September 3, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Ronin Aerial Photography for an Exemption Pursu ant to Section 333 of the

FAA Modernization and Reform Act of 2012

Director: Flight Standards Service:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Ronin Aerial Photography (“ RAP ”) hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles ( i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting aerial photography, videography, stock video footage , residential and commercial real

estate for related real estate and construction industries.

This petition for exemption is made based on information outlin ed in this Petition for Exemption, as well as the accompanying RAP documents;

1. PIC Flight Operations Manual and; 2. Operations Manuals (collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. Flight Manual (collectively 3 and 4 are referred to as "Manufacturer's Manual s") 1

RAP submits these supporting materials as confidential document s pursuant to 14 C.F.R. § 11.35(b), as the materials contai n confidential commercial and/ or proprietary information that RAP has not and will not share with other requesting parties. A dditionally, these documents contain operating conditions and proc edures that are not genera lly available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et. seq.

1 The term "Manufacturer's Manual" also includes all relevant man ufacturer publications, including, but not limited to: operations and flight manuals, user guides, compone nt maintenance manuals, pilot training manuals,

service information letters a nd, safety/service bulletins.U.S Department of Transportation September 1, 2015 Page 2

For your convenience, this Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Aerial Real Estate Videography and Photography Services

III. Relevant Statutory Authority

IV. Ronin Aerial Photography ’ s Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, a nd Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Roto rcraft

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking a nd Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91. 409(a)(1) and (2); 91.4 17(a) and (b): Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Privat e Pilot Privileges and

Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Air craft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Re gistration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Cond itions

V1. Drug and Alcohol Program

VII. Public Interest VIII. Privacy IX. Federal Register Summary

X. ConclusionU.S Department of Transportation September 1, 2015 Page 3

I. DESCRIPTION OF PETITIONER

Ronin Aerial Photography, is based in Las Vegas, NV working in real estate photography and videography services. The Company specializes in, and will cont inue to focus on, the photography and videography of property and real estate for sales pur poses as well as property mapping and inspections . The Company’s Principal and Chief Pilot Brandon Fowler has been flying UAV Quadcopters as a hobby for more than three years without incide nt, spending thousands of hours flying.

Upon the grant of the 333 Exemption the Company’s business will specialize in real estate ph otography and videography of residential, commercial and industr ial for the promotion of properties for sale and land development. Ronin Aerial Photography ’ s staff are well trained and experienced in providing support as visual observers (“VO”) for the pilot in command (“PIC”) in addition to any other needed on site assistance.

All of the equipment owned by Ronin Aerial Photography is of th e highest quality gear and has been able to provide these services safely and without any clai ms or incident. Ronin Aerial Photography ’ s goal is to advise the perspective client that Ronin Aerial Ph otography is following all the applicable state and federal rules to ensure the safety of the public while providing the client with a competitive and cost effective product.

Ronin Aerial Photography seeks an exemption to allow for photography, videography and ot her related media products.

The contact information for Petitioner is as follows:

Brandon Fowler Ronin Aerial Photography

9973 Lost Colt Cir Las Vegas, NV

Phone: 702.353.5423 Email: brandon@calypsodevelopment.com

II. DESCRIPTION OF PROPOSED OPERATION

RAP seeks an exemption pursuant to Section 333 of the Reform Ac t to operate the DJI Phantom 3 Inspire, 3DRIris+ (referred to R-UAS ) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly cont rolled conditions on private property where RAP has received verifiable permission to operat e from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance with the conditions and limitations of this Petition for Exemption a nd Ronin Aerial Photography ’ Operations Manuals. As detailed in Ronin Aerial Photography ’s Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within vi sual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 mm away from an airport reference point. Moreover, Ronin Aerial Photography ’s Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel out side the controlled area of UAS operations, including GPS "geo-fencing" technologies.U.S Department of Transportation September 1, 2015 Page 4

A. Real Estate Aerial Photography and Videography Services

RAP seeks to use small RAP-UAS for the purpose of conducting ae rial photography, videography, mapping and inspection service s for the real estate indust ry. RAP has purposefully tailored its operations to meet the requirements established by the FAA in prior grants of exemption authorizing commercial use of UAS in the real estate industry, in cluding:

x Trudeau, Realtor® (Exemption No. 11138)

x Alon Sicherman (Exemption No. 11728)

x Sokoler Medly (Exemption No. 11341)

All UAS real estate photography and videography operations will occur on private property in a controlled area away from spectators and persons not involved i n the recording process. In addition, the filming will be conducted between dawn and dusk t o ensure maximum safety for the public and those involved in the manipulation and operation of the UAS; VFR conditions, at altitudes below 400' above ground level (“AGL”).

