# MENN L A 

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April3, 2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room Wl2-140 1200 New Jersey Avenue, SE Washington , DC 20590 **~50** I l:: a...t

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. Box 785 Appl eto n . WI 54912-078 5 p 920. 7 3 1 .663 I f920.734.0981 Douglas 0. Hahn Dougla s-Hahn @. mennlaw. com D

irect Phone : 920.560
.4 7 18



### RE: Image Studios Inc
. Submission of Request for Authorization to Conduct Unmanned Aircraft Systems Operations Allowed by Section 333 of the FAA Modernization and Reform Act of 2012 Through tlte Exemption Process Identified Under 14 C.F.R. 

### § 11.81
Dear Sir /Madam: This firm represents Image Studios Inc. in its exemption request pursuant to section 333 ofthe FAA Modernization and Reform Act of2012 in order for Image Studios to operate its unmanned aircraft system (UAS) for the purposes of photography and videography. The enclosed petition provides the specific sectio ns from 14 C.F. R. from which Image Studios seeks exemptions, the reason relief is sought , how the exemptions would provide a level of safety at least equivalent to the rule, and how the exemptions benefit the public as a whole. Petitioner also provides additional information in the fonn of the UAS (DJI Phantom 2 Vision Plus) Quick Start Guide, Pilot Training Guide v l
. l , and User Manual v1 .8
. Thank you for your consideration ofthi s petition. Very truly yours, MENN LAW FIRM , L TO. 

# ])rMJ {s OJ

. 

# fiLDouglas D. Hahn

APPLETO -Joseph J. Beisenstein • Mark R. Feldmann • Joseph A. Bielinski • Douglas D. Hahn • Robert N. Duimstra • Patrick J.

**Co ffe~** 

**·** James N. Miron • Steven J. Frasscllo • Jarrod J. Papendorf • C hristopher D
. Wolske • Mitchell J
. Musial • Brenton D. Teeling Mary F. Co ughlin • Abby D. Theisen • lan M. Mevis • Jillayne Y. Verich • 'William P. McKinley • Kurt F. Ellison • Brian P. Bcisenstein SEYMOUR

- Perry D
. Pierre • Brennan T
. lhworth GREEN BAY

- Megan A. Kuehl • Mary Beth Callan • Jaso n G. Wied OF COUNSEL- Bruce K. Sc hmidt • Mark A
. Pennow WWW.MENNLAW.COM

### 9 1MAGE Image Studios Inc
. Michael Leschisin 1100 S. Lynndale Drive Appleton , WI 54914 920-738-4080 mleschi si n @ imagestudios.com April 3, 2015
U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington , DC 20590 

### RE: Image Studios Inc
. Submission of Request for Authorization to Conduct Unmanned Aircraft Systems Operations Allowed by Section 333 of the FAA Modernization and Reform Act of2012 Through the Exemption Process Identified Under 14 C.F.R. 

### § 11.81 Dear Sir /Madam, Pursuant to Section 333 ofthe FAA Modernization and Refonn Act of2012 (The Refonn Act), Image Studios Inc. ("Petitioner") , hereby applies for an exemption from the Federal Aviation Regulations (FARs) to allow commercial operation of an unmanned aerial system (UAS) for aerial photography and videography in advertising campaigns within the United States National Airspace System (NAS) so long as operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. This request is separate from any Certificate ofAuthorization/Waiver (COA) requested. Section 333 ofThe Reform Act allows the Secretary ofTransportation to detennine if certain UAS may operate safe ly in the national airspace based on , " their size, weight, speed , operational capability, proximity to airports and populated areas , and operation within visual line of sight.
.

., . as to not create a hazard to users of the national airspace system or the public, and not pose a threat to nati onal security. Pursuant to 14 C.F.R. 

### § 11.81 , contained within is detailed information on why the approval of the reque st is in the best interests of the public and how the approval w ill , ' ·... provide a level of safety at least equal to that provided by the rule from which,'" exemption is sought.Thank you for your time and co ns i

Michael Leschisin Partner /Owner Image Studios Inc
.

Applicant Contact Information: Image Studio s Inc. Attn: Michael Leschisin 1100 S
. Lynndale Drive Appleton , WI 54914 920-738-4080 mleschisin @ imagestudios .com ration in this matter.

