(!) OJ CIJ 0..

c:: .8 c:: CIJ**~** 0 ::!:



# ii: lO lO

lO ..- a N 1..0 0 1 

## Chad Medford Video Production 1111Tiney Rd Ellenboro, NC 28040 828.429.5148 chadandmyra@gmail.com July 29, 2015 

### U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, D.C. 

### 20590 .':**~**

..

## ,

.,


# .. '·

._., I · .. ,'

RE: Exemption Request Section 333 ofthe FAA Reform Act ofthe Federal Aviation Regulationsfrom 

### 14 CFR 

### 91.7(a};91.119(c); 91.407(a)(1);9])iQ9{a)(1) and {2); 

### 91.417(a)&(b); C.F.R. 61.113(a(&(b); C.F.R. 

### 61.133 (a); C.F.R. 

### 91.405 (a).

. .**:·~** . To whom it may concern, · .· Enclosed please find an exemptic•r application filed on behalf of Chad Medford Video Production. (CMV) under Section 333 ofthe FAA Mociernization and Reform Act of2012 and 

### 14 C.F.R Part 11to allow commercial operations of unmanne-d aircraftfor aerial photography and videography for the real estate, construction, and utilities Industries for commercial .use, so long as such operations are conducted within and underthe conditions outlined lierein or as established by the FAA in an exemption granted under either Section 333 or Section It is the request ofthe petitionerfor exemptions listed above in orderto legally and safely operate the 

### DJI Phantom 3 Vision Plus UAS, DJI 5900 UAS and a 3D Robotics Solo in the National Airspace System. CEM is a leading production company in Western North Carolina with an extensive background in television production and videography. Ct:M proposes to use small, lightweight, UAVs and proprietary cloud-based software. 

### 2N Q) Ol m 0..

N I"- (,() N N**~** c .8 c m El 0 :L

l{) ..- a N (,() 0 As discussed beiOW1 CEMs operatk,ns underthe exemption 

### will be subjectto strict operating requirements and conditions to**e~sure** atleast an.**eq!~illaient** level ofsafetyto currently authorized operations using manned aircraft and underC<lndition.; as may be modified 

### by the FAA <lS required by Section 333. It is the petitioners position thatthe oper<1tions for which exemption is requested are safer and more cost effective than using man'ned aircraft and for those reasons are in the Public Interest; and would be of benefit in identifyingareas of operation that may need additional oversight as well as raising public awareness and interest in this rapidly browing facet of aviation. Because these small UASs will be used :n lieu ofcomparatively hazardous operations now conducted with fixed wing and rotary manned aircraft/ CEM respectfully submits thatthe FAA can have confidence that the operations will achieve at least an equivalent level or greater level ofsafety. Approval ofthis exemption would thereby enhance safety and**fulfil~ 333~c)**  ofthe Reform Act to "establish requirements for the safe operation ofsuch aircraft systems in the n<Hional airspace system." 

## Section 333's Legal Standard Grant ofthis exemptionapplication for use of the above named UAV's for purposes ofobtaining and recording video will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction of UASs into the national airspace ·system «'NAS") ifsuch integration can be accomplished safely. Thestatutory provision direc:tsthe Secretary ofTransportation to consider whether certain UASs may operate safely in the NAS**befor~** completion of the rulemaking required under Sections the Secretary ofTransportation to consider whetn:er certain UASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In doing S0 1 the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS or the public or pose a threatto national security in light ofthe following; 

### f!l The UAS's size/ weight speed1 and operational capability; 

### 3 '**~.** r/ t;
')I'

•. l'".,l';**~** 1 '•-
. 