As set forth below, Ronin Aerial Photography ’s operations provide an equiv alent level of safety which is superior to performing the same work using conventiona l fixed-wing aircraft or helicopters.

Small UAS real estate video production is also safer than tradi tional manned aircraft performing the same function. Videographer also frequently need to cli mb roof tops, trees, or otherwise perform elevated work, whic h exposes them to the risk of d angerous falls, electrocution or other work related injuries. In addition, depending on the n ature of the video needed and proximity to equipment, and other mechanical hazards associatedwith industrial sites and construction facilities often involves a risk of exposure to hazar dous conditions. The use of RUAS mitigates these hazards and is ultimately a much safer and cost efficient method of performing these and most other types of inspections.

Moreover, conventional operations using rotorcraft and fixed-wi ng aircraft in low level operations present risks associated with vehicles weighing tens of thousands of pounds (including payload) and carrying large amounts of fuel which in herently presents significant fire hazards as well as exposure to oth er chemical contaminates. It is important to note the use of small UAS in this area will not only be safer and more cost eff ective to the perspective user or purchaser of the service, but the quality and expanse of acquir ed information will be far more robust given the low cost associated with its acquisition and o ther potential consumers an inexpensive product.

UAS real estate video production is more reliable, and allows f or the collection, dissemination, and storage of visual and other sensory data with greater preci sion and duration at a very low cost. Small UASs will also be capable of accessing and inspect ing areas that would otherwise be inaccessible or highly dangerous using conventional aircraft or other inspection methods.U.S Department of Transportation September 1, 2015 Page 5

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 33 3(a) through (c) of the FAA Modernization and Reform Act of 2012 ("Reform Act"). Congre ss has directed the FAA "to safely accelerate the integration of civil unmanned aircraf t systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Adm inistrator is to permit unmanned aircraft systems to operate in the National Airspace S ystems ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximit y to airports and populated areas; and

● Ope ration of the UAS within the visual line of sight of the operat or.

Additionally, the FAA Administrator has general authority to gr ant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (de fining the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions fro m §§ 44701(a), (b) and §§ 44702

– 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) wou ld not adversely affect safety (or how it would provide a level of safety at least equal to the ex isting rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. RONIN AERIAL PHOTOGRAP HY ’S PROPOSED R-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

The small R-UAS operations proposed by RAP as noted above in th is Petition for Exemption qualify for expedited approval pursuant to Section 333 of the R eform Act as each of the statutory

criteria and relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, a nd Operational Capability

A Grant of Exemption is appropriate for operations conducted us ing the UASs due to their size weight, speed, and operational capability.

x The UAS utilized by RAP has been approved for use in prior Sect ion 333 Grants of Exemption from the FAA. 1

x The UAS weighs less than 55 pounds, including payload

x The UAS will not be flown at a ground speed in excess of 50 kno ts.

1 See e.g., Grant of Exemption to Trudeau, Realtor® (Exemption No . 11138); Grant of Exemption to Alon Sicherman (Exemption No. 11728); Grant of Exemption to Sokoler Medly (Exemption No. 11341).U.S Department of Transportation September 1, 2015 Page 6

x Altitude information will be ge nerated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. This information will be transmitted to the pilot

via telemetric data feed.

x The R-UAS will have system redundancies and independent functio nality to ensure the overall safety and predictability of the system. If connection to the remote control or ground control station i s lost, failsafe systems wil l permit the UASs to return to a predetermined location and safely land without inju ry or damage.

x The radio frequencies used for operations and control of the R- UAS comply with

the Federal Communications Com mission ("FCC") and other appropr iate government oversight agency requirements. The operating frequency for the R-UAS is 2.4 GHz frequency bands.

If the same operations were conducted using a helicopter, the a ircraft's take-off weight would likely exceed 6,000 pounds depending on payload. The difference in weight between the R-UAS and a helicopter significantly reduces the potential harm to th e participating and nonparticipating individuals and/or surrounding property in the ev ent of an unintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in Ronin Aerial Photography ’s Operations Manuals

Ronin Aerial Photography ’s Operations Manuals and the Manufacturer's Manual for the selec ted R-UAS will contain all the pro cedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption . To assist the FAA in making a safety assessment of Ronin Aerial Photography ’s proposed operations, below is a summary of operational limitations and conditions that RAP will adhere to, and which will ensure an equivalent or higher level of safety to operations conducted un der current regulatory guidelines:

1. The R-UAS weighs less than 55 pounds, with payload.

2. All operations shall be conducted over private or controlled-ac cess property with verifiable permission from the land owner/controller or authori zed representative. Permission from land owner/controller or authorized representat ive will be obtained for each scheduled flight prior to operation.

