U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve. SE Washington DC 20590 Re; Exemption Request Section 333 ofthe FAA ReformActivities Dear Sir/Madam, Pursuant to Section 333 ofthe Modernization and Reform Act of2012 (the ReformAct), and 14 C.F.RPart II, Starfruit Productions, a Floridalimited liability company operating Small UnmannedAircraft Systems (sUAS) equipped to conduct areal photography and survey for various industries, hereby applies for exemption from the FederalAviation Regulations (FARs) listed below to allow operation ofour sUAS commercially in airspace regulated by the Federal AviationAdministration (FAA) so long as such operations are conducted with and underthe conditions outlined herein or as may be established by the FAAas required by Section 333. The requested exemption is similarto previous FAA issued grants ofexemption including but not limited to ExemptionNos 11602, 11109, 11112, 11213, 11295. Our commercial activities would include: The requested exemptionwould permit Starfruit Productions LLC to pursue its commercial interests in providing services to consumers interested in training, research, and areal data capture using a small advanced sUAS inthe following areas:



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• Aerial photography andVideography for the wedding, real estate, construction and utilities industries Agricultural Surveying and Application sUAS OperatorTraining Product Demonstrations Research and Development All Starfruit Production sUAS flights will occur overprivate or controlled access property. Will do so with the owner's prior consent and knowledge. Onlypeople who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured in any photos or videos. Additionally, all Starfruit Productions pilots will hold an airline transport, commercial, private, recreational, or sport pilot certificate and also hold a current FAA airman certificate or a valid U. S. Driver's license issued by a state, the District ofColumbia, Puerto Rico, a possession, or the Federal government. Ifan observer is not a qualified pilotthey will be trained by Starfruit Productions pilots to understand the proper roles, ofan observer, communicationprocedures, proper visual scan techniques, operations at non-towered airports, and appropriate sections of the Aeronautical Information Manual. The petitionerRequests ReliefFrom the following regulations:Regulations from whichthe exemption is requested: 14 CFR 61.23(a) and (c), 61.10l(e)(4) and (5),61.113(a)(l) ans (2), and 91.7(a), 91.109, 91.119(c), 91.121, 91.15l(a)(l), 91.215, 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), to the extent necessary to allow Starfruit Productions to operate a sUAS to perform training, research, and areal data collection. We are petitioning for exemptionto enable Starfruit Productions to operate a series ofUAS platforms that have beenpreviously approved by exemption. Namely: DJI Phantom2 DJI Phantom Vision DJI Phantom Vision+ DJI Inspire DJI SlOOO DJI S900 DJI Flamewheel 550 eBeeAG 3DRobotics IRIS+ RF-70 DJI Phantom 3 Professional DJI Phantom 3Advanced Exemption 11398 Exemption 11310 Exemption 11398 Exemption 11398 Exemption 11416 Exemption 11401 Exemption 11397 Exemption 11339 Exemption 11419 Exemption 11295 Similar to Exemption 11310 Similarto Exemption 11398 These sUAS all weigh less than 55 pounds, have a built incapability to limit the height flown above the ground, to limitthe radius ofthe distance from the operator andto exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has a failsafe function ofthe autopilot system, which when communicationbetweenthe Main Controller and the transmitter is lost, the system will automatically trigger return to home and will land safely. This submission does not include the operating manuals for eachmodel requested above. As they have beenreviewed by theAdministrator in grantingprevious exemptions. Copies ofall Operating Manuals will be provided onrequest. It should be noted thatwhile the FAAhas not granted an exemption for the Phantom 3 series, it is an upgraded version ofthe Phantom 2 including components ofthe DJI Inspire 1. The above specifications meet standards listed below:



### • Starfruit Productions will only operate its sUAS in line ofsight ofa pilot and/or an observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the operators manual. Such operations will ensure that the sUAS will "not create a hazard to users ofthe national airspace system orthe

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• public. Starfruit Productions will not operate an sUAS within 5 nautial miles ofan airport reference point (ARP) as denoted inthe current FAAAirport/Facility Directory (AFD) unless a letter ofagreement with that airports management is obtained or otherwise permitted by a COAissued to Starfruit Production. Maximum flight time for any flight will be 60 minutes

. Flights will be terminated at 20% battery powerreserve should that occurbefore the 60 minute limit. The sUAS will be programmed to set a maximum altitude of400AGL. Minimum crew will be for each operation will be the sUAS pilot who will keep the sUAS in visual line ofsite at all times. The sUAS pilot PIC's (Pilot In Command) will hold anAirline Transport, Commercial, private, recreational, or sportpilot certificate and also hold a current FAA airman medical certificate or a valid U.S. drivers license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The sUAS operated bythe petitioner weighs less than 55 pounds includingthe payload (i.e. camera, gimbal, and lens). The sUAS will operate at speeds ofno more than 55 knots