## ... '•**~** -·(Y)
Q) OJ 

## "' o._

N r-- tD N N**~** c .8 c 

## "' El 0 :L:

l{) ..- 0 N tO 0 

## rn Operation ofthe UAS in close proximityto airports and populated areas; and Ill Operation ofthe UAS within visua! llne ofsight ofthe operator
Ifthe Secretary determines that**~..:d1 vr~hicles**  

### "may operate safely in the national airspace system, the Secretary shall establish requirer**:.~nt.s** 

### forthe safe operation ofsuch aircraft in the national airspace system. (333 emphasis added)

. The Federal Aviation Act expressly grants the FAA the- 1uthor.wto issue exemptions. This statutory, by its terms, includes exempting civil ain:;·aft, as the term iS:.defined under

### 40101oftheAct, from the requirement that 

### all civil aircraft rnu5-t

### have~**i!urr~nt** airworthiness certificate and those regulation requiring commercial pilots to operate aircraft in commercial service. Reform Act 333(a)(1) · Applicant submits thatthis provision places a duty on the Administratorto not only process applications for exemptions under Section 333, butfor the Administrator, ifhe deems the conditions proposed herein require modification in orderto allow

### ~pproval, to supply conditions forthe.safe operation ofthe l,IASs. CEM requests to consult with the FAA staffto address any issues or concerns"that they believe may require such modification. The Administrator may grant an exemption from··a.requirement ofa regulation prescribed under



# . '

.



### . subsection (a) or (b) ofthis section orany ofsections 

### "44702-44716 ofthis title ifthe Administrator finds the exemption is in the public interes-t. -,, · 

### 49 U.S.C 440701{f) See also 49 U.S.C44711(a);49

# u.s.c 44704; 14

### C.F.R 9-1.203{aJ(1). The grant ofthe requested exemption is in the public·interest given the clear direction in Section 333 of the Reform Act; the additional authority In the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit arising from the use of newtechnology to provide services that are not practical orsafe 4N 1"- l.O N N**~**

'+- 0

l.() 

### 0 N l.O 0 to provide using traditional aircran. Accord.ingly, the applicant respectfully requests that the FAA grant the 

### requested exemption 

### without deiay. 

## Aircraft and Equivalent ofLevel ofSafety The applicant proposes that

### the exemption requested herein applyto 

### civil aircraft that have the characteristics and that operate with the limitations and conditions listed herein. These limitations provide for 

### at least an equivalent or even higher level ofsafety to operations 

### under the current regulatory structure because the proposed operations represent a safety enhancement to operations thatwould be conducted with conventional aircraft. These conditions are drawn from Exemptions 

### 11062 through 

### 11067, 11080, 11109, 11110, 11136, 11138, 11150and 

### 11153. 

## Additional Issues Privacy- 

### All flights will occur over private or controlled access property with the property 

### owner's prior c:onsent 

### and knowledge. Operation>· 

### will be wherethe owners have agreed to all CEM's activities to take pface. 

### In addition, members ofthoi.·**1-i'~!:-e•al** public will 

### be alerted to the operation of 

### UASs at these locations.

. ., In filing this application, Chad Medford Video Production also requests that the 

### FAA combine the grant of the Section 333 exemption with a starid-alope**CeH;jfi!=~te** of.Operation ("COA'') that 

### will allow commercial operations of

### DJI Phantom 

### 3Vision 

### plusUAS, DJI**~.900-UAS** and a 3DRobotics Solo withoutfiling for 

### a COA for each flight. Compliance with the ccnditici1ns**ag~eed** ·hereil'and thatmay be imposed by the FAA, as set forth in prior Section 333 exemptions, provide the sepc.ration needed from other aircraft. Notice to airmen and notice to airtraffic control can be provided 

### by the 

### "filing

# of a NOT

### AM as set forth within the proposed conditions. 5lO
Q) OJ 

## "' o._

N r-- tO N N (Y) 

# ""'
c: .8 c: 

## "' El 0 ::!:

4- 0**~** 0

### ~ lO lfl
.....- .....- lO .....- 0 N tO 0 

# s ..., National Security Grant ofthis exemption 

### will not raise any**natic~··.<'lf** security concerns. Given the size, load carrying capacity, speed atwhich theyoperate and the fact. 