3. All UASs operated under the Grant of Exemption will be identifi ed by serial number, registered in accordance with 14 CFR part 47, and have identifi cation (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight ope ration will consist of a pilot, who will be Pilot-in Command ("PIC") of the R-UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct the mission.U.S Department of Transportation September 1, 2015 Page 7

5. PICs shall possess at least a S port or Private Pilot's Certific ate shall possess at least a

current Class III Medical Certificate and/or a valid and curren t driv er’s license issued

within the United States. The P IC will also meet the flight rev iew requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his or her pilot

certificate.

6. The R-UAS shall be operated within VLOS of the PIC and Observer at all times. The PIC must use human vision unaided by any device other than corr ective lenses, as specified on the PIC's FAA-issued medical certificate.

7. The PIC and Observer designate d for any operation will be able to communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during fl ight operations.

9. The additional requirements identified in the Grant of Exemptio n shall be added to the Ronin Aerial Photography ’s Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request . If a discrepancy

exists between the conditions and limitations in the Grant of E xemption and Ronin Aerial Photography ’s Operations Manuals, the conditions and limitations in the Gran t of Exemption shall take precedence and must be followed. Otherw ise, RAP shall follow the procedures outline d in their Operations Manuals.

10. RAP may update or revise its Oper ations Manuals. Revisions wil l be tracked and a revised copy of the Manual will be provided to the Administrato r upon request. RAP will also present an updated and revised Operations Manuals if it petitions for extension or amendment to its Gra nt of Exemption. If an update or re vision would affect the basis upon which the FAA grant s the exemption, RAP will see k an amendment to its Grant of Exemption. RAP will contact the FAA’s UAS Integr ation Office (AFS80) if questions arise regarding updates or revisions to the op erating documents.

11. RAP Operations Manuals and its Grant of Exemption will be avai lable to the PIC at the ground control station anytime the R-UAS is operating.

12. The PIC is prohibited from beginning a R-UAS flight unless (con sidering wind and forecast weather conditions) there is enough power to fly to th e first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the R-UAS will be

limited to 40 minutes or the amount of time the UAS can be flow n and still maintain a reserve battery power of no less than 25%, whichever occurs fir st.

14. Flights will be operated at an altitude of no more than 400 fee t AGL and will never enter navigable controlled airsp ace without timely prior writte n authorization and approval from the FAA. In the event the structure being inspect ed exceeds 400 feet AGL, the UAS will not be opera ted more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the struc ture.U.S Department of Transportation September 1, 2015 Page 8

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are pre sent that sufficiently protect no nparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipa ting persons remain under such pro tection. If a situation arises where nonparticipating persons leave such prot ection and are within 500 feet of the UA, flight operations must cease immedia tely and/or;

b. The aircraft is operated near vessels, vehicles or structures w here the

owner/controller of such vessels , vehicles or structures has gr anted permission and the PIC has made a safety assessment of the risk of operati ng closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essentia l persons do not present an undue hazard to those persons per § 91.119(a).

16. The R-UAS 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 3 sta tute miles from the PIC.

17. The R-UAS may not operate within 5 nm of an airport reference p oint as denoted on a current FAA-published aeronautical chart unless a letter of agr eement with that airport’s management is obtained, and the operation is conducted in a ccordance with a NOTAM as required by the RAP COA. The letter of agreement wi th the airport management will be made available to the Administrator upon req uest.

18. Prior to each flight the PIC sha ll inspect the R-UASs to confir m that it is in a condition safe for flight. The pre-flight inspection will accou nt for all discrepancies, e.g. inoperable components, item s, or equipment, not already co vered in the relevant sections of the operating documents as well as equipment update s. The PIC shall not operate any R-UASs if the inspection reveals a condition that a ffects the safe operation of the R-UAS until the necessary maintenance has been performed and the R-UAS is found to be in a condition for safe flight. The ground control station shall be included in the preflight i nspection. All maintenance and al ternations must be properly documented in the UAS ’s records as required by Ronin Aerial Photography ’s Operations Manuals.

19. RAP will timely carry out its m aintenance, inspections, and re cord keeping requirements in accordance with the Operations Manuals. Mainten ance, inspection, and alterations will be fully noted in the R-UAS records, inclu ding total time in service, description of work accomplished, date completed and t he signature of the authorized person returning the R-UAS to service.

20. Any R-UAS that has undergone maintenance or alterations that af fect the UAS operation or flight characteristics (e.g., replacement of a fli ght critical component) must timely undergo a functional test flight in accordance with Ronin Aerial Photography ’s Operations Manuals. The PIC who conducts the functional test f lightU.S Department of Transportation September 1, 2015 Page 9

must make an entry in the UAS aircraft records of the flight. T he requirements and procedures for a functional test flight and R-UAS record entry shall be included in the Ronin Aerial Photography ’s Operations Manuals.

