Aerial Anthropology LLC



### REQUEST FOR EXEMPTION

Aerial Anthropology LLC Thomas Davis, Owner

4702 Grace Rd. North Olmsted, OH 44070

ENTITY ID: 2390423

TABLE OF CONTENTS:

1. Request for Exemption

– purpose and operations of Aerial Anthropology

2. Exemption Details

3. Appendix A

– Inspire1 Safety and Flight Details

4. Appendix B

– Inspire1 Specifications

5. Appendix C

– Phantom1 Safety and Flight Details

6. Appendix D

– Phantom1 Specifications

7. Appendix E

– Aerial Anthropology General Safety Standards

8. Appendix F

– Aerial Anthropology LLC

– Certificate of Approval

– State of Ohio

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2);

14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Aerial Anthropology LLC, operator of Small Unmanned ai rcraft Systems (“ UAS”), applies for an exemption from the listed Federal Aviation Regulations to all ow commercial operatio n of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as my be established by the FAA as required by

Section 333.

Aerial Anthropology will use UAS to capture aerial videography and photography. Aerial Anthropology will not poses any risk to national security interests in any way and will be dedicated to promoting the safe operation and flight of UAS within the National Airspace. Aerial Anthropology LLC intends to use aerial videography and photography to produce high quality media that can serve as a tool to aid in the study of human culture and provide historical reference for future generations. In addition, Aerial Anthropology will use aerial videography and photography to provide high quality media used in marketing efforts for several industries including, but not limited to businesses, municipalities, cities, states, parks, non

- profit organizations , and academia.

The Commercial operation of UAS equipped with photography equipment, as described herein , would operate in the following manner:

1. Aerial videography for public and/or private use including but not limited to marketing, insurance, agriculture, architecture, historical reference, video services, real estate, golf courses, land surveyi ng, events, and other r elated professional activities. 2. Aerial photography for public and/or private use including but not limited to marketing, insurance, agriculture, architecture, historical reference, video services, real estate, golf courses, land s urveying, events, and other related professional activities.

3. Aerial photography for public and/or private use including but not limited to television, public events, and other cinematography projects. 4. Aerial videography for public and/or private use including but not limited to television, public events, and other cinematography projects.

5 . Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.Aerial Anthropology LLC

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. Provide safety training and education to hobbyists, photographers, and organizations that will be operating UAS. Our intention is to spread awareness and ensure safety and best practices by placing education at the forefront of this industry. 7. Provide consulting on the best pra ctices around the purchase, use, flight, safety, and maintenance of UAS

As described in the pages below , the requested exemption would permit the operation of UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermin ed and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

R egulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a)

14 CFR 91. 7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

The UAS are multi

- rotor craft weighing no more than 55lbs. including payload. Under normal conditions they operate at speeds of no more than 50kts and have the ability hover and move along a vertical and horizontal plane simultaneously. They will operate in li ne of sight (VLOS) and will operate within the rules of the NAS and in only areas deemed safe for flight.

Based on the equipment that will be used and the safety procedure in place our proposed operations will completely adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissio ns and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observe r. 3. Maximum flight time for each operational flight will be less than 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. 4. Flights will be operated at an altitude of no more than 40 0 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may also involve

a Camera Operator in certa in situations, but will not be required in addition to the PIC and the VO

.Aerial Anthropology LLC

6. The UAS pilot will be a de signated Pilot in Command (PIC) . If the PIC feels another operator to be qualified with

the necessa ry skills to be PIC & possess a valid state driver’s license, that person may be designated PIC p rovided they have a minimum of 4 0 hours of flight time with the UAS. 7. A briefing will be p erformed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activi ties. 8. The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 9. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

10. The PIC and VO will hav e been trained in operation of UAS and will maintain current knowledge of UAS.

11. The PIC and VO will be able to clearly communicate by voice, radio, and/or text at all times. 12. Written and/or verbal permissi on and permits will be obtained, when necessary, from territorial, state, county or city jurisdictions, including la w enforcement, fire or other appropriate governmental agencies.

13. If the UAS loses communications or loses GPS signal, the UAS will have the capability to return to a pre

determined location within a designated location and land autonomously.

14. The U AS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the p rocedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthin ess certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and pop ulated areas of the particular UAS. In all cases, an analysis of these criteria

demonstrates that the UAS operated without an airworthi ness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating

with an airworthiness certificate without the restrictions and condition s proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike

other ci vil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates tha t there is no credible threat to nationa l security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experiment al," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f ) where the pilot, observer and oth ers working with the UAS will see the identification of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carryingAerial Anthropology LLC

passengers or property for compensation or hire. Our UAS do not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Al though helpful, a pilot’s license will not ensure remote control piloting skills. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equat e to the safe operation of the UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be

no airworthin ess certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, o r any combination thereof. The UAS, given its size and configuratio n has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keepi ng the flight manual at the ground control po int where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the sa fety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and

aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fu lly functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control

box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers wil l be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less th an the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at alti tudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth her ein, the UAS will never operate at higher than 400 AGL with the exception t hat in circu mstances where the UAS is used to survey or photograph a structure whose he ight exceeds 400 feet AGL, the UAS will not be operated more than 100' above the highest point on the structure. It will however be operated in a restricted area with security perim eter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size , weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to fligh t operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the

low

- altitude operations of the UAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.Aerial Anthropology LLC

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting avail able before departure.”

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruis ing speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve require ment in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length . Given the

limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in d aylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only people and property owners or offici al representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sma ll UAS. Additionally, limiting

UA S flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery

power

— whichever happens first. This restriction would be mo re than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinen t part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness 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 legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and i s operated without an onboard pilot. As such, there is no ability or place to carry certification and registration docum ents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control po i nt where the pilot flying the UAS will have immediate access to them, to the ext ent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operat or or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” a nd others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods

of t ime. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet

AGL. The operator will ensure that the U AS is in working order prior to initiating flight, perform required maintenance, and keep a log of any m aintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be pe rformed in accordance

with the UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating fl ight and perform required

maintenance needed.