### that it carries no explosives or any other dangerous materials,

### the DJI Phantom 2 Vision Plus UAS, DJI 5900 UAS and 

### a 3D Robotics Solo pose no threat to national security. 

## Conclusion Satisfaction ofthe criteria provided in Section 

### 333 ofthe Reform Act of

### 2012- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight 

### and national security- provide more

### .than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicants UAVs for the purposes outlined herein and are consistentwith exemptions alreadygranted, including Exemptions 

### 11062 through 

### 11067, 11080, 11109 through 

### 11112, 11114, 11136, 11138, 11150 and 11153. Given that CEM is willing to abide by conditions the FAA has required in issuing recent Section 333 exemptions, the 

### FAA has 

### a strong basis for prompt consideration and grant ofthis request. Please contact CEM 

### ifthere are any other questions or concerns. Best regards, 

### Chad Medford owner



### .. t'\·_.-·

\

----------- -**~-~-----~-------**Q) 01 C'O Q_

c 

## .s c C'O**~** 0 :::!:

LO 

### 0 N (.0 0 

# Exemption Request and Equivalent levelofSafety Showings under Applicable Rules 

# Subject to, 

# Exemption CEM request an exemption from the following regulations as 

### well as any additional regulations that 

### may applyto the operationsofthe DJI Phantom 2 Vision Plus UAS, DJI 5900 UAS and a 3DRobotics Solo. 

## 14C.F.R. 61.113(a)(b);**61.133{a)~** 

## Private Pilot Privileges and limitations; Pilot in Command; Commercial Pilot**Pr~vileges** 

## and Limitations. Section 61.113(a)(b) limit private pilotsto non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers and cargo, the DJI Phantom 2 Vision Plus UAS, DJI S900 UAS and 3DRobotics Solo are remotely controlled with no passenger.s or property ofothers on board. Section 61.133(a) requires an individual with a commercial pilot's license to be the.pilot in command of any aircraft for hire and/or compensation. CEM proposes that operator requ!rements should take into account the characteristics ofthese particular UAS's. DJI Phantom 2 Vision Plus UAS, DJI 5900 UAS and the 3DRobotics Solo have navigation and control systems capable ofconducting pre-programmed missions. Flights are pre-programmed with precision GPS guidance 

### and, although monitored 

### by the PIC and Observer, do not require human intervention. The aircrafts also can operate in guided mode, where the aircraftwill flyto a location designated bythe operators. In the case ofan unplanned event, operators can manually intervene and take one ofthe following actions: Ill Commandthe aircraft to return and land attne recovery location
Ill Command the aircraftto conduct a return to the recovery area.where the pilot

### will assume control and land the aircraft ··· ., ·.,., ., · 111 Manuallyassume control ofthe aircraftvia the hand controllerand return the craftto the recovery area in which the operator land its manually 7



### '' ,J \
·'**~** 

## . .:

### ..

### ' I '. -·-

. , ..**~.** "-:
-Q) rn ro 0..

N 

### r- (.0 N N**~**

1.(') ..- 0 N (.0 0 

### Additionally, the automated safety functions and safety enhancing features include the following: Ill Auto-pilot detection of lost GPS initiates GPS failsafe mode, in which the aircraft switches to manual control in 

### an altitude hold mode.


## rn Low battery power on the aircran:**;~riggers** 

### the la,"ding sequence and then the craft will land at the current location


## rn Ifthe aircraft detects a lost-linktothe ground control station, itwill return to the launch site and land.
lZJ 

### Ifthe aircraft exceeds 

### an altitude of

### 40Dtl AGL**or.go~s** 

### more than 

### 2 

### km from 

### its launch point (except it it 

### is in GPS 

### failsafe mode), it will return to 

### the**la~mch** 

### point, automatically.
Given these safety features, 

### CEM purposes that operators ofthe 

### UAS's should not be required to hold 

### a commercial pilot certification. Instead, operators should be required to hold only a private pilot certification. The risks associated with the operatioP of DJI Phantom 

### 3 Vision Plus 

### UAS, DJI 

### S900 UAS and the 3DRobotics Solo are so diminished from the.level of risk associated with commercial operations contemplated by Part 61 with conventional aircraft that allowing operations of the UAS's as set forth above meets and/orexceeds the present leveJ.,-,f safety provided under 