21. The R-UAS will be operated and maintained according to the Manu facturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates.

22. Prior to the operation, a Mission Packet will be created in acc ordance with the requirements on Ronin Aerial Photography ’s Operations Manuals.

23. RAP will obtain an Air Traffic Organization ("ATO") issued Cer tificate of Waiver or Authorization, otherwise known a s a COA, prior to conducting an y operations under this Grant of Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in accordance with airspace requir ements in the ATO issued COA including class of airspace, altitude level and pote ntial transponder requirements.

24. All required permissions and pe rmits will be obtained from terr itorial, state, county or city jurisdictions, including local law enforcement, fire or ot her appropriate governmental agencies.

25. If the R-UAS loses communication with the PIC, it will have the capability to safely return to a pre-determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight i f there is a loss of

communication between the PIC and the Observer.

27. The R-UAS will have the capability to safely abort flight in th e case of unpredicted obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medic al Certificate or a valid

and current state driver’s license issued within the United States

.

29. Prior to conducting operations for filming, the PIC will have a ccumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 h ours logged as a UAS pilot with a similar R-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist.

30. Prior to conducting operations for filming, the PIC will have a ccumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of hou rs pursuant to 54 CFR § 61.51(b) as UAS pilot operating the make and model of R-U AS to be utilized for operations under the exemption and three take-offs and thre e landing in the preceding 90 days.

31. Operations shall occur during da ytime VFR Meteorological Condit ions; flights under special visual flight rules ( "SVFR") shall not be conducted.U.S Department of Transportation September 1, 2015 Page 10

32. The R-UAS shall remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limi ted to, ultralight vehicles, parachute activities, parasai ling activities, hang gliders, etc .).

33. R-UAS Operations under Instrument Flight Rules, at night, or be yond VLOS are prohibited.

34. The R-UAS will not be operated from an elevated platform or mov ing device/vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control of the R-UAS will comply with the Federal Communication s Commission (FCC) or other appropriate government oversight agency requirem ents.

V

. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms , includes exempting civil air craft, as the term is defined under § 40101 of the Act, including UASs, from its safety regulations a nd minimum standards when the Administrator decides a requested exemption is in the public in terest. 2

RAP seeks an exemption from se veral interrelated provisions of Title 14 of the Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes o f conducting the requested operations using R-UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating proc edures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. 3

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §91.203(a)(1)

The FAA has stated that no exemption is needed from this sectio n if a finding is made under the Reform Act that the UAS selected provides an equivalent level o f safety when compared to aircraft normally used for the same application. These criteria are met and in point of fact exceeded, and therefore no exemption is needed. 4 If, however, the FAA determines that there

are some characteristics of the chosen UAS that fail to meet th e requirements of the Reform Act, an exemption is requested.

2 49 U.S.C. § 44701(f) (authorizing t he grant of exemptions from requirements of regulati ons prescribed pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

3 14 C.F.R § 11.81(e), which requires a petition for exemption t o include: The reasons why granting the exemption would not adversely affect saf ety, or how the exemption would p rovide a level of safety at least equal to that provided by the rule from which you seek exemption.

4 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0 352 at pgs. 13-14, 22).U.S Department of Transportation September 1, 2015 Page 11

Equivalent Level of Safety

Ronin Aerial Photography ’s use of the R-UAS is safe when taking into account its size, we ight, speed, and operational capability. As set forth in the descript ion of proposed operations in Section IV(A), the R-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of 50 knots. The R-UAS is also equ ipped with safety features which will allow Petitioner to operate the R-UAS safely after experie ncing certain in-flight contingencies or failures as noted below. 5 6

Additionally, the R-UAS carr ies neither pilots nor passengers, carries no explosive materials or flammable liquid fuels, or other elements identified by Homelan d Security as being prohibitive and operate exclusively within the parameters stated in Ronin A erial Photography ’s Operations

Manuals.

Operations conducted under this e xemption will be closely contr olled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area of operati on. RAP will also provide the F AA with advance notice of all operations via NOTAMs as required by the applicable COA. In all cases, operation of the R-UAS under the proposed conditions will be at least as safe as, or s afer than, conventional rotorcraft operating with an airworthiness certificate. Lastly, the R-UASs do not need a means to communicate with other aircraft or ATC, because those capabilit ies will be solely possessed by the PIC and Observer, who are not onboard the R-UAS. 7 In addition, no sense-and-avoid

5 See e.g., Grant of Exemption N o. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI S1000] has the capability to operate safely after experiencing certainin-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link eve nt with a pre-coordinated, predi ctable, automated flight man euver, and manual flight control functionality as a bac kup. These safety features provid e an equivalent level of safety compared to a manned aircraft performing a similar operation."

