Mark	McBride,	President

Aerial	Media	One Inc.

8115	Grenada	Drive  Brighton,	MI	48116  Phone:	517.404.1 930

E

- Mail:	aerialmediainc@gmail.com  Web: www.aerialmediaone.com

May	25 ,	2015

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

- 140 1200	New	Jersey	Avenue,	SE.

, Washington,	DC	20590

RE :	Exemption	Request Section	333	of	the	FAA	Reform	Act

Dear	Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA	Moderni zation	and	Reform	Act	of	2012	(the	Reform Act),	and	14	C.F.R.	Part	11,	Aerial	Media	One Inc. (AM1),	a	complete	Unmanned	Aircraft Systems	(UAS)	service	provider

, hereby	applies	for	an	exemption	from	the	Federal	Aviation Regulations	(FARs)	listed	below	to	al low	operation	of	our	Small	Unmanned	Aircraft Systems	(sUAS)	commercially in airspace	regulated	by	the	Feder al	Aviation	Administration (FAA)	so	long	as	such	operations	are	conducted	with	and	under	the	conditions	outlined herein	or	as	may	be	established	by	t he	FAA	as	required	by	Section	333.

The	requested	ex emptions would	permit	Aerial	Media	One Inc. to provide services	to clients	using sUAS	devices in	the	following	commercial	markets:

• Real	Estate

• Agriculture

• Utility	Grid	Management

• Utility	Customer	Servi ce

• Mapping

• Cinematography

• Videography / Photography

• Advertising

As	described	more	fully	below,	the	requested	exemptions	would	permit	the	operation	of small,	unman ned	and	relatively	inexpensive UAS	under	controlled	conditions	in	airspace that	is	limited,	pre determined,	controlled	as	to	access,	and	would	provide	safety enhancements	to	the	already	safe	operations	using	conventional	aircraft.

The	petitioner	requests	relief	from	the	following:

• 14	C.F.R	Part	21• 14	C.F.R.		45.23	(b)

• 14	C.F.R.		61.113	(a)	&	(b)

• 14	C.F.R.		91.7	(a)

• 14	C.F.R.		91.9	(b)	(2)

• 14	C.F.R.		91.103

• 14	C.F.R.		91.109

• 14	C.F.R.		91.119

• 14	C.F.R.		91.121

• 14	C.F.R.		91.151	(a)

• 14	C.F.R.		91.203	(a)	&	(b)

• 14	C.F.R.		91.401

– 91.417

Extent	of	Relief	Sought

Aerial	Media	One Inc.	is	petitioning for	an	exemption	to	operate	sUAS	weighing	less	than	55 lbs	at	altitudes	at	or	below	400	ft	above	ground	level	(AGL),	not	within	3	nautical	miles	of an	airport.

Aerial	Media	One Inc.	will	only	operate	its	sUAS	in	visual	line	of	sight	of	a	pilot	and	visu al observer,	and	will	operate	at	sites	that	are	sufficient	distance	from	populated	areas,	clouds

and	full

- scale	aircraft.

Such	operations	will	ensure	that	the	sUAS	will	not	create	a	hazard	to	users	of	the	national airspace	system	or	the	public.

Exempti on	Requests by	14	C

. F

. R

. Section ,	Including	Relief Sought,	Purpose	for	Relief, and	Safety	Implications

14	C.F.R	Part	21 ,	Airworthiness	Certificates

14	C.F.R.	21,	Subpart	H,	enti tled	Airworthiness	Certificates.

This	regulation sets	forth	requirements	fo r	procurement	of	necessary	airworthiness certificates	in	relation	to	FAR	§	91.203(a)(1).	The	size,	weight	and	enclosed	operationa l

area	of	Aerial	Media	One	Inc. UAS	permits	e xemption	from	Part	21	because	AM1	UAS	meet (and	exceed )	an	equivalent	level	of	saf ety	pursuant	to	Section	333	of	the	Reform	Act.	The FAA	is	authorized	to	exempt	aircraft	from	the	airworthiness	certificate	requirement	under both	the	Act	(49	U.S.C.	§	44701	(f))	and	Section	333	of	the	Reform	Act.	Both	pieces	of legislation	permit	the	FAA	t o	exempt	UAS's	from	the	airworthiness	certificate	requirement in	consideration	of	the	weight,	size,	speed,	maneuverability	and	proximity	to	areas	such	as airports	and	dense	populations.	Aerial	Media	One	Inc.’s	current	and	projected	UAS's	meet

or	exceed	eac h	of	the	elements.