### 14 C.F.R. 61.113(a)(b) and does not rise to the level of requiring a commercial 

### piiq,t i:o operate the aircraft under 61.133(a). Given these conditions and restrictions, an equivalem !•"i!e! ofsafety will be provided allowing operation ofthe DJI Phantom 3Vision Plus UAS, DJI 5900 UA3 and the 3DRobotics Solo with a private pilot's certificate, underthe conditions set forth in the exemption re, quest. The FAA has, granted exemptions to conduct similar operations in .Exemptions 

### 11062 through 

### 11067, 11080, 11109, 11110, 11136 and 11138. 8

.. :.. :"**:·~** c :-. :· ..:**·.;i_f::~** {.·;;·· :-:.·:co
OJ ITl ro o._

N r-- 1.0 N N**~**

lO .-- 0 N 1.0 0 

## 14C.F.R 91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes foroperation ofcivil aircraft. As setforth herein, 

### CEM will never operate at higherthan 400 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. No flight will be taken without the permission of the landowner, all affected individuals

# w.m be aware ofand 

### will have signed waives consenting tothe flights. 

### CEM will ensure thatthe aircraft will remain at least 500 feet away from non-participants unless they are protected from potential hazards by barriers orstructures. 

## 14C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an in.dividual fro·m beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

### flyto the first point of landing and, assuming normal cruising speed- (1) During the day, to flyafterthat forat least 30 minutes; or (2) At night, to fly after that for at least 

### 45 minutes." The batteries powering the OJI**P~,.:11'otom** 3 Vision Plus UAS, DJI S900 UAS and the 3DRobotics Solo provide approximately 15 minutes of**po~:;.:red** night. Witilout an exemption from 14C.F.R. 91.151, the UAS's flights would not be permitted.**Bfcau~c,** ofthe limitations ofthe DJI Phantom 3 Vision Plus UAS, DJI S900 UAS and a 3DRobotics Solo, a

### long~!- timefr;jme fQ'"J\;-!,hl:c ;n oayilght VFR conditions is reasonable. 

### CEM would not initiate flight unless**(ccn_~idP,dng ~i:-<.1** **~nJ** forecast weather conditions) there is enough power to 

### fly at normal cruising speed to**-th~:** intendid Iariding point and land the UAS's with 25% battery power remaining. CEM believes that an exemption from 14 C.F.R. 

### 91.15l{a} is safe and within the scope of prior exemptions. See exemption 10673. Operating the UAS without 30 minutes of reserve fuel does not engender the type of risks that Sectioi'J91.151(a) was meantto prevent given the size and speed atwhich the UAS's operate. In the unlikely evem thatthe UAS's achieve a low battery 9 ;·

. 1

ol 1 :\.0) (LJ c:n cu 0...

c: .8 c: cu**~** 0 2:

L()



# -- 0 N (.0 0 status it would simply land. Given the UAS's "Y<::-ight and construction materials, the risks are less than contemplated bythe current regulation. Similar exemptions have been grantE!.d to other**op~;i?~NS,** including Exemptions 2689F, 

### 5745, 10808, 

### 10673 and Exemptions 

### 11062 through 

### 11067, 11080, 1110, 11112, 11109, 11138, 11136 and 

### 11150. 

### 14C.F.R. 91.405(a); 407(a)(1); 409{a)(2); 417(a)&(b}: Maintenance Inspections Section 91.405(a) requires that an airr;raft operator or owner "shall have thataircraft inspected as prescribed in subpart 

### Eofthis and shall between required inspections, expectas provided 

### in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43; Section 91.409{a}(2.) requires an annual inspection forthe issuance of an airworthiness certificate. Section 

### 91.417(a) requires the owner or operator

### to keep records showing certain maintenance work that has been accomplished bycertified mechanics, under Part

### 43, or licensed pilots and records ofapproval ofthe aircraft for return to service. Maintenance ofthe DJI Phantom 

### 3 Vision Plus UAS, DJI 

### 5900 UAS and 

### the 3DRobotics Solo will 

### be accomplished by the owner/operator pursuantto the manuals attached as confidential exhibits. 

### An equivalent level of safetywill be achieved 

## because UAS's are small and light will carry a small payload, will operate in restricted predetermined areas and is not a complex mechanical device. The operator will ensure that the UAS is in working order prior

