(b); and (2) For which an Airplane or Rotorcraft Flight Manual i s not required by9 section 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Section 45.23 entitled Display of marks; general, subsection (b), states the following, in part: (b) When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally cert ificated 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," "lightsport," "experimental," o r "provisional," as applicable. Section 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by section

45.23.

3. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 61.23(a). Section 61.23(a), entitled Operations requiring a medical certificate: Requirements and duration , subsection (a) prescribe the following, in relevant part: (f) Except as provided in pa ragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

4. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 61.101(e)(4) and (5). Section 61.101, entitled Recreational pilot pri vileges and limitations: Pilot in

command , subsection (e)(4) and (5) prescribe the following, in relevant part: (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft for compen sation or hire ; (5) In furtherance of a

business;

5. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 61.113(a) and (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe th e following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passenge rs or property for compensation or

hire.

6. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 61.315(a).10 Section 61.315(a), entitled What are the privileges and limits of my sport pilot certificate, subsection (a) prescribes the following in part: (a) If you hold a sport pilot certificate you may act as pilot in command of a lightsport aircraft, except as specified in paragraph (c) of this section (c) You may not act as pilot in command of a lightsport aircraft: (2) For compensat ion or hire. (3) In furtherance of a business.

7. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

8. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 91.103. Section 91.103, entitled Preflight action , states the following: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC ; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under exp ected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

9. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 91.109(a). Section 91.109(a), entitled Flight instruction prescribes that a ny civil aircraft operated for the purpose of flight instruction must have fully functioning dual controls, states the following, in part: (a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction u nless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls.

10 Forget Me Knot Events Ltd. Seeks Exemption From The11 Requirements Of Section 91.119(c). Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than congested areas, states the following, in part: Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be

opera ted closer than 500 feet to any person, vessel, vehicle, or structure.

11. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating(1) Below 18,000 feet MSL, to(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the

aircraft ; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a

radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

12. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 91.151(b). (a) No person may begin a flight in an airplane under VFR conditions unless (cons idering 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. (b), states the following: (b) No person may begin a flight in a rotorcraft 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, to fly

after that for at least 20 minutes.

13. Forget Me Knot Events Ltd. Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner o r operator of an aircraft

— (a) 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 t his chapter.

14. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a ) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless(1) It has been approved12 for return to service by a person authorized under § 43.7 of this chapter[.]

15. Forget Me Knot Events Lt d. Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unle ss, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by section 43.7 of this chapter; or (2) An inspection for the iss uance of an airworthiness certificate in accordance with part 21 of this chapter.

16. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with sections 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the mainten ance, preventive maintenance, and alteration and records of the 100hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe)and each engine, propeller, rotor, and appliance of an aircr aft. The records must include(i) A description (or reference to data acceptable to the Administrator) of the work performed ; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for

return to service. (2) Records containing the following information: (i) The total time in service of the airf rame, each engine, each propeller, and each rotor. (ii) The current status of lifelimited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be ov erhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of ap plicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring

action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for t he periods13 prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this s ection shall be

retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the

aircraft i s approved for return to service.



### C. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks, and the reason “Forget Me Knot Events, Ltd.” Seeks Relief.

1. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Se eks Relief From 14 C.F.R. Part 21, Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27.

Given the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the req uirements 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

airworthines s certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthin ess certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed sUAS

ope rations.

To the extent the Petitioner's sUAS would otherwise require certification under Part 27, as an airplane or rotorcraft, Petitioner requests an exemption from Part 27's airworthiness standards for the same reasons identified in the exemption

reques t from 14 C.F.R. Part 21, Subpart H.

2. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Seeks Relief From Sections 91.9(b), 45.23(b) and 45.27(a).

Exemption from section 45.23(b) is warranted because the listed UA’s have no entrance to the cabin, cockpit, or pilot station on which the word "Experimental" can be placed. Moreover, given the size of the listed UA’s and UAS, two

- inch lettering would be impossible.14 The word "Experimental" will be placed on th e fuselage in compliance with § 45.29(f). Given the nature of the specific relief sought by this exemption request, Petitioner requires relief from the associated marking and identification requirements of section 45.27(a) and section 91.9(c), which would require compliance with section 45.23(b).

3. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Seeks Relief From Section 61.23(a).

Relief from Section 61.23(a), entitled Operations requiring a medical certi ficate: Requirements and duration, is requested to the extent required to necessary to allow a PIC holding a sport pilot certificate or higher level certificate, as well as a current and valid driver’s license, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.23(a) otherwise require the PIC of any flight for compensation or hire to hold a comprehensive FAA issued medical certificate. In Exemption No. 11213 to Aeryo n Labs, Inc., the FAA “finds that, because of the risk mitigations

established in the conditions and limitations of this exemption, a person that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect safety. The FAA is grant ing relief from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed above to operate a UAS under this exemption with a U.S. issued driver’s license, in lieu of an FAAissued medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver’s license under this exemption.”

4. Extent of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Se eks Relief From Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a).

Relief from sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges

and limitations ; section 61.113(a), entitled Private pilot privileges and limitations: Pilot in command; and section 61.315(a), entitled What are the privileges and limits of my sport pilot certificate, is requested to the extent necessary to allow a PIC holding a sport pilot, recreational pilot, or private pilot certificate, as well as an airman medical certificate or U.S. issued driver’s license, and who has met certain flight hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire, subject to the conditions and limitations below. This relief is requested since the limitations set forth in sections 61.101(e)(4) & (e)(5) state that no person who holds a recreational pilot certificate may act as pilot in command of an aircraft for compensation or hire or in furtherance of a business. Relief is requested from 61.113(a) since the

limitations set forth in that section state that no person who holds a private pilot certificate may act as pilot in command of an

aircraft that is carr ying passengers or property for compensation or hire ; nor may that person, for compensation or hire, act as pilot in command of an aircraft.15 Relief is requested from 61.315(a) since the limitations set forth in that section only allow a person who holds a sport pilot certificate to act as pilot in command of a lightsport aircraft. As set forth more fully below, Forget Me Knot Events Ltd. submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the listed UA’s unless that PIC has met certain flight hour

and curr ency requirements, demonstrating that the PIC is able to safely operate the listed UA’s in a manner consistent with the operations specifications as set forth herein, including: Evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles, and structures. Further, Forget Me Knot Events Ltd. submits that the additional airmanship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for Forget Me Knot Events

Ltd. specific proposed operations.

5. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to

the extent required to allow Forget Me Knot Events Ltd. to determine that the listed UA’s are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Forget Me Knot Events Ltd. Flight Oper ations Manual, Maintenance Log, and Specific UA Operations Manual).

Forget Me Knot Events Ltd. seeks the requested relief because the listed UA’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Forge t Me Knot Events Ltd. will ensure that the listed UA is in an airworthy condition based upon its compliance with the operating documents (i.e., the Forget Me Knot Events Ltd. Flight Operations Manual, Maintenance Log, and Specific UA Operations Manual) pri or to every flight. Additionally, Forget Me Knot Events Ltd. will determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

6. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Fo rget Me Knot Events, Ltd.” Seeks Relief From Section 91.103.

Relief from FAR 91.103 is requested, as FAA approved aircraft flight manuals will not be used. In the absence of the flight manuals the PIC will take all preflight action, including reviewing We ather, Mission Constraints, Safety Concerns, Flight battery requirements, Takeoff and Landing performance, environmental conditions as they relate to aircraft limitations and aircraft performance data before starting a flight.

7. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.109(a).16 Relief from Section 91.109a is requested, as UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Inste ad, flight control is accomplished through the use of a control box that communicates with the UA

via radio communications.

Forget Me Knot Events Ltd. managing members have trained many first time RC pilots using well

- established protocols using single an d multiple radio transmitter control systems. This arrangement has proven safe and effective over the past 50 years and using modern equipment, the system is still effective and valid.

8. Extent of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reaso n “Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.119(c).

Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than congested areas, is required because all proposed operations of the listed UA’s will take place at an altitude at or below 400 feet AGL. This relief is requested since the limitations set forth in Section 91.119(c) state that no person may operate an aircraft below 500 feet above the surface. As set forth more fully below, Forget Me Knot Events Ltd. submit s that a level of safety equivalent to Section 91.119(c) will be maintained because operations will be conducted in areas with controlled access and under the safety provisions contained within this petition. The listed UA SOP’s and protocols are proven s afe and effective in maintaining an exceptional level of safety and the Forget Me Knot Events Ltd. Flight Operations Manual, specific US Operations Manual and effective aeronautical decision making create a robust level of safety management.

Additionally, relief from Section 91.119(c) is requested to the extent necessary to allow operations to be conducted closer than 500 feet to persons, vessels, vehicles, or structures, under certain conditions. This relief is requested since the

limitations set forth in Section 91.119(c) prohibit operating an aircraft closer than 500 feet to a person, vessel, vehicle, or structure.

Forget Me Knot Events Ltd. submits an equivalent level of safety will be maintained because operations closer than 500 feet to a person, ves sel, vehicle, or structure will first require that the operator receive permission from any nonparticipating persons or the person who owns/controls the property. In addition, barriers or structures will be in place to sufficiently protect nonparticipating persons from debris in the event of an accident and all nonparticipating persons will be required to remain under such protections for the duration of the operation.17 9. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me K not Events, Ltd.” Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the listed UA’s, which utilize a barometric pressure sensor, GPS equipment, and a radio communicatio ns telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations Forget Me Knot Events Ltd. seeks the requested relief because the listed UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the listed UA’s are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the via telemetry data transmitted to the GCS.

10. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered, l isted UA’s during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR).

Forget Me Knot Events Ltd. seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of battery pow ered listed UA’s will prohibit the practicality of any aerial video or still photo flight operations Forget Me Knot Events Ltd. proposes to conduct pursuant to this

Petition.

Significantly the technical specifications of listed UA’s operating documents an d

the Forget Me Knot Events Ltd. proposed operating limitations ensure that Forget

Me Knot Events Ltd. will safely operate the battery powered listed UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for the entire planned mission and there after for an additional 4 Minutes, 30 Seconds.

11. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason “Forget Me Knot Events, Ltd.” Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &18 (b) only apply to aircraft with an airworthiness certificate, Forget Me Knot Events

Ltd. requests relief from these S ections because listed UA does not require airworthiness certificates. As set forth more fully below, the listed UA meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Forget Me Knot Events Ltd. will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Forget Me Knot Events Ltd. Flight Operations Manual,

Mainten ance Log, and Specific UA Instruction Manual). Forget Me Knot Events

Ltd. will document and retain all maintenance records for all listed UA’s.



### D. The Reasons Why Granting the request to “Forget Me Knot

Events, Ltd.” Would Be In The Public Interest and how It Would

Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Forget Me

Knot Events Ltd. to safely, efficiently, and economically perform aerial videography and photography for its clients over area s of the United States.

Many of the proposed operations Forget Me Knot Events Ltd. plans to conduct cannot be economically or safely conducted with traditional, manned aircraft. Examples include smaller

- scale aerial mapping, smaller budget special event coverage and certain promotional videography and photography. These services are a boon to choices available to the average person or small business owner that were not previously available. Additionally, use of listed UA’s will decrease congestion of th e NAS, reduce pollution, and provide significant benefits to the

economy.

Notably, the benefits of Forget Me Knot Events Ltd’s. proposed operation of the listed UA’s will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The listed UA’s are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to p erform aerial acquisitions, an exemption allowing the use of listed UA’s would reduce the volume of unscheduled, manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

By reducing the number of unscheduled manned aircraft operating in the NAS unpredictable congestion around airports caused by arriving and departing aircraft will be reduced. The listed UA’s do not require an airport to takeoff or

land. Likewise, a reduct ion of manned aircraft conducting aerial video and19 photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Listed UAS equipment “Forget Me Knot Events, Ltd.” will employ in serving the public.

