July 22 , 2015 U.S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 (a); 91.203 (a) & (b);

91.405 (a); 91.407

INTRODUCTION

Pursuant to Section 333 of the FAA Modernizations and Reform Act of 2012 and 14 CFR Part 11, Angel City Air, Inc. , operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for KNBC, KTLA , and various other

news outlets for the purpose of electronic ne ws gathering in Los Angeles, CA. Additional operations to include closed set aerial filming for movie and television operations, and data acquisition. Angel City Air Inc. hereby applies for an exe mption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of sUASs under the conditions outlined here or modified by the FAA. Angel City Air inc. submits supporting material in this application as confidential documents pursuant to 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and proprietary information

that Angel City Air Inc. has not and will not share with others

In the detailed explanation to follow, the series of exemptions being requested would allow ope ration of the commercially procured, DJI S1000, an eight engine and blade, light weight, relatively slow (<50 knots) unmanned rotary aircraft (or like platform), and an Intuitive Aerial Aerigon IAH3 an twelve engine and blade, light weight relatively slow (<50 knots) unmanned rotary aircraft (or like platform), in and around the city of Los Angeles during active news, traffic and weather events using very controlled conditions and operational procedures to provide robust safety buffers both vertically and

h orizontally to ensure personnel and property safety. These f lights would only fly within

200 feet of the control vehicle with a dismounted pilot and safety team using an auto

pilot system that would control speed, vectoring and hovering. At no time would t he vehicle fly directly over locally assembled c rowds or over any ongoing fires. The launch and recovery point would be cordoned off by the safety team in coordination with law enforcement and/or first response units. Approval of this exemption would help to prove the safe concept of UAS activity while conducting electronic news gather (ENG) during active news, weather or traffic events in a major metropolitan environment with safety controls to provide proactive risk management that is technically within t he National Airspace System, but realistically segregated well below any other air traffic and well clear of the Los Angeles International Class B airspace (beneath the lateral confines).To date, the FAA has granted an exemption for ENG operations to Arr ow Data, LLC

, Aerigon airframe approval to Vision Pictures LLC, and closed set filming approval to

Team 5 LLC

.

The following is contact information for the applicant:

Angel City Air, Inc

Patrick McKernan

12653 Osborne St. #6

Los Angeles, CA 91331

( 310)570

- 8477

EXMEPTIONS (Regulations from which exemption is requested)

• 14 CFR Part 21, Subpart H

- Airworthiness Certificates

• 14 CFR 45.23 (b),,

o Aircraft Marking

o Certification and Registration

• 14 CFR 61.113 (a) & (b)

o Pilot in Command

• 14 CFR 91.7 (a)

o Civil aircraft airworthiness

• 14 CFR 91.9 (b) (2)

o Document/Flight Manual

• 14 CFR 91.103 (b)

o Preflight Action

• 14 CFR 109

o Flight Instruction

• 14 CFR 91.113o Right

- of

- way rules

• 14 CFR 91.119

o Minimum safe altitude

• 14 CFR 91.121

o Altimeter setting

• 14 CFR 91.131 (a) (1) ( c) (2) (d) (1)

o Operations in class B airspace

• 14 CFR 91.151

o Fuel requirements for VFR flight

• 14 CFR 91.203 (a) & (b)

o Civil Aircraft: Certifications required

• 14 CFR 91.405 (a) (1); 409 (a); 417 (a) &(b)

o Maintenance and maintenance inspections

• 14 CFR 407

o Operation after Maintenance, preventative maintenance, rebuilding, and inspections

• 14 CFR 409

o Inspections

• 14 CFR 417

o Maintenance records

• NOTAM 9/5151, NOTAM 4/3621

o Flying around sporting events

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFETY

Section 333 refers to exemption s for sUASs for commercial operations. Those operations could include a vast array of events such as elect r onic news gatherin g (ENG). Much like the movie industry, aerial news and traffic/weather information gathering is both useful and entertaining to the general public. The quick deployment and less restrictive weather constraints will create a safer environment, while delivering a superior and timelierproduct to the general public, providing near real time information for traffic , severe weather and crime scene avoidance considerations.