14	C.F.R.		45.23	(b)14	C.F.R.	45.23	(b) require s when	aircraft	marks	only	include	the	capital	letter	“N”	and	the registration	number	displayed	on	limited,	restricted	or	light	sport	category	aircraft	or experimental	or	provisionally certificated	aircraft,	the	operator	must	also	display	on	that aircraft	near	each	entrance	to	the	cabin,	cockpit, or	pilot	station,	in	letters	not	less	that	2

inches	nor	more	than	6 inches	high,	the	words	“limited,”	“restricted,”	“light	sport” “experimental ,”	or	“provisional,”	as	applicable.

Our	UAS	are,	by	definition,	unmanned.	They	therefore	do	not	have	a	cabin,	cockpit	or	pilot station	on	which	to	mark	certain	words	or	phrases.	Further,	two

- inch	lettering	is	difficult	to place	on	such	small	aircraft	with dimensions	small er	than minimal	lettering	requirement.

Aerial	Media	One	Inc. will	mark	its	UASs	in	the	largest	possible	lettering	by	placing	th e word	“EXPERIMENTAL” on all fuselage s as	required	by	14	C.F.R.	§45.29	(f)	so	that Aerial Media	One	Inc., the	as sisting spotter ,	o r	others working with	the	UAV	will	see	the	markings. The	FAA	has	previously	issued	exemptions	to	this	regulatio n	through	Exemptions	Nos.
8738, 10167,	10167A	and	10700.

14	C.F.R.		61.113	(a)	&	(b)

14	CFR	61.113 (a) Private	Pilot	privileges	an d	limitations:	Pilot	in	Command	and	61.133 Commercial	privileges	and	limitations.

The	regulation	provides	that	no	person	who	hold s a	Private	Pilot	certificate	may	act	as	pilot in	command	of	an	aircraft	in	connection	with	any	business of	employment	if:	(1) The	flight is	only	incidental	to	that	business	or	employment;	and	(2)	The	aircraft	does	not	carry passengers	or	property	for	compensation	or	hire.		Our	proposed	operations	require	that the	PIC	hold	at	least	a	Private	Pilot	Certificate	issued	by	the	FAA	an d	since	the	aircraft cannot	carry	passengers	or	property,	we	feel	we	meet	the	intent	of	61.113	Subparagraph (b)	even	though	the	intent	of	this	application	is	to	conduct	a	business.

14	C.F.R.		91.7	(a)

14	CFR	91.7 (a) prohibits	the	o peration	of	an	aircraft	wi thout	an	airworthiness	certificate. As	no	such	certificate	will	be	applicable	in	the	form	completed	by	the	FARs,	this	regulation is	inapplicable.

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

14	CFR	91.9 (b)	(2) Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

This	r egulation	provides	that	no	person	may	operate	an	aircraft	unless	a	current,	approved flight	manual	is	in	the	aircraft.	We	assume	that	the	intent	of	this	requirement	is	to	ensure that	flight	manual	information	is	available	to	the	aircrew	while	operating	the aircraft.	We request	an	exemption	to	this	requirement	since	the	aircraft	is	not	only	too	small	to	carry documentation, but the	documentation	would	not	be	available	to	the	crew	during	flight operations.	To	obtain	an	equivalent	level	of	safety	and	meet	the intent	of	91.9,	we	proposethat	a	current,	approved	sUAS	Flight	Manual	must	be	available	to	the	crew	at	the	ground

sta tion	anytime	the	aircraft	is	in or	preparing	for flight.

14	C.F.R.		91.103

14	C.F.R.	§	91.103:	Preflight	action

This	regulation	requir es	each	pilot	in	command	to	take	certain	actions	before	flight	to insure	the	safety	of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be	provided

for	the	aircraft

, an	exemption	will	be	needed.	The	PIC	will	take	all	actions	including reviewing	w eather,	flight	battery	requirements,	landing	and	takeoff	distances	and	aircraft performance	data	before	initiation	of	flight.