Conducting aerial acquisitions with the listed UA’s, instead of manned aircraft, will greatly benefit the public by reducin g the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the listed UA’s produce no air pollution, and are a viable and environmentally conscious alternative to the internal combustion engine aircraft that are typically utilized for aerial video and photography. The listed UA’s will reduce the carbon footprint of aerial acquisitions and eliminate the need for leaded aviation gasoline in this type of an operation.

Utilizing the listed UA’s to perform aerial acquisitions will substantially reduce the risk to life and property in the air and on the ground compared to gasoline reciprocated engine light aircraft conducting on

- demand aircraft operations

.

Aside from the lack of flight crew members located onboard the aircraft, the listed UA’s clearly have significantly less physical potential for collateral damage to life and property on the ground in the event of a mishap compared to the manned

aircraft that typically conduct similar operations. This is due to the small size, battery operation and advanced technology available to the listed UA’s. The result is the listed UA’s can more accurately conduct missions with many more options to abort safely a nd easily in the event of an unforeseen circumstance.

3. Performing Aerial Video and Photography Operations with the listed UAS Will Benefit The Economy.

In addition to being safe and efficient, listed UA’s and UAS are also an

economical alternative to u sing manned aircraft to conduct similar aerial operations. As such, operation of acceptable UAS will allow United States based companies, like Forget Me Knot Events Ltd., to remain competitive and contribute to innovation and to the growth of the U.S. econ omy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain

co mpetitive. Operating the battery UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.20 By op erating the contemporary UAS, companies such as Forget Me Knot Events Ltd. can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Im proved financial performance of U.S. companies, through innovation and commercial use of UAS, provides a stable workforce that results in the following the following: Increases the creativity of society, spurs new ideas, increases consumer spending, impro ves local, state, and federal tax revenues and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight ope rations that have been conducted for decades, Forget Me Knot Events Ltd’s. proposed operation of the listed UA’s will not implicate any privacy issues. Specifically, the listed UA’s will be operated only in compliance with operating documents (i.e., the Fo rget Me Knot Events Ltd. Flight Operations Manual, Maintenance Log, and listed UA Ops Manuals). Flights are planned well ahead of time, require property owner

involvement and will be conducted in accordance with the Federal Aviation Regulations, includin g the minimum distance requirements of 14 C.F.R. §

91.119.



### E. Reasons Why Granting The Exemption Would Not Adversely Affect Safety; How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which “Forget Me Knot E vents, Ltd.” Seeks Exemption.

1. Reasons Why The listed UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated

with the unmanned aircr aft and its operation, Forget Me Knot Events Ltd. operation of the listed UA’s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 states t he following, in part: (a) In General.Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may oper ate safely in the national airspace system21 before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems. In making the determination under subsection (a), the Secretary shall determine, at a minimum(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line o f sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security ; and (2) whether a certificate of waiver,

certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Req uirements for Safe Operation. If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft syste ms in the national airspace system. In seeking this exemption, Forget Me Knot Events Ltd. submits that the listed UA’s can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the listed UA’s (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The listed UA’s Demonstrate Their

Characteristics.

The listed UA’s do not create a hazard to users of the NAS or the public, or otherwise pose a threat to nat ional security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The listed UAS. The technical specifications of the listed UA’s Specifications and Data Sheet

can be found in APPENDIX A.

ii. The listed UAS Au tonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The listed UA’s may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the

listed UA ’s are provided via web links in Appendix A and examples can be seen

in certain vendor websites as attached for each listed UA.

iii. The listed UA’s Are Designed For Automatic Return To Home

Point Or Hover In The Event Of Loss Of The Control Link Or Navig ation. When the Control Link is lost, the listed UA’s with VTOL capability will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the listed VTOL UA’s do not reacquire control link data from the GCS, the UA will operate on the

basis that the Control Link is lost and the UA will return to the initial launch position (RTL) (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.22 When the control link is lost, the listed UA’s with HTOL capability will hold in a racetrack position. If GCS signal is not regained, the applicable UA will operate

on the basis that the Control Link is lost and the UA will return to the initial launch position (RTL) (i.e., failsafe mode) via GPS. The HTOL UA will descend to the

t akeoff position with motors shutdown and perform an auto glide to landing.