The sUAS aircraft to be employed by Angel City Air, Inc. has a number of safety features

that make it ideal for use in this environment. The state of the art DJI S1000 with single

2 2 ,000 mAh, 22.2 volt battery technology and the ability to fly with two engines inoperable. The Intuitive A e rial Aerigon with a triple 16,000 mAh, 22.2 volt battery technology and the ability to fly with 4 engines inoperable. Both UAS are well under 55 pounds with a top speed of approximately 40 knots. Additionally, there is redundancy in the power system to the data link, motherboard, and wireless communications withi n the sUAS team operating the system. The mobile vehicle to be used with the UAS is already

fitted with r edundant power sources for satellite and camera operations and would be available to the UAS safety team as well. The aircraft would be employed utilizing

Visual Line

- of Sight ( V L OS) operations not to exceed 200 feet vertically and launched

from a sterile area created upon arrival at the news event by the safety team in coordination with local law enforcement and first responders. Any vertical obstructions would be noted upon arrival and the pilot and safety team would ensure operations

remained well clear of those obstructions. The pilot would launch the aircraft and navigate to an acceptably safe hover point at which time a waypoint would be designated

and the auto

- pilot would be engaged in an auto

- hover mode while filming commences. A

loss of communicatio n “return to base” fail

- safe system is integrated as well. The battery life is approximately 30 minutes with a planned flight time of not more than 15 minutes. Angel City Air, Inc. will file a FAA Form 7711

- 1 or any such form deemed appropriate with the local Flight Standards District Office. Additionally, an Operations Plan would be submitted on a mutually agreed periodical basis to the FSDO.

All sUAS pilots being employed by Ange l City Air, Inc. for this mission will have a FAA

Private Pilot Ce rtificate a nd a second class FAA medical certificate with additional experience in unmanned aircraft operations. The team composition will consist of a minimum of one pilot, one camera opera tor and one safety observer during all mobile news events, giving redundancy to the human element as well. Pilots will be well trained in areas of both normal and abnormal operations equipped with checklists and operations

and maintenance manuals to be abl e to contend with any scenario. After extensive range testing and pilot training

, the sUAS team will perform “dry

- runs” to simulate and practice actual news events and situations. To help prepare for actual flight and news gathering with a UAS, the team w ould deploy with the mobile news team and observe conditions and scenarios where future operations might take place. This would give the team a feel for the “cadence” of an active news event to allow them to be able to plan timing and

coordination issues. Unlike other use s for sUASs, these flights would be mostly shorter in length, obviating the need for a backup pilot. The designated safety observer would help to provide greater situational awareness for the team in order maintain alertness and vigil

at al l times. A n environmental assessment will be performed to measure such parameters

as noise and hazardous material concerns.

Additionally Angel City Air Inc. proposes that the exemption requested apply to civil aircraft that have the characteristics and that operate with the limitations listed. These limitations provide for at least an equivalent or even higher level of safety tooperations under the current r egulatory structure because the proposed operations represent a safety enhancement to the already safe aerial photography and closed set aerial filming for movie and television filming operations conducted with conventional

aircraft.

These limitations and conditions to which Angel City Air agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1

. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to

the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. M inimum crew for each operation will consist o f the sUAS Pilot and the Visual

Observer.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s

certificate and third class medical.

7. sUAS Pilot assume all duties and responsibilities a s Pilot in Command (PIC).

8

. The sUAS will only operate within a confined “Sterile Area”. Security will be performed by the operator and designated security personnel.

9. A briefing will be conducted in regard to the pl a nned sUAS operations prior to

each day’s production activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.

10. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination. With the advanced permission of the relevant FSDO, operatio ns at closer range can be approved.

11. When required, the operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot.

12. Pilot and observer will have been trained in operation of UAS generally and received up

- to

- d ate information on the particular UAS to be operated.

13. ALL crew members will at all times be able to communicate by ONLY voice

communications as to ensure all crew members maintain a visual contact with the

UAS at ALL TIME.14. Written and/or oral permi ssi on from the relevant property holders will be

obtained.

15. All required permissions and pe r mits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

16. I f the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location within the Security Perimeter and

land.

17

. The sUAS will have the capability to abort a flight in case of unpredicted

obst acles or emergencies.