<

### Table of Contents I. Company Background II. Training and Operations III. Regulations

- Exemptions Requested a. 14 CFR Part 21 Subpart H ; 14 CFR § 91.203 (a) (l): Airworthiness Certificates b. 14 CFR § 61.113 (a) and (b) and§ 61.133(a)(1)(ii): Private and Commercial Pilot Privileges and Limitations c. 14 CFR § 91.7(a): Civil Aircraft Worthiness d. 14 CFR § 91.9 (b)(2): Civil Aircraft Flight Manual e. 14 CFR § 91
. 109: Flight instruction 

### f. 14 CFR § 91.119: Minimum Safe Altitudes g. 14 CFR § 91.121: Altimeter Settings h
. 14 CFR § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 1. 14 CFR 

### § 91.405(a) , 

### § 91.407(a)(1 ) , 

### § 91.409(a)(2) and 

### § 91.417(a) and (b): Maintenance Inspections IV. Public Interest and Safety V. Federal Register SummaryI. 

### Company Background Petitioner has provided commercial photograph y and videography for advertising , corporate publications, catalogs , annual reports , and websites for nearly fifty years. Petitioner continually seeks to bring new technology, techniques, and creative methods to clients in order to maximize the effectiveness of advertisement campaigns. In order to continue to provide the best in advertising campaigns, Petitioner seeks regulatory exemptions that will allow Petitioner to employ UAS technology in the photography and v ideography process. 

### II
. Training and Operations The Aircraft: DJI Phantom 2 Vision Plus Des ign: The DJl Phantom 2 Vision Plus is comprised ofa UAS and a transportable ground station. It is a quad-copter that is equipped with four rotors that are driven by electronic motors and powered by batteries. It is approximately 23 inches square and 14 inches high. Aircraft Performance /Specifications:

• Flight Controls: o Primary: GPS guided autopilot (lock into at least 6 satellites) o Backup : Standard flight controls that combine gyro , accelerometers , barometer and compass for navigation • Power Suppl y: Battery

- 5200 mAh lithium-polymer • Speed: Maximum airspeed of 30 knots • Flight Time: Maximum of25 minute s • Weight: Approximately 3 lb s including battery and propellers Aircraft Registration : The UAS will be identified by serial number and regi stered in accordance with 14 C.F .R
. 

### § 47 , and have an identification markings in accordance with 14 C.F.R. § 45 Subpart C. These markings will be made as large as is practicable on the UAS in accordance with 14 C.F. R. 

### § 45.29 

### (f). Maintenance Standards: Pilot in charge (PIC) must detennine whether UAS is in condition for safe fli ght.Pre and post flight inspections will be routinely conducted. Maintenance will be performed in accordance with the manufacturer ' s guidelines and by certified technicians
. All inspections and maintenance will be documented in hou se. After maintenance, certified technicians will verify the UAS is ready for flight. PIC Training: PIC will : o Have a private pilot license ; o Have a third-class ainnan medical cettificate; o Meet the minimum flight hour requirements required b y the FAA in Exemption No. 11062 {Astraeus) and in a manner consistent with 14 C.F.R. 

### § 61.51 (b), defined below

Visual Observer: • Flight hours: PIC must complete 25 hours oftotal time as a UAS rotorcraft pilot. Included in these 25 hours , the PIC must log at least 10 hours as a UAS pilot with a multi-rotor UAS and at least 5 hours operating the DJ I Phantom 2 Vision Plus
. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience-building flights , the PIC is required to operate the UAS within appropriate distances in accordance with 14 C.F.R. 

### § 91.119. Pursuant to Exemption No. 11138 {Trudeau). • Skills: The PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes)
. • Manufacturer's Certification and Training: PIC must review all DJI Phantom 2 Vi sion Plu s manu als , training and quickstart guides, and tutorials. These will be updated from time to time and PIC is required to keep up to date with these manuals , guides , and tutorials
. • Prior Documented Flight Experience: Pr ior documented flight experience that was obtained in compliance with applicable regulations will s atisfy the flight hours requirement.

Must complete all training contained in Operating Documents
. Must maintain sight ofUAS at all time s. Does not need an ainnan medical certificate.