iv. The listed UA’s and their Operation. A description of the operation and specifications of the listed UA’s are found on links provided. In the case of self made UA’s and UAS, t hese systems are using state of the art flight controllers and navigations systems that are “off the shelf” technology available to experienced UAV designers like the Petitioner in this case. The associated links provided show the auto flight, navigation, GPS, loss of Signal reversion capabilities of the Pixhawk controller. The Pixhawk controller is a gold standard of late 2015 technology and these protocols are leading the way for industry best practices as of today.

The level of safety and functionalit y of the AVALOFT self made UA’s and UAS are as good or better than the off the shelf, consumer UAS that have gained exemption thus far.

b. Flight Operations of the listed UA’s are Limited To The Line Of Sight, and

a certificated Pilot in Command With A Sa fety Observer is required to operate. Forget Me Knot Events Ltd. will only utilize certificated and current pilots to act as a PIC’s of listed UA’s under commercial flights, while under operational control of Forget Me Knot Events Ltd. Additionally, a saf ety observer (SO) will assist all PIC’s during Commercial Missions and Official Training Events.

c. Flights of all listed UA’s Will Be Conducted Pursuant To Specific Operating Limitations.

1. Operations authorized by this grant of exemption are limited to the Approved listed UA’s, weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and tel evision filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 40023 feet above ground level (AGL). Altitude must be reported in f eet AGL.

5. Each flight will have a Pilot in Command (PIC) designated before flight commences. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision, unaided by any devic e other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. The PIC, as designated before the flight, cannot transfer his or her designation for the duration of the flight.

6. All operations m ust utilize a Safety Observer (SO). The UA must be operated within the visual line of sight (VLOS) of the PIC and SO at all times. The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO will not be t asked with any other duties, outside of the safety and observation duties of the flight environment and UA that are immediately required of a SO. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not per mitted during flight operations. The PIC must ensure that the SO is capable and able to perform the duties required of the SO.

7. This exemption and all documents needed to operate the UAS and conduct its operation in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the “Operating Documents”. The Operating Documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists betwe en the conditions and limitations in this exemption and the procedures outlined in the Operating Documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its Op erating Documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The opera tor must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the ope rator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterat ions that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights will only be conducte d by a PIC with a SO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.24 9. The operator is responsible for maintaining and inspecti ng the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential di screpancies, e.g.,inoperative components, systems, or equipment. If the inspection reveals a condition that affects, or will effect 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also

hold a current FAA airman medical certificate or a valid U.S. driver’s license, issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14CFR §61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under th is exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR §61.51(b). Flights f or the purposes of training the operator’s PICs and SOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered non

- pa rticipants. The PIC must operate the UA with appropriate distance from non

- participants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not

authorized.25 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) o r for airports not denoted with an ARP, the center of the airport symbol as denoted on

the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemp tion holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3statute miles from

the PIC.

18. For tethered UAS operations, the tether line must have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet

above the surface of the earth and visible from at least one mile. This requirement for pennants or streamers is not applicable when operating exclusively below the top of and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications with the GCS or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

access property.

20. The PIC must abort the flight if obstacles or events posing a safety hazard t o continued mission operations occur, or in all cases, in the event of any other UAS system emergency.

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 4 minutes and 30 seconds, or with the reserve power recommended by the manufacturer if greater.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA.

23. All aircraft operated in a ccordance with this exemption must be identified by

serial number, registered in accordance with 14CFR part 47, and have identification (N

− Number) markings in accordance with 14CFR part 45, Subpart C. Markings must be as large as practicable.26 24. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

25. The UA must remain clear and give way to all manned aviation operations

and activities at all times.

26. The UAS may not be operated by the PIC from any moving device or

vehicle.

27. All Flight operations must be conducte d at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator m ust 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 UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determ ined that it does not present an undue hazard. The PIC, SO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

28. All operations shall be conducted over private or controlled

- access property with pe rmission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that trans gresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AF S

− 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. If this exemption permits operations for the purpose of closed

- set motion picture

and telev ision filming and production, the following additional conditions and limitations apply.

30. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

31. At least 3 days before aerial fil ming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-27 day notification may be waived with the con currence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

32. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as

sp ecified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61,

and 91. http://www.ntsb.gov/

2. Reasons Why An Exemption From The Requirements Of 14 C.F.R. Part 21, Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27 Would Not Adversely Affect Safety.

The listed UA’s are less th an 55 lbs. fully loaded. They carry neither a pilot nor passenger, and carry no explosive materials or flammable liquid fuels. Unlike other civil aircraft, the proposed operations in this petition for exemption will be controlled and monitored by the oper ator in accordance with Forget Me Knot Events Ltd. Flight Operations Manual, Maintenance Log and specific US operations manual. These safety practices, which already apply to civil aircraft operated in connection with existing inspection operations, prov ide an equivalent of 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.

Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the listed UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. To the extent of Part 27's airworthiness standards, safety will not be adversely be affected for the same reasons identified in the response from 14 C.F.R. Part 21, Subpart H.28 3. Reasons Why An Exemption From The Requirements Of Sections 91.9(c), 45.23(b) and 45.27(a) Would Not Adversely Affect Safety.

An equivalent level of safety for exemptions to the aircraft marking and identification requirements of sections 91.9(c), 45.23(b) and 45.27(a), will be provided by having the listed UAS marked on its fuselage as require d by §45.29(f) where the pilot, observer, and others working with the listed UAS will see the identification of the UAS as "Experimental." Additionally, Petitioner will ensure compliance with any requests of UAS rulemaking by the FAA.

4. Reasons Why An E xemption From The Requirements Of Sections Section 61.23(a) Would Not Adversely Affect Safety.

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, because of the risk mitigations established in the conditions and limitations of this exemptio n, a person that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed above to operate a UAS

under t his exemption with a U.S. issued driver’s license, in lieu of an FAA issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to operate aircraft other than LSA with a U.S. issued

driver’s license under this exemption.”

5. Reasons Why An Exemption From The Requirements Of Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) Would Not Adversely Affect Safety.

Forget Me Knot Events Ltd. submits that an equivalent level of safety established by Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) will be maintained because no PIC will be allowed to operate a listed UA unless that PIC has demonstrated, by meeting minimum demonstrated training currency requirements, that the PIC is able to safe ly operate the listed UA in a manner consistent with the exemption. This includes evasive / emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures. Considering the Forget Me Knot Event Ltd. proposed area of operations, and the operating limitations set forth above, the shared nature of sport pilot through ATP certificate holder ensures appropriate aeronautical knowledge requirements. This will allow safe and effective flight operations with

the listed UA’ s (See Exemption Nos.11062 and 11213); and the airmanship skills necessary to safely operate the listed UAS. Forget Me Knot Events Ltd. submits that the additional manned aircraft experience of a commercially certificated pilot would not correlate to th e airmanship, knowledge, skills and decision

- making skills necessary for Forget Me Knot Event Ltd’s specific proposed flight operations. The FAA has previously granted relief from Sections 61.101(e)(4) & (e)(5) and 61.315(a) specific to UAS, in circumstan ces similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11213, 11221, 11222, 11223,29 11224, 11225,11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241). Additionally, the FAA has previously granted relief from Section 61.113(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11110,11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 1116 1, 11170, 11171,11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11189, 11191, 11192,11193, 11194, 11195, 11204, 11206, 11208, 11209, 11213, 11215, 11216, 11217,11218, 11220,

11221, 11222, 11223, 11224, 11225, 11226, 11227, 11228, 11229, 11230, 1123 7, 11238, 11239, 11240, 11241).

Forget Me Knot Events Ltd. will not allow any PIC to operate a listed UA unless that PIC has demonstrated, by meeting minimum training and currency requirements that the PIC is able to safely operate the listed UA in a

mann er consistent with this exemption. This includes evasive and emergency maneuvers; maintaining appropriate distances from people, vessels, vehicles and structures; SOP’s for Preflight Planning, Mission Execution and Post Flight

duties.