UAS Crew Requirements:

UAS Pilot in Command must:

1. Hold at least a FAA Private Pilot with current 3 rd class medical

2. Have a minimum of 200 flight cycles and 25 hours of total time as

a sUAS rotorcraft pilot and at least 10 hours as a sUAS pilot with a similar sUAS type (single blade or multirotor); a minimum of 5 hours as sUAS pilot with the make and model of sUAS to be utilized for operations under the exemption and 3 take offs and landing s in the preceding 90 days;

3. Received training in the safe operation of the UAS to be operated. Training will include:

a. Normal and emergency modes of operation

b. Familiarization with the operation manual published by

the UAS manufacturer.

c. Types of maneuvers to be performed during operations including safe operation in relation to persons, property and applicable airspace using the actual UAS or

manufacturers simulation software

Camera Operator must:

1. Become familiar with the operation manual published by th e UAS

manufacturer.

2. Receive training in the safe operation of the systems operated onboard the UAS. Training will include:a. Proper method of loading, rigging, or attaching the camera mount, lighting, and any external equipment

b. Types of maneuvers to be pe rformed during operations

c. Safe operation in relation to persons, property and applicable airspace.

d. Receive training on basic VFR weather minimums

outlined in 14 CFR 91.155

In a dual control configuration, the Camera Operator will not operate the master

controller.

Visual Observer must:

1. Be familiar with the use of VHF / FM radio communication.

2. Have received training on the National Airspace System 14 CFR 71 and

the basic VFR weather minimums outlined in 14 C.F.R. 91.155.

The Plan of Activities

The Plan of Activities must include the following:

1. Dates and times for all flights;

2. Name and phone number of the person responsible for the photography / filming event;

3. Name and phone number of the person responsible for the aircraft;

4. Make, model and serial number and/or registration number of all UAS t to be used;

5. Name and certificate number, if applicable, of all crewmembers to be utilized in the event including copies of FAA Me dical Certificates and endorsements;

6. A statement that the Waiver Holder has obtained permission from property owners and/or local governmental officials to conduct the event;

7. Signature of Waiver Holder or representative;

8. A description of the flight activity including maps or diagrams of any area, city, town, county, and/or State over which filming will be conducted and the minimum altitudes essential to accomplish the operation.

BriefingAngel City Air and the event representative will conduct a v erbal and written briefing for the members involved, including emergency, if applicable, and security personnel. This briefing will be conducted prior to each day’s UAS activities and will include the following items.

1. Authorization UAS flight opera tions, Plan of Activities, special provisions and any additional provisions issued by the Flight Standards District Office having jurisdiction over the photo / filming area.

2. Radio communications.

3. Takeoff procedures.

4. Aviation activities to be conducted dur ing the event.

5. Approach and landing procedures.

6. Alternate landing zone in the event of emergency or security breach.

7. Recall procedures.

8. Emergency procedures.

9. Possible risk to personnel that are involved.

10. Control of non

- participating persons.

11. Location of boundaries or deadlines, man

- made or natural, readily visible to the participants. 13. Local governmental limitations, restrictions, or any special circumstances, such as noise sensitive areas, time of day restrictions or changes in operating procedures.

Secu r ity

The exclusion from the flight operations area of unauthorized persons, vehicles or aircraft will be enforced by designated event personnel, private security officers or sworn

law enforcement officers at the direction of Angel City Ai r

.
Angel City Air or his designated representative will halt flight operations in the event unauthorized persons, vehicles or aircraft enter the flight operations area.

A predetermined abort signal will be used to halt flight operations should a breach of perimeter se curity occur, or for any other reason in the interest of safety.

Alternate UAS landing sites will be made available prior to the start of the event.

14 CFR Part 21, Subpart H

– Airworthiness Certificates 14 CFR 91.203 (a) (1)

Subpart H (Airworthiness Certificates) defines the requirements for airworthiness certificate issuance IAW FAR 91.203 (a) (1). Existing law (49 USC 44701 (f)), Part 11 and Section 333 allow the FAA to exempt aircraft from the requirements of an

airworthine ss certificate upon consideration of the size, weight, speed, operationalcapability and proximity to airports and populated areas of the ident i fied sUAS. Unlike a manned helicopter, the sUAS being employed is lightweight, has no flammable fuel or

other lu bricants, operates at very slow speeds and stays well below any conflicting air traffic thereby providing, an equivalent level of safety when compared to currently employed manned aircraft.

The pro p osed sUAS to be employed is under 55 lbs. when outfitte d with all equipment and batteries. There are no flammable liquids or other hazardous materials that would propose a danger to the public or event participants. Accordingly, no threat to national security exists due to the inability of carriage of any exte rnal stores or ordnance

and the exhaus tive vetting of team personnel. All activities will be closely monitored by a team of aviation professionals and using a system with redundancies in all areas.