# to initiatingflight, perform required maintenance, and keep 

### a log of any maintenance that is performed; moreover, the operator is the person mostfamiliar with the aircraft 

### and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. The FAA has granted-exemptions for similar operations in Exemptions 

### 11062 through 

### 11067, 11080, 11109, 11110, 

# nu:..
.. 11136 and 11138.10

,_**~,.**

.l "



## .'0

(!) OJ ctJ c..

c 

# .a c ctJ El 0 L:

1.0 ..- 0 N 1.0 0 

## Limitations and 

## Conditions The limitations and conditions for which Chad Medford Video Production agrees to be bound when conducting commercial operations under an- FAA issued exemption include: 1. Operations ofthe UA is limited to the aircraft described in the attached manuals which are miniature rotor aircraft. 2. The UA may not be flown at an indlc.;ted airspeed exceeding 50 knots. 3. The may be· operated an altitude of no mme than 400feet above the ground level. All altitudes reported toAirTraffic Control (ATC) must be in**ft::£;~** 

### AGI.
4. The UA must operate within**visu~i** 

### line ofsight (VLOS) of the pilot-in-command (PIC) at all time,s.
5. All operations must utilize a visual observer. The visual observer (VO) may be used to satisfy the VlOS requirements as long as the PIC always maintains VlOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or herdesignationforthe duration ofthe flight, The PIC must ensure thatthe 

### VO can perform the functions prescribed in the operator's manuals.,.

. 6. The manuals must be amended to include all conditions and limitations required by the FAA. The manuals must be maintained and made available to the administrator upon request. 7. The PIC must inspect the UA to ensure it is in a comlition forsafe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UA, the aircraft is prohibited from operating until the 

### ' necessary maintenance has been performed, and the UA is found to be in a condition for safe flight. All maintenance and alterations will be properly documented in the aircrafts records. 8. The PIC who conducts the functional test flight afterthe UAS has undergone maintenance or alterations that affectthe UAS's oper.ation, must make an entry in the UAS aircraft record. 

### 11



# ..

·1. .··'Q) OJ co 0..

c: .8 c: co El 0 E

U") 

### 0 N 1.0 0 9. The preflight inspection must**acco~nt** for all discrepancies not covered in the relevant preflight inspection sections ofthe**operator',~** manuals. 10. The operator mustfollow the :t:.w;dacturer's UA aircraft/component, maintenance, overhaul, replacement, inspection and life 

### :,mit**requir~ments,** with particular attentionto flight critical components that may not be addressed in the mandacturer's manuals.
11. The operator mustcarry out its**mai~1t~nai1Ce,** jnspections, and record keeping requirements in accordance with the manuals. 

### Ma?nt·mimce, ic"'Spt:ction and alterations must be noted in the aircraft records, including total flight hours,**d~cription** ofwork accomplished, and the signature ofthe authorized technician returning the

### UAS to service. 

### 12. The authorized technicians must receive and document training referenced in the manuals. 13. Each UAS operated underthe exem!Jtion must comply with all manufacturersystem and safety bulletins. 

### 14. Operator's maintenance personnel must 

### f-f;ake a record entry in the 

### UAS logbook orequivalent document ofthe corrective action taken

### againstl{i·i~aep~ncies discovered between inspections.· 

### 15. The PIC must possess at least a private pilot

### certificat~''and a third-class airman medical certificate. The PIC mustalso meetthe flight review requirements specified in 

### 14C.F.R. 61.56 as to the 

### UAS. 16. The operator may not permit and-PIC to operate**~nless** that PIC has demonstrated through Chad'straining and currency requirements thatthe

## PiC is able to safely operate the 

### UA in a manner consistent with how the UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
17. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within or controlled-access property and land or be recovered in accordance with the manuals. 

### 12



### ....

.. tn?!,.**~.** i:·1 -\

-

. U·N

QJ OJ m 0...