14	C.F.R.		91.109

14	CFR	91.109	Flight	Instruction;	Simulated	instrument	flight	and	certain	flight	tests.

The	regulation	sta tes

, "No	person	may	operate	a	civil	aircraft	that	is	being	used	for	flight instruction	unless	that	aircraft	has	fully	functi oning	dual	controls."	The	sUAS	s ystem ground	based	control	station	consists	of	a	handheld	radio	transmitter	and	while	it	does	not

o f

fer	a	second	set	of	"controls,” both	the	student	and	instructor	can,	and	will,	operate	the single	set	of	controls	simultaneously.	With	both	student	and	instructor	having	"hands

- on" the	controls	during	flight,	this	technique	meets	the	inten t	91.109	and	prov ides	an equivalent	level	of	safety

14	C.F.R.		91.119

91.119	Minimum	safe	altitudes:	General.

The	regulation	states	that	over	sparsely	populated	areas	the	aircraft	cannot	be	operated closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.	Sinc e	the	typical	mission	of the	sUAS	would	be	photography	or	survey	of	persons,	vessels,	vehicles	or	structures

, it would	be	necessary	to	operate	closer	than	500	feet	to	the	items	listed.	Operations	will	only be	flown	over	property	or	p eople where	permission has	been obtained	and	careful	pre

planning has	been	performed.	The aircraft	will	be	operated at	a	low	altitude	allowing,	if	a power	unit	fails,	an	emergency	landing	without	undue	hazard	to	persons	or	property	on

the	surface.	Therefore	we	maintain	that	due	t o	the	small	size	of	the	UAS,	the	hazard	to persons,	vehicles	and	structures	is	minimal	compared	to	manned	aircraft,	which	should	be considered	in	granting	the	exemption.

14	C.F.R.		91.121

CFR	91.121	Altimeter	settings

.The	regulation	requires	that	aircr aft	shall	maintain	cruising	altitudes	by	reference	to	an altimeter	setting	available	within	100	NM	of	the	aircraft.	The	sUAS	will	always	fly	below 400	feet	AGL	and	will	not	need	to	maintain	cruising	altitudes	in	order	to	prevent	conflict

with	other	aircraf t.	An	Above	Ground	Level	altimeter	measurement	above	the	takeoff	point

is	transmitted	via	radio	from	the	sUAS	on

- board	computer	to	the	display	screen	held	by	the PIC,	providing	a	constantly	updated	AGL	readout

.

14	C.F.R.		91.151	(a)

14	CFR	91.151 (a) Fuel	re quiremen ts	for	flight	in	VFR	conditions

.

The	regulation	provides	that	no	person	may	begin	a	flight	in	an	airplane	under	day V FR conditions	unless	there	is	enough	fuel	to	fly	to	the	first	point	of	intended	landing	and	to	fly

after	that	for	at	least	30	minu tes.	We	feel	the	intention	of	this	paragraph	is	to	provide	an energy	reserve	as	a	safety	buffer	for	delays	to	landing.	The	sUAV	is	battery	operated	and the	maximum	duration	of	flight	from	a	single	battery	charge	is	12	minutes	with	a	20%

reserve .	Since	the aircraft	will	never fly	more	than 3⁄4 N autical	Miles from	the	point	of intended	landing,	a	full	battery	charge	at	launch	will	ensure	that	we	meet	the	reserve energy	requirement	of	this	paragraph.	We	request	an	exemption	to	the	word	"fuel"	and	ask for	an	eq ui valent	interpretation	with	th e	word	"energy.”

14	C.F.R.		91.203	(a)	&	(b)

14	CFR	91.203(a)	&	(b)	Civil	ai rcraft:	Certifications	required

.