2

### Operations Execution Given the fact that commercial UAS operations are restricted due to the lack of regulations , a logical and s afe solution is to utili ze the parameters of model aircraft operation outlined in Section 336 of PL 112-95 as well as other guidelines found within 14 C.F.R. The following list provides specific rules and guidelines all Petitioner UAS operations will adhere to in order to ensure at least an equivalent or higher level of safety when compared to manned aircraft perfonning the same functions as outlined in 14 C.F.R .: I) All flight crews will : • Be comprised of a minimum of3 members. One for piloting, one for visual observation, and one for camera operation. • Perfonn pre flight operations to ensure the safety ofthe flight in accordance with C.F.R. 

### § 91.103 (b) {I) and (2) , excepting the Aircraft and Rotorcraft Manual requirements ofthe regulation , including reviewing: o Weather such as wind speeds that will affect the flight or cloud cover and sun glare that will affect visibility ofthe UAS or other aircraft; o Flight battery requirements ; o Landing and take-off distances ; o Aircraft perfonnance data ; and o Relevant site specific condition s . • Schedule flight in a daily production sheet. • Infonn all persons on site ofthe flight plan and the UAS ' s operation. 2) All flight operations will : • Fly below 400 feet and remain clear of s urrounding obstacles . • Keep the aircraft within visual line of sight at all times. • Remain well clear of and not interfere with manned aircraft operations. • Not fly within 5 miles of an airport unless contact is made with the airport and control tower before flying. • Not fly near groups ofpeople, stadiums or members ofthe general public
. • Be conducted using a UAS weighing Jess than 55 lbs. • Not fly in a careless or reckless manner. • Limit flight to days when weather will not create unnecessary safety risks. • Limit flight to remote areas away from the public, and ifpossible conducted on a closed set. • Be conducted with the permission of property owner or controller where the flight is taking place. • Have a predetermined flight plan that all crew members are aware of. 3• Take place 500 feet away from non-participating person s, vessels, veh icles , and structures. Non-participating mean s those persons, vessels , vehicles , and structures that are not associated with the UAS photography or videography production. • Briefparticipating persons on the potential risks ofthe proposed flight operations. Participating persons mu st acknowledge and accept the risks. • Utili ze a barrier including terrain features , obstructions or buildings for nonparticipating persons in the event the UAS will fly closer than 500 feet to them. Pursuant to Exemption No. 111 89 (Video Solutions). • Conduct flight at a safe distance from participating persons as to not present an undue hazard to the essential person. • Be conducted during daylight. For safety , the UAS is eq uipped with preprogrammed and user programmable flight limits. GPS coordinates for Restricted Flight Areas including all airports worldwide are preprogrammed into the UAS. The UAS will not take off or fly in these restricted areas in either mode ofnavigation and if flown into restricted airspace , will automatically descend and land. The UAS is also equipped wit h user programmable flight limits. The programmable flight limit functions allows the UAS pilot to set a ''maximum distance from a home point," (generall y the location of the pilot) , and a maximum altitude that the UAS will not fly beyond , in Petitioner' s case, the UAS will be programmed to allow for the distance of required filming , but no further. 3) Emergency Procedures : Failsafe Mode

• Pilot Activated or Loss of Communication The DJI Phantom 2 Vision Plu s is equipped with failsafe mode. Failsafe mode is activated if communication between the RC controller is broken or ifthe pilot activates it. It causes the aircraft to climb to a programmable altitude that is set by the operator to avoid obstacles , and fly at that altitude to a preset " home point", which will generall y be the takeoff location , and land.
• Loss of Power The DJI Phantom 2 Vision Plu s is also equipped with failsafe protection in the event the battery is running low. The aircraft will monitor the battery level throughout the flight and ifthe battery reaches a level of 30%, the UAS will communicate with the pilot via a flashing red screen and alann on the Vision 2 app, which is used on a smart device via WiFi , as well as flashing red lights on the aircraft itself. The Vision 2 app is used in conjunction with the RC contro ller. Once the UAS reache s a battery level of 15 %, the UAS will enter failsafe mode, return to the home point, and land
.

4

### Ill. Regulations- Exemption Requested Pursuant to 14 CFR § 11.81(b) and (e), Petitioner seeks exemptions from the below mentioned regulations and provides reasons as to why the exemptions should be approved based on the level of safety at least equal to what the rule requires.