N 1"- U) N N**~** c 

## .s c m !!I 0 2::

l.() 

### 0 N U) 0 18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the manuals. 

### 19. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather condition) there is enough powerto at normal cruising speed to the intended landing point and land the UA with 25% batter power remaining. 20. The operator

### will file 

### a request for

### a Notice toAirmen (NOT AM) not more than 72 hours in advance, but not less than 48 hours priorto operation. 

### 21. All aircraft operated in**accordat·~.:e** with the exemption must 

### be identified 

### by serial number, registered 

### in accordance with 

### 14**'~-.FR.** 

### 9.art 47 and have identification (N-Number) markings in accordance with 

### 14 C.F.R. Part4'\ Su.bpart c:Markings must be as large as practicable. 

### 22. Before conducting operations, the radio frequency spectrum used for operation 

### and control 

### of the UA must comply with the Federal Communications**Cql.mn~ssion** 

### ("FCC") or other appropriate government oversight agency requirements. ·.'

. l · ' · , _: · ·:o- · ··.:..· 

### 23. The documents required under 

### 14 C:f.R. '91.9 and 

### 91.203 must be available to the 

### PIC at the ground control station ofthe UAS anytime the aircraft'ls operating. These documents must be made available to the Administrator or any lawenforcement official upon request.
24. The UA must remain clear and yield the right 

### ofwayto all other manned operations and activities at 

### all times (including, but not limited to, ':.Jtralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).
25. The UAS may not be operated by the PIC

## f~~·i;·J._:~y**~oving-device** or vehicle. 

### 26. UAS operations may not 

### be conducted during night,**o.~** defined 

### in 

### 14 C.F.R. l.l.AII operations must 

### be conducted undervis_ual meteorological conditionsr'VMC"). The UA 

### may not be operated less than 500 feet below or less than 2,000feet horizontallyfrom a cloud or when visibility is less than 3 statute miles from the PIC.
27. During operations in Class Gairspace, the UA may not operate within 5 nautical miles ofgeographic center of an airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the 

### 13

...,**~-~~~-----**Q) OJ cu o._

l() ..-- 0 N 1.0 0 operation is conducted in accordance with a NOT AM aJ !'!!quireo by the operator's COA. The letter of agreement with the airport management must be made

### a~ailable tothe Administrator upon request.
28. The UA may not be operated over congested or**~ensely** populated areas unless the conditions set forth in

### #31 are satisfied. These poputated areas

### include~ but are not limited 

### to, the yellow areas depicted on World Aeronautical Charts ("WAC'', Sectional Aeronautical Charts ("Sectionals"), orTerminal Area Charts ("TAC"}. However, it is the PIC's responsibilityto'maintain 

### safe altitudes required by 91.119. 29. Operations must be conducted at least 500 feet from all nonparticipating persons {persons otherthan the PIC orVO), vessels, vehicles and structures unless:
111 Barriers or structures are presentthat sufficiently protect nonparticipating persons from debris in the event ofan accident. The operator must ensure that nonparticipating persons remain undersuch protection. If nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately; and/or



## rn The aircraft is operated nearvessels, vehicles or structures where the land owner/controller has granted permission and the PIC has made 

### a safety assessment ofthe risk of operating closerto those object; 

### and**~Operations** nearthe PIC or

### VO

### ~?**~~~t** present an undo hazard to the PIC orVO, per 

### 91.119(a).**~** >**~ ~**  \ 30. All operations shall be conducted ove(private or controlled access propertywith permission from the land owner/controlleror authoriz,,:d

### re;Jr~s.entatiyewill be

### obt~fhed for each flight to be conducted. · 31. In the event

### COA's are require:t: 1**an~' incid.eh~,.**  <icddent orflight operation that transgresses the 

### lateral or vertical boundaries ofthe operdttonal 

### are.:-· as defined bythe applicable COA must 

### be reported to the FAA's UAS lntegration.Office ("AFS-80") withiri 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB") 

### per instructions contained on the NTSB website: www.ntsb.gov.

Thankyou foryourconsideration, Chad Medford**~-** J

....

,--**r---~ -----~** **--------~------** ---------