14 CFR 45.23 (b) Display of Marks; general

CFR 45.23 states:

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 displa y 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.

An exemption to this section is needed due to the lack of a cabin, cockpit or pilot station where any reference to the term “Experimental” could be affixed. Accordingly, the wording will be placed on the fuselage. This equivalent level of safety will allow the

team to clearly see “Experimental.” Previous precedence exists within Exemptions 10700, 10167, and 10167A.

CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command

CFR 61.113 (a) & (b) states:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for

compensa tion or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or empl oyment; and

(2) The aircraft does not carry passengers or property for compensation or hire.To reach an equivalent level of safety, the self

- imposed experience and training requirements would more than offset any risk introduced by using private pilot s to fly an unmanned aircraft in very restricted and controlled areas.

CFR 91.7 (a) Civil aircraft worthiness

CFR 91.7 (a) states:

No person may operate a civil aircraft unless it is in an airworthy condition.

Assuming no airworthiness certificate will be required due to relief from Subpart H, no regulatory standard exists for determining airworthiness. The equivalent level of safety will be achieved through the employment of the manufacturers flight manual and maintenance manual procedu res, pilot training and analytical risk management for each

event.

CFR 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft

CFR 91.9 (b) (2) states:

No person may operate a U.S.

- registered civil aircraft

—

For which an Airplane or Rotorcraft F light 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, or any

combination thereof.

Given the size o f th e sUAS being utilized in this endeavor, there is no room onboard for an aircraft flight manual.

The equivalent level of safety will be achieved by keeping the flight manual with the pilot/team on the ground with easy access. Previous precedence is resid ent in Exemptions 8607, 8737, f8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, f32827, and 10700.

CFR 91.103 (b) Preflight action

CFR 91.103 (b) states:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

—

(b) For any flight, runway lengths at airports of intended use, and the following

takeoff and l anding distance information:(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircra ft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and

wind and tem perature.

This regulation dictates that a pilot conduct preflight activities. Without an FAA approved flight manual, relief is required from this regulation. Extensive pre

- flight planning will provide an equivalent level of safety by using the operations plan, aircr aft flight manual, maintenance manual and available weather and NOTAM information.

CFR 91.109 Flight instruction

CFR 91.109 states:

No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unle ss that aircraft has fully functioning dual control s

.

sUASs clearly have no onboard flight controls. An equivalent level of safety will be accomplished by conducting pilot training via the control system that communicates with the aircraft from the grou nd.

CFR 91.113 Right

- of

- way rules: Except water operations.

CFR 91.113 deals with the many scenarios whereby different types of aircraft in different states must give way to other aircraft.

Becaus e the sUAS PIC does not have “see and avoid” capabili ty, the petitioner requests relief from this regulation. All operations will be within V LOS of the pilot and well below any airspace where other flight activity is taking place.

CFR 91.119 (d) (1) Minimum safe altitudes; general

CFR 91.119 states:

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA.Recognizin g that this relief is unprecedented, the petitioner asks that the FAA recognize the inherent capability of the Angel City Air, Inc. we feel that an acceptable level of safety can be achieved. Extensive range testing and additional on

- site testing in a

beni gn environment would be conducted in re al or near

- real time conditions. The current

altitude and/or horizontal restrictions on rotor c raft assumes a much heavier manned aircraft loaded with fuel and possible external stores. The light

- w e ight sUAS being

prop osed for use in this activity along with its precise guidance and redundant systems create an entirely different paradigm that should be considered by regulatory bodies.

The activities being proposed by this petitioner are in a very controlled and open area. The flights would be confined to the immediate area of the mobile control center (MCC). Given these considerations, Angel City Air, Inc. proposes allowing fli ghts to operate no more than 300 feet from the MCC and well clear of the Class B airspace an d

attendant manned air traffic.

CFR 91.121 Altimeter settings

CFR 91.121 states:

Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, w hen operating

—

Below 18,000 feet MSL, to

—

The current reported altimeter setting of a station along the route and within 100

nautical miles of the ai r craft ;

The sUAS aircraft intended for this activity will not be equipped with a

barometric altime ter. Instead it will incorporate radio altimetry via the onboard GPS. An equivalent level of safety will be achieved through use of the operations and maintenance manuals governing altitude control. A preflight calibration of launch site altitude will be

a ccomplished.