### a. 14 C.F.R. § 21 Subpart H; 14 C.F.R. § 91.203 (a) (1): Airworthiness Certificates Subpart H , entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairwmthiness ce1tificates as required by 14 C.F. R. § 91.203 (a) (l). An exemption from 14 C.F.R. § 21 subpart H meets the requirements of an equivalent level of safety under § 11 and§ 333 of The Reform Act considering the UAS 's
..size, weight, speed , operational capability and proximity to airports and populated areas ..." The UAS measures 14 inches tall and 23 inches square. It weighsjust 3 lb s . , can achieve a maximum flight speed of just 30 knots , and a maximum flight time of 25 minutes. It does not carry passenger, pilot, or flammable or explosive materials, liquid s, or fuels. As stated in the Operations Execution section above , the UAS will operate in compliance with the model aircraft operation parameters and wi ll be programmed before each fli ght to only the areas necessary for Petitioner' s specificjob. Further, the UAS is able to respond to a Joss ofGPS , controller communication , or battery power with a pre-coordinated, predictable, automated flight maneuver known as fail safe mode. These safety features provide an equi valent level of safety compared to a manned aircraft holding a restricted airworthiness certificate perfonning a similar operation. 

### b. 14 C.F.R. § 61.113 

### (a) and (b) and§ 61.133(a)(l)(ii)- 

### Private and Commercial Pilot Privileges and Limitations 14 C.F.R. 

### § 61.1 13 (a) and (b) states that , " (a)
. .. no person who hold s a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person , for compensation or hire , act as a pilot in command of an aircraft (b) A private pilot may, for compensation or hire, act as a pilot in command of an aircraft in connection with any business or employment if: (1) The flight is on ly incidental to that business or employment (2) The aircraft does not carry passengers or property for compensation or hire. " 14 C.F.R. 

### § 61.133 (a) ( 1 ) states , · · . . . A person who hold s a commercial pilot certificate may act as a pilot in command of an aircraft

. . . (ii) For compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts ofthis chapter that apply to the operation...
5§ 61.113 (a) and (b) limits private pilots to non-commercial operations . But , because the UAS will not be catTying a pilot or passengers, will operate in the NAS over property which they have been granted pennission by the property owner /controller, and the ainnanship skills necessary to operate a UAS are not as extensive as those necessary to operate a commercial airliner, an equivalent level of safety can be achieved by requiring the pilot operating the UAS to have a private pilot ' s license and a third-class airman medical certificate. Further, the area of operation ofthe UAS will be controlled and restricted and all flights are planned and coordinated in advance using the UAS's pre-programmed flight limits
. Unlike a conventional commercial aircraft with pilot and passengers, a UAS operated by a private pilot exceeds the level of safety provided in § 61.113 and§ 61.133. Petitioner requests the same relief as was granted in Exemption No
. 11172 (Blue-Chip) and Exemption No. II 062 (Astraeus).


### c. 14 C.F.R. 

### § 91.7(a)- Civil Aircraft Worthiness This regulation states that, '·no person may operate a civil aircraft unle s s it is in an airwm1hy condition. " As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist to detem1ine airworthiness. Given the size of the aircraft and Petitioner' s maintenance standards , an equivalent level of safety will be provided. 

### d. 14 C.F.R. § 91.9 (b)(2)- Civil Aircraft Flight Manual in the Aircraft This section provides, " No person may operate a U.S. registered civil aircraft-

. .. (2) For which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 ofthis 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. ' " The UAS , gi ven its size and shape has no ability to place or carry such a flight manual on the aircraft. An equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.


### e. 14 C.F.R. 

### § 91.109- Flight instruction This section prohibits operation of a civil aircraft, other than a manned free balloon, that is being used for flight instruction unless the aircraft has fully functioning dual controls. The majority of UAS and remotely piloted aircraft by their design do not have fully functional dual controls. Generally, they are developed with a single operational control through the use of pre-detennined GPS enabled waypoints programmed before flight in addition to the use of a single hand held transmitter or control station controlled by the pilot. This design doe s not allow for dual control s during flight training.
6An equivalent level of safety will be ensured during training operations based on the size and speed of the aircraft coupled with the lack ofpilots , passengers, and flammable liquids and fuels , by utilizing the same flight planning process as nonnal operations. 