Specifically, the P IC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under t he exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days for flight currency purposes.

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Forget Me Knot Events Ltd’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a ma nner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a m inimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive ; i.e. 5 hours make and model time may be included in the 10 hours of multirotor time and the 10 hours may be

included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in th e preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight hour30 requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct Forget Me Knot Event Ltd’s,

propos ed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience building flights can also be conducted under the gra nt of exemption to accomplish the required flight time. During training, proficiency, and experience building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119,(Exemption No. 11138 at page 15). For get Me Knot Events will ensure safe operations by not allowing any PIC to operate a listed UA unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the listed UA in a manner

consi stent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

6. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety

.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Forget Me Knot Events, Ltd. will ensure that the listed UA is in an airworthy condition based upon best practices and operating

documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080,

11109,11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,11161).

7. Reasons Why An Exemption From The Requirements Of Section 91.103 Would Not Adversely Affect Safety.

An equivalent level of sa fety will be ensured while following Forget Me Knot Events Ltd. Flight Operations Manual, Maintenance Log Procedures and Specific UA operations manuals . The PIC will take all actions, including reviewing weather reports and forecasts, NOTAMS, Mission Requi rements including flight battery requirements, landing and takeoff Requirements and aircraft performance calculations. This preflight planning will occur before initiation of flight. During the flight, a continual assessment of aeronautical decision maki ng and mission status will validate progress or initiate a need to re

- evaluate the mission status.

8. Reasons Why An Exemption From The Requirements Of Section 91.109(a).Would Not Adversely Affect Safety.

Given the size and speed of the listed UAS, an eq uivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS. All persons will be a safe distance away should the UAS experience any difficulties during flight instruction. Based on over 8 0 years of31 documented model aviation experience via AMA records: Safe and effective miniature, automated and remotely controlled aircraft training operations are easily and safely achieved via preflight briefings, pre planned training objectives

and commun ication during training via careful instruction and supervision.

9. Reasons Why An Exemption From The Requirements Of Section 91.119(c) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.119(c) will be maintained because in any operation to be conducted closer than 500 feet from any nonparticipating persons, barriers or structures will be present to sufficiently protect any nonparticipating persons from debris in the event of an accident during operation of a liste d UA which weighs less than 55 pounds and will be operated below an altitude of 400 feet AGL. The nonparticipating persons will be required to remain in the area of protection, and if any nonparticipating person leaves the area of protection and is within 500 feet of the listed UA, flight operations will divert and / or cease immediately.

Additionally, any operation to be conducted closer than 500 feet from persons, vessels, vehicles, and structures would first require the permission of the land

owner/cont roller and a safety assessment of the risk of operating closer to those objects will be carried out by the PIC. See (Exemption Nos. 11204 and 11224). Additionally, the FAA has previously granted relief from Section 91.119(c) specific to UAS, in circumsta nces similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112, 11114,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166,11167, 1117 0,

11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188,11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209,

11213,11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226,11227, 11228, 11229, 11230, 11237, 1123 8, 11239, 11240, 11241).

10. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of listed U A will be provided to the PIC via GPS equipment and a telemetry data link. This data communication downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with operating the listed UA wit hin visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section

91.121.

The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation p oint is automatically32 established by the UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064

, 11065, 11066, 11067, 11080, 11109, 11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

11. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would e nsure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications the listed UA’s (2) the limitations on the proposed flight operations ; and (3) the location of the proposed flight operations.

Accordingly, Forget Me Knot Events Ltd. will ensure that it will safely operate the listed UA during daylight hours in VFR conditions, with enough battery power to fly for a total planned mission d uration to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. This will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the listed UA’s provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage. The first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power.

S ignificantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircra ft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, t o those presented herein (e.g. Exemption Nos. 8811, 10808, 10673,

11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

12. Reasons Why An Exemption From The Requirement s Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Forget Me Knot Events Ltd. submits that the equivalent level of safety with regard to the regulatory maintenan ce and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b) will be met because Forget Me Knot Events Ltd. will use trained technicians to perform maintenance, alterations, or preventive maint enance on the UAS systems using the methods, techniques, and practices prescribed in the operating documents (Forget Me Knot Events33 Ltd. Flight Operations Manual, Maintenance Log, and listed UA Operations Manual).

Furthermore, Forget Me Knot Events Ltd. will document and maintain all maintenance records for the approved UAS. Since the approved UAS will be inspected as prescribed by the operating documents, Forget Me Knot Events Ltd. will maintain the equivalent level of safety established by Sections 91 .405(a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversely affect safety because Forget Me Knot Events Ltd. will use trained technicians to perform repairs, alterations or preventive maintenance on the UAS using the method s, techniques, and practices prescribed by the operating documents. The exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the approved UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the Forget Me Knot

Events Ltd. M aintenance Log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the approved UAS are considered.

In consideration of Forget Me Knot Events Ltd’s proposed operating limitations, the operating d ocuments, and the technical aspects of the approved

UAS, Forget Me Knot Events Ltd. submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). Th e FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 13. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Forget Me Knot

Events Ltd. requests that the FAA prescribe special conditions for the intended operation of listed UA’s, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Such special conditions will permit safe operation of the listed UA’s for the limited purpose of conduct ing aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the34 NAS or the public, or otherwise pose a threat to national security ; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special c onditions pursuant to 14 C.F.R. § 21.16, for operation of the listed UA’s, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of

the aircraft. Secti on 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel o r unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the

FA A may prescribe special conditions for Forget Me Knot Events Ltd’s intended operation of the approved UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).



### F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Forget Me Knot Events Ltd. Seeks Exemption:

Forget Me Knot Events Ltd. seeks exemption from the requirements of 14 C.F.R Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a ), 91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Forget Me Knot Events

Ltd. Seeks:

This exemption will permit Forget Me Kn ot Events Ltd. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States

.35 G. Any Additional Information, Views, Or Arguments Available To Support Applied Art & Technology, LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Forget M e Knot Events

Ltd’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS

will create a hazard to users of th e NAS or the public, or otherwise pose a threat to national security ; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Forget Me Knot

Events Ltd. will operate the listed UA’s safely in the NAS, without creating a hazard to users of the NAS, or t he public, or otherwise pose a threat to national security.36 

### CONCLUSION

As set forth herein, Forget Me Knot Events Ltd. d.b.a. AeroNautic Works, seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA

Moderniz ation and Reform Act of 2012 (FMRA), which will permit safe operation of the approved UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of

the United States.

By gr anting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Forget Me Knot Events Ltd. to safely, efficiently, and e conomically operate the approved UAS commercially,

within the NAS.

Therefore, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Forget Me Knot Events Ltd. respectfully requests that the Admi nistrator grant this Petition for an exemption from the requirements of 14 C.F.R Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 91.1 51(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Forget Me Knot Events Ltd. to operate the approved UAS commercially for the purpose of conducting aerial video and photography over certain areas of t he

United States.

Dated: 15 December, 2015 Respectfully submitted,

Edward A. Putnam

Forget Me Knot Events Ltd.

d.b.a AeroNautic Works 15962 Green Springs Drive Reno, NV 89511 USA Phone and Email will be sent separately for privacy

Appendices:

A. Liste d UA’s

B. Flight Operations Manual C. Specific UAS checklists and procedures D. Maintenance Log37 

### APPENDIX

- A

LISTED UNMANNED AIRCRAFT (LISTED UA’s):

Appendix A is listed and sent in a separate document to protect proprietary information and processes.



### APPENDIX

– B

FLIGHT OPERATIONS MANUAL

Appendix B is listed and sent in a separate document to protect proprietary information and processes.



### APPENDIX

– C

SPECIFIC UAS CHECKLISTS AND PROCEDURES

Appendix C is listed and sent in a separate docume nt to protect proprietary information and processes.



### APPENDIX

– D

MAINTENCE LOG

Appendix D is listed and sent in a separate document to protect proprietary information and processes.