. Given the small size ofour sUAS and the restricted sterile environment which they will operate, out sUAS operations adhere to the ReformAct's safety requirements. Additionally, the fact that the Starfruit Productions pilots hold FAA Pilot certificates demonstrates theyhave the highest regard for safe operations with an understanding ofFAR's pre-flight inspections, maintenance requirements and repairs, operations withinregulated airspace as well as highlytrained to high safety standards. Underthe requested exemption Starfruit Productions will ensure all operators have completed a small unmanned aircraft systems (UAS) education and training program including all applicable regulations and guidance documents. Including aeronautical background information such as Charts, NOTAMS,Aircraft Circulars; Radio Communication Procedures; Human Factors and CrewResource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and DecisionMaking; and Safe Operating Procedures.We respectfully request exemption under section 333 to enable StarFruit Productions to operate safe, lowrisk commercial sUAS operations for the activities stated. RFS at all times will respectthe space and privacy ofcitizens and property whilst keeping our skies safe. Exemption Requests and Equivalent Level ofSafety Starfruit Productions requests an exemption for the following regulations as well as any additional regulations that may technically apply to the operation ofthe sUAS:14 CFR61.23 Medical Certificates The regulationprovides that a person requires a first or second class medical certificate to act as pilot in Command ofan aircraft for compensation orhire. Ourproposed operations require thatthe PIV must hold a current FAA airmanmedical certificate or a valid U.S. drivers license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal Government. Since the aircraft cannot carrypassengers orproperty, we feel we meetthe intent of61.23 even though the intent ofthis application is to conduct business. 14 CFR61.101, 14 CFR 61.113, and CFR61.315 Pilot privileges and Limitations The regulationholds that no personthat holds a Recreational Pilot, Sport Pilot or Private Pilot certificate may act as pilot in command ofan aircraft for compensation or hire. Ourproposed operations require that the PIC musthold at least airline transport, commercial, private, recreational or sport pilot certificate. Since the aircraft cannot carry passengers orproperty we feel we meetthe intent of61.113 Subparagraph (b) even thoughthe intent ofthe application is to conduct business. 14 CFR 91.7 CivilAircraftAirworthiness This sectionprohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 CFR 91,109 Flight Instruction; Simulated instrument flight and certain flight tests. The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." During training we have the ability to provide dual controls utilizing two transmitters with a wireless link betweenthe transmitters. One transmitterwill be designated the mastertransmitter and the othertransmitter is designated the slave. The PIC instructor, utilizing the master transmitter, will at all time be able to assume control ofthe sUAS. 14 CFR 91.119 Minimum SafeAltitudes: General The regulation states that over sparsely populated areas the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle,s or structures. Since the typical mission ofthe sUAS would be photography or survey ofpersons, vessels, vehicles, or structures it would be necessary to operate closer than 5oofeetto the items listed. Operations will only be be flown over property or persons where permission has been obtained and careful pre-planning has been accomplished. The aircraft will be operated at a low altitude allowing, ifpowerfailure, an emergency landing without undue hazard to persons, orproperty on the surface. Therefore we maintainthat due to the small size ofthe sUAS the hazard to persons, vehicles, and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. 14 CFR91.121 Altimeter Settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within lOONM ofthe aircraft. The sUAS will fly below 400 feet AGLand will not need to maintain cruising altitudes inorderto prevent conflict with otheraircraft. AnAbove Ground Level altimetermeasurement above the takeoffpoint is transmitted via radio from the sUAS on board computerto the display screen held by the PIV, providing a constantly updatedAGLreadout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions The regulationprovides that no person may begin flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after that for atleast 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and maximum flight duration from a single battery charge is 15-45 minutes (depending onthe sUAS) minutes with a 20% reserve. Since the aircraftwill never fly more than Y, NM from the point ofintended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and askthat ourreserve will be to fly the missionto the point ofintended landing and have a minimum reserve of20% afterthat. 14 CFR91.215ATC transponder and altitude reporting equipment and use This regulation states all aircraft operating within 30 NM ofclassA, B and C airspace must be equipped with automatic pressure altitude reporting equipment having mode C interrogations. Dueto the small size and lifting capabilities ofour sUAS we cannot carry a traditional transponder. All our operations will bebelow400" when within 30NM. 14 CFR Subpart E (91.401-91.417)- Maintenance, Preventive Maintenance,Alterations The regulation provides the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance withpart 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Itis our intentionthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in airworthy condition priorto every flight and in addition, conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks replacing propellers, checking electrical connections and updating software and firmware ofthe on-board computer. All maintenance will be performed by the manufacturer ortheir designated repair facility. The PIC will document workperformed in accordance with 91.417. We feel due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. How this Request is to the betterment ofour Community The enhanced safety achievedbyreplacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew and operated underthe specific guidelines and procedures proposedbyPetitioner gives the FAAgood cause to find that the UAS operations enabled bythe instant Petition are in the public interest. Moreover, as the FAA has already recognized, "UAS provide an additional tool for the film making industry, adding a greater degree offlexibility, which supplements the current capabilities offered by traditional aircraft.Additionally, the unmanned aircraft cantake offan land from the property we have been contracted to image. The ability to avoid overflying private and public properties provides the public with the benefit ofincreased safety and privacy from overhead aircraft. Request for Blanket COAApproval On March 25, 2015 the FAA announced that it has implemented a new policy ofgranting "blanket" COAs to applicants requesting exemptions from the FederalAviation Regulations under Sections 333 ofthe FAA Modernization and ReformAct of2012. TheApplicant hereby requests that a "blanket" COAthat conforms to the terms set forth in https://www.faa.gov/news/updates/?newsld=82245 upon approval ofStarfruit Production's exemption request. Respectful!y,

Sage President Starfruit Productions, LLC 51St St W, Bradenton, Fl 34210 (941) 527-9522