6 See e.g., Grant of Exemption N o. 11184 to VDOS Global, LLC. (FA A-2014-0382 at pgs. 4-5): "The FM-UAS can be operated entirely by a touch-screen, map-based interface. Th is means the operator only needs to command the system where to go, and the system does all the flying for the operator. The AL-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply cli cking on a map to create a pre-planned flight path for a flight. In addition, the o perator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. Th e petitioner states further that the UAS has built-in intelligent fault handling which a llows the AL-UAS to detect a system fault while in the a ir and automatically fly

back to its takeoff location and land. Faults that can be detec ted include: loss of communication; exceeding pre-set wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) contr olled, making the system easy to navigate. At any point if the operator is not explicitly commanding the system t o move, the system automatically holds its GPS position. The flight control system employs not only GPS positi oning but a variety of sensors including sonar, barometric pressure, temperature , wind speed and others to ensu re stability so long as wind thresholds are not exceeded. Also a flight termination link

– to prevent a 'fly away' or other potentially dangerous situati on

– is available to the operator."

7 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0 352 at pg. 13).U.S Department of Transportation September 1, 2015 Page 12

technology is necessary for the R-UASs because they will be ope rated at all times in VFR conditions and within VLOS of the PIC and Operator. 8

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Roto rcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Ronin Aerial Pho tography ’s small R-UASs would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's

airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. R. Part 21, Subpart H, supra

.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking a nd Identification Requirements

RAP seeks an exemption from the aircraft marking and identific ation requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless t hat aircraft is identified in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the re gistration number is displayed on limited, restricted or light-sport categ ory aircraft or experimental or provisionally certificated aircraft, the ope rator 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," "light-sport, "experimental, " or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft h orizontally on both surfaces of the cabin, fuselage, boom, or tail the mark s required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemp tion from these requirements was warranted provided that the aircraft "have identification ( N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." 9

Equivalent Level of Safety

8 Id

9 FAA Docket No. FAA-2014-0352.U.S Department of Transportation September 1, 2015 Page 13

All R-UAS s flown by RAP will bear N-number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 10

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.4 17(a) and (b): Maintenance Inspections

RAP seeks an exemption from the maintenance inspection require ments contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). The se regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft " [s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed because Part 43 and these sections only apply to airc raft with an airworthiness certificate, which the UAS platforms to be operated under th is grant of exemption will not have .( Emphasis added)

Equivalent Level of Safety

An equivalent level of safety will be achieved or exceeded beca use maintenance and inspections will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Ronin Aerial Photography ’s Operations Manuals, the PIC will conduct a pre-flight inspectio n of the R-UASs and all associated equipment to account for all discrepancies and/or in operable components. Maintenance will be performed and verified to address any condi tions potentially affecting safe operation of the R-UASs and no flights will occur unless, and u ntil, all flight critical components of the R-UASs have been found to be airworthy and in a conditio n safe for operation. A functional test flight will be conducted following the replacem ent of any flight-critical components. As required by Ronin Aerial Photography ’s Operations Manuals, the PIC who conducts the functional test flight will make an entry in the R -UAS aircraft records of the flight.

Ronin Aerial Photography ’s Operations Manual also includes requirements to follow the manufacturer’s UAS aircraft/component, maintena nce, overhaul, replacement, inspection, and life limit requirements for the following applicable components : powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/e levons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Ronin Aerial Photography ’s Operations Manuals also include procedures to document and maintain a record of the R-U AS ’s maintenance, preventative maintenance, alterations, status of replacement /overhaul compo nent parts, and the total time in service of the R-UASs used under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in Ronin Aerial Photography ’s Operations Manuals ensure that an equivalent or higher level of safety will be achieved.

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

10See, e.g., FAA Docket No. FAA-2014-0352, at 14.U.S Department of Transportation September 1, 2015 Page 14

RAP seeks exemption from 14 CFR § 61.113, which restricts priva te pilot certificate holders from flying aircraft for compensation or hire, and would also r equire a second class medical certificate. The purpose of Part 61 i s to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as req uiring certifications if the private pilot is carrying passengers or cargo for hire. In this case, w hile the R-UASs will be operated as part of a commercial operation, they carry neither passengers n or cargo. In the Grant of Exemption to Astraeus Aerial, the FAA determined that the uniqu e characteristics of UAS operation outside of controlled airspace did not warrant the ad ditional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Cer tificate and Class II Medical