CFR 91.131 (a) (1) (c) (2) & (d) (1) Operations in Class B airspace

CFR 91.131 states:

(a) Operating rules. No person may operate an aircraft within a Class B airspace

area excep t in compliance with § 91.129 and the following rules:

(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.(c) Communications and navigation equipment requirements. Unless otherwise authorized by ATC, no person m ay operate an aircraft within a Class B airspace area unless that aircraft is equipped with

—

(2) For all operat i ons. An operable two

- way radio capable of communications with ATC on appropriate frequencies for that Class B airspace area.

(d) Other equipment requirements. No person may operate an aircraft in a Class B airspace area unless the aircraft is equipped with

—

(1) The applicable operating transponder and automatic altitude reporting equipment specified in § 91.215 (a) , except as prov ided in § 91.215 (e) , and

Much of the city of Los Angeles lies within the limits of the Class B airspace , or various other controlled airspace . Because the pl a nned sUAS to be employed lacks an onboard transponder or two way communication capability, rel ief from this regulation is required. An equivalent level of safety will be achieved by limiting the operating ceiling

o f

the sUAS to altitudes well below any conflicting manned airc raft traffic (no higher

than 200 feet). This assures de

- confliction with a ll other traffic and specifically traffic within the Class B airspace. Additionally

, the sUAS will remain clear of the Los Angeles

International Class B airspace at all times. Ang el City Air, Inc. will periodically report to the FSDO on operations and risk management issu e s.

CFR 91.145 (b) Management of aircraft operations in the vicinity of aerial demonstrations and major sporting events.

CFR 91.145 states:

In deciding whether a temporary f light restriction is necessary for an aerial demonstration or major sporting event not listed in paragraph (a) of this section, the FAA considers the following factors:

(1) Area where the event will be held. (2) Effect flight restrictions will have on kn own aircraft operations. (3) Any existing ATC airspace traffic management restrictions. (4) Estimated duration of the event. (5) Degree of public interest. (6) Number of spectators. (7) Provisions for spectator safety

. (8) Number and types of participatin g air craft

. (9) Use of mixed high and low performance aircraft. (10) Impact on non

- participating aircraft. (11) Weather minimums. (12) Emergency procedures that will be in effect.If KNBC, or KTLA , or various other news outlets intends to us e the sUAS t o cover sporting events from the outside of the activity, coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of any other unmanned activities. Flight activity will be conducted using the same operations plan as with any other ENG activity with particular attention to the avoidance of over flight of large concentrations of people. All of the concerns in the above twelve subparagraphs have been or will be addressed in other portions of this exemption application . How ever, specific relief from this regulation is still necessary to ensure compliance with FARs.

CFR 91.151 (b) Fuel requirements for flight in VFR conditions.

CFR 91.151(b) states:

No person may begin a flight in a rotorcraft 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 cruising speed, to fly after that for at

lea st 20 minutes.

The batteries t hat power the DJI S100 and Intuitive A e rial Aerigon have a m ission life of approximately 30 minutes. To mee t the 20 minute reserve requirement, the

airborne mission woul d be limited to approximately 10 minutes. Given the limitation of the proposed flight area during any ENG, a more liberal flight time is a reasonable request. The aircraft would never be further than 150 feet from the recovery area, literally representing seconds to land. In no case woul d the aircra ft be operated with less than 20 % battery life remaining.

No night time operations are currently planned.

CFR 91.203 (a) & (b) Civil Aircraft: Certifications required

CFR 91.203 (a) & (b) states:

(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. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy

of t he applicable operations specifications issued under § 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21.197(c)

, or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter . However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after t hat number isfirst affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identific a tion number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31(c) , or a registration certification issued under the laws of a foreign country.

(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 sUAS to be employed has no cockpit or pilot and therefore has no ability to carry onboard any certification or registration documentation.

The equivalent level of safety will be achieved by keeping these docum ents with the pilot/team on the ground at the event. Previous precedence is resident in Exemptions 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A and 10700.

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 417 (a) & (b) Maintenance

T hese CFRs state: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in parag raph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapte r ;

Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter; and

(2) The maintenance record entry required by § 43.9 or § 43.11 , as applicable, of this chapter has been made.