### f. 14 C.F.R. § 91.119- Minimum Safe Altitudes This section establishes safe altitudes for the operation of civil aircraft and states, · ' [ e]xcept when necessary for takeoffor 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 operated closer than 500 feet to any person, vesse l, vehicle, or structure." ' Petitioner will achieve an equivalent level of safety because UAS operation will be conducted below 400 feet in accordance with the model aircraft operation parameters. In open areas, the UAS wi ll not be operated within 500 feet of any non-essential persons, veh icles, vessels, or structures. The UAS may be operated within 500 feet of essential flight personnel when operations are necessary , provided operation s wi ll not cause an undue hazard to an essential person. In areas which are not open areas, the PIC shall make a safety assessment. Ifban·iers or structures are present that can suffici ently protect non-essential persons from the UAS or debris in the event of an accident, then the UAS may operate closer than 500 feet to persons afforded such protection, for so long as the persons remain under such protection. The operator shall immediately cease operations in a safe manner when such non-essential persons leave their protection and the UAS is within 500 feet. Petitioner may conduct operations closer than 500 feet to vessels , vehicles , and structures on ly when the owner /controller of any such vessels , vehicles, or structures grants pennission for the operati on and the PIC makes a safety assessment ofthe risk of operating closer to those objects and detennines that it does not present an undue hazard. 

### g. 14 C.F.R. § 

### 91.121- Altimeter Settings This section states , '·[ e]ach person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operating
..." UASs are equipped with GPS which provides altitude and geo-location data, rather than a barometric altimeter. An equi valent level of safety wi ll be achieved by utilizing the DJI Phantom 2 Vision Plu s software during flight which allows the PIC to view real time altimeter readings via a WiFi signal to a smart device and by the PIC confirming the altitude ofthe UAS at launch and in flight. Further, the DJI Phantom 2 Vision Plus emergency procedures commence landing ifcontact with the pilot is broken.

7

### h. 14 C.F.R. § 91.15l(a)- Fuel Requirements for Flight in VFR Conditions This section states , '·No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and , assuming nonnal cruising speed

- (1) during the day, to fly for at least 30 minutes
.. :· This regulation is written based on the capabilities oftraditional aircraft which have flight times of several hours or greater. UAS on the other hand , generally only have flight times of an hour or less. The DJI Phantom 2 Vision Plus only has a maximum flight time of25 minutes. In order to ensure an equivalent level of safety, once the UAS reaches a power level of no less than 20%, Petitioner will begin return to home procedures and initiate a landing seq uence. 

### i. 14 C.F.R. § 91.405(a), § 91.407(a)(l), § 91.409(a)(2) and§ 91.417(a) and (b)- Maintenance Inspections § 91.405 (a) states,
.. Each owner or 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) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter
..." 

### § 91.407 (a)(l) states , "No person may operate any aircraft that has undergone maintenance , preventati ve maintenance, rebuilding, or alteration unless- (I) it has been approved for return to service by a person authori zed under § 43.7 of this chapter

. .." 

### § 9 1.409 (a)(2) s tates , "Except as provided in paragraph (c) of this section, no person may operate an aircraft unless , within the preceding 12 calendar months , it has had

- ... (2) An inspection for the i ssuance of airworthiness certificate in accordance with part 21 ofthis chapter. No inspection perfonned under paragraph (b) ofthis section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an ..annual " inspection in the required maintenance record s. " § 9 1.41 7 (a) and (b) states , " Except for work performed in accordance with §§ 9 1.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section
... (b) The owner or operator shall retain the following records for the periods prescribed
.. ." Given that these sections and part 43 only apply to aircraft with an airworthiness certificate, these section s will not apply to Petitioner, and therefore an exemption is required. An equivalent level of safety can be achieved because the UAS is small , has a 25 minute flight time, and will be operated in restricted and controlled areas. Once the UAS reaches a power level of no less than 20%, Petitioner will begin return to home procedures and a initiate landing sequence . Therefore, if mechanical is s ues do arise, the UAS will land immediately within the controll ed operating
8area. Further, an equivalent leve l of safety is achieved through Petitioner ·s maintenance standards. Petitioner will routinely conduct pre and po st flight inspections and maintenance will be performed in accordance with the manufacturer's guideline s and by certified technici ans. All inspection s and maintenance will be documented in house
. After m aintenance, certified teclmician s will verify the UAS is ready for flight. 