Certificate. 11 The fulfillment of the additional requirements for a private p ilot to become qualified as a commercial pilot would not lead to any additiona l safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions RAP has placed on its R-UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial. RAP will operate on priva te property away from persons and property not involved in the operation. RAP will also obta in an ATO issued COA prior to conducting any operations under this Grant of Exemption. All op erations will be conducted in accordance with airspace requirements in the ATO issued COA inc luding class of airspace, altitude level and potential transponder requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, RAP will further ensu re safe operation by requiring that any PIC be thoroughly versed not only in airspace and communica tion issues pertaining to all aircraft operators but also in the unique aspects of R-UAS flig ht. As set forth in the Operations Manuals, pilots will have experience not only in R-UAS operatio ns generally but have logged flight time in the specific make and model used for the operati ons before they are permitted to participate in commercial flights on behalf of Ronin Aerial Pho tography. The pilot qualification, training, and currency requirements in the Operations Manuals e nsure that RAP pilots are competent and proficient in the R -UASs they are operating. Roni n Aerial Photography ’s training and qualification requirements are consistent with those contai ned in prior FAA Section 333 Grants of Exemption, and will provide a higher level of compete ncy and proficiency for its pilots and will ensure at least an equivalent level of safety to the p ublic.

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued f or the UASs, RAP seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is require d for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found ina pplicable. 12

11 Exemption No. 11062 (FAA Do cket No. FAA-2014-0352).

12 See Id. at 13-14, 22.U.S Department of Transportation September 1, 2015 Page 15

Accordingly, Petitioner requests that the requirements for § 91 .7(a) be treated in accordance with Section V(A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Air craft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require th e operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Purs uant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft

–

... (2) For which an Airplane or Rotorcraft Flight Manual is requir ed by § 21.5 of this chapter, unless there is available in the aircraft a current ap proved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards , or any combination

thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civ il aircraft unless it has within it the following:

(1) An appro priate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthi ness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legibl e to passengers or crew.

Given the small size and configuration of the R-UAS, it would b e impossible to keep

airworthiness documents and other aircraft manuals on board the R-UAS because there is simply no room and the R-UAS has no cabin or cockpit. As a way to com ply with the code RAP will

maintain the documents with the PIC and make them available for inspection.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 201 4, and prepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledged that the inten t of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 13 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has ac cess to these key documents during flight. Therefore, an equivalent level of safety will be achiev ed by ensuring that the pilot has access to the documents at the ground control station from whic h he or she is piloting the UAS.

13 Memorandum from Mark Bury, FAA Assistant Chief Counsel for Int ernational Law, Legislation and Regulation, to John Duncan, FAA Flight Stand ards Service (Aug. 8, 2014); se e also Docket No. FAA-2014-0352 at 16-18.U.S Department of Transportation September 1, 2015 Page 16

H. 14 C.F.R. § 91.103: Preflight Action

RAP seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each fl ight, including information contained in the FAA-approved Flight Manual on board the aircraft. While the PIC will be fami liar with all information necessary to safely conduct the flight, an exemption is request ed to the extent that an FAAapproved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Ronin Aerial Photography ’s Operations Manuals and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or inoperable components in ac cordance with the Ronin Aerial Photography ’s Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to re view weather, flight requirements, battery charge, landing and takeoff distance, UA performance da ta, and contingency landing

areas

— before initiation of flight. Ronin Aerial Photography ’s Operations Manuals and the Manufacturer's Manual will be kept at the ground control statio n and will be accessible to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

RAP seeks an exemption from 14 C.F.R. § 91.109(a), which provid es in pertinent part that "[n]o person may operate a civil aircraft (except a manned free ballo on) that is being used for flight instruction unless that aircraft has fully functioning dual con trols." UASs and remotely piloted aircraft, by their design, do not have functional dual controls . Instead, flight control is accomplished through the use of a device that communicates with the aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that RAP intends to use, a n equivalent level of safe training can still be performed without dual controls because n o pilot or passengers are aboard the UAS, and as required by the Ronin Aerial Photography ’s Operations Manuals, all persons will be a safe distance away in the event that the UAS experien ces any difficulties during flight instruction. Moreover, as requi red by the Ronin Aerial Photogra phy ’s Operations Manuals, all flight training will be conducted i n controlled and sterile env ironment. As a whole, the safety procedures provided for in Ronin Aerial Photography ’s Operations Manuals ensure that the proposed UAS operations provide an equivalent or higher level o f safety than that provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe AltitudesU.S Department of Transportation September 1, 2015 Page 17

RAP requests an exemption from the minimum safe altitude requir ements of 14 C.F.R. § 91.119(c). 14 Section 91.119 prescribes the minimum safe altitudes under w hich aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Se ction 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "e ach person operating the helicopter complies with any routes or altitudes specifically prescribed f or helicopters by the FAA."