Except as provided in paragraph (c) of th is section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—

(2) An inspect ion for the issuance of an airworthiness certificate in accordance with part 21 of this chapt e r

.

operator shall keep the following records for the periods specified in paragraph (b) of this

section:(1) Records of the maintenance, preventive maintenance, and alteration and records of the

100

- hour, annual, progressive, and other required or approved inspections, as appropriate,

for e ach aircraft (including the airframe) and each engine, propeller, rotor, and appliance

of an aircraft. The records must includ e

—

( i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of complet ion of the work performed; and ( iii) The signature, and certificate number of the person approving the aircraft for

return to service.

(2) Records containing the following informatio n :

( i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of al l items installed o n the aircraft which are required to be overhauled on a specified time bas i s.

(iv) Th e current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances

are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date when the next action is requir e d.

(vi) Copie s of the forms p rescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The re cord s specified in paragraph (a) (1) of this section shall be retained until the work is repe a ted or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained and

tra nsferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for

return to servi ce.T hese FARs only concern aircraft with an airworthiness certificate and therefore would not apply in this situation. All maintenance and inspections will be conducted IAW the maintenance manual and operations manual. The ability for an almost immediat e safe recovery and landing if a malfunction occurs and the multi engine configuration with the ability to fly with loss of thrust on 2 engines provides a comfortable operating envelope and ensures an equivalent level of safety.

The reasons why granting Angel City Air, Inc. ’s request would be in the public interest; that is, how it would benefit the public as a whole:

Granting the exemption to Angel City Air, Inc. would allow the public to safely view breaking news from a dynamic and unprecedented aerial perspective. Angel City Air, Inc. has created a unique way to view news events that benefits the general public socially and economically. Angel City Air, Inc. set s the industry standard in using purpose built

Small Unmanned Aircraft Sys t ems ( sUAS) with multiple redundant features that enhance safety. Angel City Air, Inc. operates it s DJI S1000 and Intuitive A e rial Aerigon platform

with dual electronic motherboards and flight control systems, multi high

- capacity

batteries rated between 1 6 ,000 mAh and 22 ,000 mAh each, and the ability to maintain controlled flight with the loss of 2 engines.

In addition, enhanced safety is achieved by using an unmanned aircraft that does not carry passengers or crew and does not carry flammable fuel.

IAW 14 CFR Part 11.81, the following summary is provided for publication in the Federal Register, should it be deemed necessary: Applicant seeks relief from th e following rules:

14 CFR Part 21, Subpart H

– Airworthiness Certificates, 14 CFR 45.23 (b) ,14 CFR 61.113, (a) & (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14

CFR 91.103 (b), 14 CFR 109, 14 CFR 91.119, 14 CFR 91.113, 14 CFR 91.121, 14 CFR 91.131 (a) (1) (c) (2) (d) (1), 14 CFR 91.145 (b), 14 CFR 91.151, 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b), 14 CFR 407, 14 CFR 409, 14 CFR 417,

NOTAM 9/5151

The unparalleled operational an d testing capabilities created by the partnership

between Angel City Air, I nc. , Welk Aviation, and Intuitive Aerial will enable the Federal

Aviation Administration to allow for the introducti o n of sUASs into environments not previously allowed with an acce ptable level of safety. This is an opportunity to use highly dependable, multi

- redundant unmanned aircraft in a major metropolitan area, but to do so with stringent controls, pervasive risk management and detailed mitigation strategies

to ensure that the public is not at any time exposed to unsafe conditions. Extensive range testing, “dry

- run” testing under benign conditions and simulated emergencies willdemonstrate that this activity can be accomplished without hazard to the general public.

The rotorcra ft being proposed for this operation has redundancy in every conceivable area: thrust, communications, and electrical power for both the aircraft itself and the supporting syst em. Eight engines powered by multiple separate batteries power ranging

between 1 6 ,000 mAh and 22 ,000 mAh and a data link system with “fly home” capability ensure that at no time will the aircraft not be able to land safely should that need arise.

Pre

- plotted waypoints using Geographic Instrument System coordinates and auto

- pilot “fly to” commands provide extremely precise navigation. A Safety Management System will be employed and will address such issues as environmental impact (noise and hazardous material) and coordination with local Emergency Services/Incident Management personnel to include:

• Fire fighting

• Medical Response

• Incident investigation

These capabilities, in total, provide a level of safety that should be satisfactory to the FAA and general public.

In view of the beneficial advantages to public safety, we respectfull y submit our Section 333 exemption request.