The	regulation	provides	that	an	airworthiness	certificate,	with	the	registration	number assigned	to	the	aircraft	a nd	a	registration	certificate	must	be	aboard	the	aircraft. Additionally,	subparagraph	(b)	provides	that	the	airworthiness	certificate	be	"displayed	at the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew." At	a	maximum gross	weight	of less	than	13 pounds,	the	sUAS	is	too	small	to	carry	documentation,	does	not have	an	entrance,	and	is	not	capable	of	carrying	passengers	or	crew.	To	obtain	an equivalent	level	of	safety	and	meet	the	intent	of	91.203,	we	propose	that	documents deemed	appropr iate	for	this	aircraft	by	the	FAA	will	be	co

- located	with	the	crew	at	the ground	control	station	and	available	for	inspection	upon	request.	In	order	to	identify	the aircraft,	we	propose	that	the	information	found	on	airworthiness	and	registration

certifica tes	be	permanently	affixed	to	the	aircraft	via placard	containing	the	applicable information	plus	the	word "EXPERIMENTAL"	to	satisfy	the	requirement	of	14	CFR	45.23.

14	C.F.R.		91.401

– 91.417

14	CFR	Subpart	E 91.401

- 91.417 Maintenance,	Preventive	Main tenance,	Alterations.

The	regulation	provides	that	the	operator	is	primarily	responsible	for	maintaining	the aircraft	in	an	airworthy	condition,	including	compliance	with	part	39	and	43.	Paragraphs 91.407	and	91.409	require	that	the	aircraft	be	"approved for	return	to	service	by	a	personauthorized	under	43.7"	after	maintenance	and	inspection. T he	PIC will perform maintenance	and	inspection	of	the	aircraft	and	"be	authorized	to	approve	the	aircraft	for

return	to	service."	The	PIC	will	ensure	that	the	aircr aft	is	in	an	airworthy	condition	prior	to every	flight	and	in	addition	conduct	detailed	inspections	after	every	two	hours	of	flight. Maintenance	and	repair	will	be performed	by	the	PIC,	as	the	PIC has	proven	knowledge	and experience	with	UAS	maintenance	an d	repair

. The	PIC	will	document	work	performed	in

accordance	with 91.417.	We	feel	that	due	to	the	size,	construction,	and	simplicity	of	the aircraft,	the	PIC	can	ensure	an	equivalent	level	of	safety.

Additional	Information	in	Support	of	Request:

Aerial Media	One	Inc.	currently	has	two	multirotor	aircraft.		First	a “Flying	Cinema,

Cinetank MK2L”	quad	rotor.		This	aircraft weighs	4.5	pounds	ready	to	fly. Its speed	is	less than	50kts,	and	a	GPS	enabled	flight	controller	allows	for	added	safety	with	fail

- sa fe	return to	launch,	and	auto	land	features. Second,	a	“Carbon	Core	950”	hexacopter.		This	aircraft has	a	ready	to	fly	weight	of	12.2	pounds.		The	airspeed	on	this	aircraft	is	also	less	than 50kts	and	the	very	robust	flight	control	system	allows	for	GPS guidance	and	fail

- safe

systems.

Aerial	Media	One	Inc.	keeps	detailed	flight	logs	of	each	of	our	aircraft.		This	coupled	with	a detailed	pre

- flight	inspection	and	flight	time	based	maintenance/inspection	intervals, allows	Aerial	Media	One	Inc.	to	keep our aircraft	flying	safely,	by	spotting	potential problems	before	they	arise.

Aerial	Media	One	Inc.	President,	and	P ilot	in	Command,	Mark	McBride, has	been	operating UAS	since	2008.		He	has	proven	hims elf	to	be	a	safe

, knowledgeable pilot,	and	UAV

Tec hnician. With	a	background	as an	ASE	master	certified	automotive	technician,	and

electrical systems	expert, he	is	able	to	maintain	and	repair	UAS	to	the	highest	level	of safety .		Mark	McBride	currently	hold	a	Class	3	airman	medical,	and	is	working	to	obtain	a pri vate	pilot	license.		As	of	the	time	of	this	letter	he	holds	22.5	hours	of	instructional	flight time,	2.5	hours Pilot	in	Command

, has	completed	an	FAA	approved	ground	s chool,	and	is preparing	to	take the FAA written	exam.		We	believe	that	these	credentials prove	that

Aerial	Media	One	In c.	can	operate	in	a	safe	manner with	regard	to	privacy	of	citizens	and property	while	maintaining	low	risk	operations	within	the	national	airspace	system.

Sincerely,

Mark	McBride,	President

Aerial	Media	One Inc.

8115	Gr enada	Drive Brighton,	MI	48116

517.404.1930