An exemption is required becau se the proposed R-UAS operation w ill normally need to occur

below 400 feet AGL. In circumstances where the R-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the R-UAS will not be operated mor e than 100 feet above the highest point on the structure , and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or Observe rs(s) may need to be less than 500 feet away from the R-UAS.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel with the abo ve noted UASs, any risk associated with these operations is fa r less than those which present ly exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the R-UASs, as well as the controlled location where the operations will oc cur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 fe et AGL or below, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations M anuals, the R-UAS will be opera ted in a restricted area, and all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person is in a position where he or she is shielded from the R-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet of the R-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timely has granted permission and the PIC has made a safety assessment of the risk of operati ng closer to those objects and , operations near the PIC or Observer will not present an undue hazard per § 91.119(a). Adh erence to these restrictions in Ronin Aerial Photography ’s Operations Manuals will ensure operations can be conducted without compromising public safety. 15

14 Relief from § 91.119(a) will not be necessary because Petitione r will be able to perform an emergency landing without undue hazard to persons or property on the ground in th e event of a failure. P etitioner's proposed UAS operations will not occur over cong ested areas, and therefore a n exemption from § 91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slugwear, Inc., dba L ike on a tree Aerial (FAA-2014-0534 at 15).

15 See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA- 2014-0481 at 19): "If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in t he event of an accident, then the UA may operate closer than 500 feet to persons afforded suc h protection. The operator must also ensure that nonparticipating persons remain under such protection. If a sit uation arises where nonparticipating persons leave such protection and are within 500 f eet of the UA, flight opera tions must cease immediat ely. When considering how to immediately cease operations, the primary concern is the saf ety of those nonparticipating persons. In addition, theU.S Department of Transportation September 1, 2015 Page 18

K. 14 C.F.R. § 91.121: Altimeter Settings

RAP seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to a n altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption i s required to the extent that the

UASs do not have a barometric altim eter, but rather a GPS altit ude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the re quirements of 14 C.F.R. §91.121 can be achieved in circumstances where: (1) the UASs will be op erated below 400 feet AGL or

below 16 , (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based on-scr een display and, (4) where pri or to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS. 17

The R-UASs that RAP intends to us e for the proposed operations will meet all these operational characteristics. Moreover, as re quired by Ronin Aerial Photogra phy ’s Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass pr ior to each flight operation. Like prior FAA Section 333 Grants of Exemption, the R-UASs RAP inten ds to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level of safety or greater level will be achieved, and a Grant of Exe mption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Cond itions

RAP requests an exemption from 14 C.F.R. § 91.151(a)'s fuel req uirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR condi tions unless (considering wind and forecast weather conditions) there is enough fuel to f ly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day, to fly after t hat for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30-minute battery reserve. An exemption

FAA finds that operations may be conducted closer than 500 feetto vessels, vehicles and structures when the owner/controller of any such vessels, vehicles or structures grant s permission for the operation and the PIC makes a safety assessment of the risk of operating closer to those objects and determines that it does not present an undue hazard."

16 If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure.

17 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0 352 at 21).U.S Department of Transportation September 1, 2015 Page 19

from the fuel requirements of 14 C.F.R. § 91.151(a) is therefor e required. Moreover, it is not Ronin Aerial Photography ’s intention to fly the R-UAS at night.

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FA A determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a R-UAS flight unless (co nsidering wind and forecast weather conditions) there was enough power to fly to the first intended point of landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the R -UAS provide approximately 50 minutes of powered flight (with payload) and provided battery l evel and battery time remaining

in minutes and seconds to the PIC. 18 The FAA also considered the fact the R-UAS operating

manu al states: “start every flight with a fully charge d battery in the aerial vehicle”, and that in the event that the R-UAS should run low on power, the PIC will be alerted and can safely land the- R-UAS as soon as possible. Like the VDOS Grant of Exemptio n, Ronin Aerial Photography ’s use of the R-UAS, combined with the requirements of Petitioner 's Operations Manuals, ensure that an equivalent level of safety can be achie ved and in fact exceeded.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined that an equivalent level of safety to the fuel requi rements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a fligh t with the UA unless (considering wind and forecast weather conditions), there was e nough power to safely fly at normal cruising speed to the in tended landing point and land th e UA with 25% battery power remaining. RAP will adhere t o this limitation for its R-UAS fl ights.

The R-UAS includes a low batte ry warning system and the amount of battery reserve power remaining is continuously trans mitted to the PIC via telemetric data feed, which downlinks from the R-UAS to a ground-based-on-screen display. 19 As required by Ronin Aerial Photography ’s Operations Manuals, the PIC will promptly fly the R-UAS back to the home launch location or pre-determined abort location where it may safely land, while s till maintaining a minimum of 25% reserve battery power. RAP subm its that the procedures requ iring flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that flights only be conducted within a secure, isolated area, using a UAS w eighing less than 55 pounds, and within VLOS of the PIC and Observer(s), ensure that the propose d operation will provide an equivalent or higher level of safety to the public to that prov ided by the regulations from which exemption is sought.