### IV. Public Interest and Safety The Public ' s best interest is achieved by the sa fe integration ofUAS into the NAS. With the ongoing exemption proce ss, the FAA has to identify tho se exemption requests with the public ' s best interest in mind and select the companies who will be able to achieve this in a safe and res ponsible manner in order to pave the way for commercial use of UAS. Petitioner is one of these companies

. Petitioner will provide aerial photography and videography utilizing UAS in strict operating environments. The use of UAS in this field will benefit the public by encouraging a higher level of creati ve work at a lower cost to clients which will allow these clients to become more profitable. The incr ease in profitability can create a larger customer base for the client, which can therefore increase demand oftheir products , and ultimately lead to morejob s, increased wages, and the growth of the overall economy in Petitioner' s region. Further, the use ofUAS in this field will benefit the public by utili z ing a safer aircraft for creative purpo ses. Aerial photography and videography has been limited to manned fixed wing aircraft and heli copters. These aircraft can weigh 5000 lb s. or more and are operated by an on board pilot, in addition to other onboard crew members, as necessa ry. In comparison, Petitioner' s aircraft weighs just 3 lbs. and the pilot and crew will be remotely located from the aircraft. The limited weight ofthe aircraft s ignificantly reduces the potential for ha rm to persons or damage to property in the event of an incident or accident while the ri sk to onboard pilot and crew is eliminated. Further, m a 1med aircraft can carry I00 gallons or more o f fuel and therefore are at ri sk offuel spillage or fire in the event of an incident or accident. The DJI Phantom 2 Vision Plus carries no fuel and therefore the ri sk of fire f ollowing an incident or accident due to fuel spillage is related.

9V. Federal Register Summary Pursuant to Section 333 ofthe FAA Moderni zation and Refonn Act of2012 (The Refonn Act) , Image Studios Inc. (Petitioner) , hereby applies for an exemption from the Federal Aviation Regulations (FARs) to allow commercial operation of unmanned aelial systems (UAS) for aerial photography and videography in advertising campaigns within the United States National Airspace System (NAS) so long as operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Section 333 ofThe Refonn Act allows the Secretary ofTransportation to determine if certain UASs may operate safely in the national airspace based on , " their s ize, weight, speed, operational capability, proximity to airports and populated areas , and operation within visual line of sight.
.." as to not create a hazard to users ofthe national airspace system or the public, and not pose a threat to national security. Petitioner has provided commercial photography and videography for advertising , corporate publications, catalogs, annual reports , and websites for nearly fifty years. Petitioner continually seeks to bling new technology, teclmiques , and creative methods to clients in order to maximize the effectiveness of advertisement campaigns. Petitioner has a vested interest in seeing that the UAS is operated safely, so as not to tarnish Petitioner' s business reputation. In order to continue to provide the best in advertising campaigns , in a safe and reasonable way , Petitioner seeks regulatory exemptions that will allow Petitioner to employ UAS technology in the photography and videography process. Regulations from which an exemption is requested:
a . 14 C.F.R. § 2 1 Subpart H; 14 C.F.R. § 91.203 (a) (I)

- Airworthiness Certificates b. 14 C
. F.R. § 61.113 (a) and (b) and§ 61.133(a)(1)(ii)- Plivate and Commercial Pilot Privileges and Limitations c. 14 C.F.R. § 91.7(a)

- Civil Aircraft Worthiness d. 14 C.F.R. § 91.9 (b)(2)

- Civil Aircraft Flight Manual e. 14 C.F.R. § 91.109

- Flight instruction 

### f. 14 C.F.R. § 91.119- Minimum Safe Altitudes g. 14 C.F.R. § 91.121- Altimeter Settings h. 14 C.F.R. § 91.15l(a)

- Fuel Requirements for Flight in VFR Conditions 1. 14 C.F.R. 

### § 91.405(a) , § 91.407(a)(l) , § 91.409(a)(2) and§ 91.417(a) and (b)

- Maintenance Inspection s Through this exemption request, Petitioner has shown that they will ensure the public ' s best interest during UAS operation. The s mall size, weight, and speed of Petitioner's UAS combined with extensive safety precautions ensures that Petitioner will safely operate UASs. Petitioner has also shown how approval ofthi s request will meet and /or exceed an equivalent level of safety for the exemptions requested. 10