VI. DRUG AND ALCOHOL PROGRAM

18. Grant of Exemption No. 11112 t o VDOS Global, LLC (FAA-2014- 0382 at 10).

19. The R-UAS ground control sta tion displays, the UASs positio n, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculated target p osition, date/time, and sensor heading and orientation

relative to the UAS.U.S Department of Transportation September 1, 2015 Page 20

RAP will have policies in place to ensure that no person may pa rticipate in R-UAS flight operations if they are under the influence of alcohol or any dr ug.

VII. PUBLIC INTEREST

The public interest will be served by granting Ronin Aerial Pho tography ’s Petition for Exemption. Congress has establishe d a national policy that favo rs early integration of UAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' go al in passing Section 333(a) through (c) of the Reform Act

— the FAA Administrator's assessment of whether certain UAS may operate safely in the NAS before completion of the statutor ily required rulemaking.

The proposed R-UAS operations in this Petition for Exemption si gnificantly improves the safety and reduces risk of harm, physical injury and property damage t o the public at large, the property owners from whom permission was granted for use by Petitioner a nd abutting properties, staff of Petitioner, unsuspecting passersby, inspecting engineers from r elevant organizations and all those who may be in the local vicinity. Traditional methods of inspec ting and monitoring potential locations and relevant sites and facilities requires location p ersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, pe rform elevated work for which the individual is neither trained nor equipped to perform, whi ch exposes them to unnecessary risk of serious physical injury from dangerous falls or other p hysical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposed to hazardo us conditions, unsafe environments, culturally tense situations and other hazards ass ociated with identifying specific locations for potential recording sites to be used in the end p roduct. The use of small UASs can eliminate these hazards and ultimately create a much safer meth od of performing these types of inspections creating a safer environment for the public as well as RAP employees.

The use of small UAS also enhances safety and reduces risk to t he surrounding public because, unlike manned aircraft weighing thousands of pounds, carrying c rew in addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furt hermore, in the unlikely event of an accident, Ronin Aerial Photography ’s small battery powered R-UAS presents significantly less danger to persons on the ground when compared to operation s by conventional manned

aircraft. 20 As Petitioner's R-UAS are batter y powered, the public will als o benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing in the same functions proposed herein. Air quality will natura lly be improved with the reduction of fuel powered vehicles.

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UAS provide an additional economic tool for the aerial filming notw ithstanding the industry, adding a greater degree of flexibility, which supplements the current ca pabilities offered by manned

20 See Grant of Exemption No. 11158 t o Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can w eigh 6,000 pounds or more and are operated by an onboard pilot, in a ddition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or p roperty in the event of an incident or accident. risk to an onboard pilot and cre w during an incident or acciden t is eliminated with the use of a UA for the aerial filming operation."U.S Department of Transportation September 1, 2015 Page 21

aircraft. 21 The quality of the finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide addi tional jobs as the cost of providing the needed product is gr eatly reduced while reducing the difficulty with which the finished product is created. The demand for the current indust rial product is increasing and will continue to increase given the enhanced flexibility of producti on; therefore, given the lower cost, owner/operators and others in the relevant industry will be mor e inclined to utilize the services of commercial UAS along with an appropriate licensed PIC’s

.

VIII. PRIVACY

All R-UAS operations will be conducted in accordance with appli cable federal, state, and local laws regarding privacy. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or auth orized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be

conducted.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provide d for publication in the FEDERAL REGISTER, should it be determined that publication is n eeded: Petitioner seeks an exemption from the following rules in Title 14 of the Code of F ederal Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a ); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & ( b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the aircr aft crew, production crew, general public, property owners and city structures from the substantia l hazards associated with performing equivalent film work and aerial video production wit h conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

Ronin Aerial Photography ’s Petition for Exemption satisfies the criteria articulated in S ection 333 of the Reform Act of 2012 which includes weight; speed; ope rating capabilities; proximity to airports and populated areas; operation within VLOS and nationa l security. The proposed R-UAS operations will benefit the public as a whole by improving safe ty and reducing risk by alleviating human exposure to danger while lowering the attendant related c osts thereby increasing the demand for the finished product. In consideration of the forego ing, this Petition for Exemption provides the FAA with more than adequate justification for gran ting the requested exemptions allowing RAP to use small R- UAS s in the recorded production of its product.

21 See e.g., Grant of Exemption N o. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).