Michael R Jarrett, CEO

CineVista Media, LLC

10080 Lake Cove Dr Unit 301

Fort Myers, FL 33908

800-91 0-4771

rhett@ci nevista med ia. com

August 11,2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Section 333 Petition to Operate Small Unmanned Aerial Systems

Petition Summary

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No.

112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's

("FAA"; general exemption authority under 49 U.S.C. section 44701 (0, CineVista

Media, LLC ("Petitioner") hereby petitions for exemptions from 14 C.F.R Part 21,

Subpart H (Ainrvorthiness Certificates), 14 C.F.R. Part 27 (Airworthiness Standards:

Normal Category Rotorcraft), 14 C.F.R sections 61.113(a) and (b), 91.103(b)(1),

91.119(c),91 .121,91 .151 ,91.405(a),91.407(aX1),91.409(aX2), and 91.417(a) and (b).

The proposed exemption, if granted, would allow Petitioner to conduct commercial

operations of small unmanned aircraft systems ("UAS") meeting or exceeding all of the

operational and safety requirements Congress has set forth in Section 333.

Petitioner is a photography, videography and technology company that plans to exploit

the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Pipeline inspection and patrolling

- Aerial surveying

- RF surueying

- Remote sensing
- Telecommunications

- Agriculture

- Energy systems inspections and asset management

- Wildlife and forestry monitoring

- Educational and research operations

Statutory Authority

Section 333, titled "Special Rules for Cedain Unmanned Aircraft Systems", provides a

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the

NAS. Section 333(a) states that the FAA "shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion of the

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the

guidance required by section 334 of this Act." In Section 332(b)(1), Congress made it

clear that Section 333 provides a mechanism for "expedited operation authorization" if

several factors are met. Petitioner meets all requirements to permit FAA approval of

commercial UAS operations.

The Petitioner Requests Relief From the Following:

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and

changing design approvals, production approvals, airworthiness certificates, and

airworth iness approvals.

Section 61 .1 13(a) and (b) prescribes that-

(a) no person who holds a private pilot certificate may act as a pilot in command

of an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation 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 employment; and

(2) The aircraft does not carry passengers or property for compensation or

hire.

Section 91.9(bX2) prohibits operation of U.S.-registered civil aircraft 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.
Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before

beginning a flight, become familiar with all available information concerning that flight, to

include-

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather

reports and forecasts, fuel requirements, alternatives available if the planned

flight cannot be completed, and any known traffic delays of which the pilot in

command has been advised by ATC;

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

takeoff and landing 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;

(2) For civil aircraft other than those specified in paragraph (bX1) 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 temperature.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person

may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing

without undue hazard to persons or property on the sudace.

(b) Over congested areas. Over any congested area of a city, town, or

settlement, or over any open air assembly of persons, an altitude of 1,000 feet

above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. lf 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; and

(2) A powered parachute or weight-shift-control aircraft may be operated

at less than the minimums prescribed in paragraph (c) of this section.
Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain

cruising altitude by reference to an altimeter that is set "to the elevation of the depafture

airport or an appropriate altimeter setting available before depafture."

Section 91.151 (a) prescribes that no person may begin a flight in an airplane under

VFR conditions unless (considering wind and forecast weather cond1ions) there is

enough fuel to fly to the first point of intended landing and, assuming normal cruising

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.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall

have that aircraft inspected as prescribed in subpart E of the same paft and shall,

between required inspections, except as provided in paragraph (c) of the same section,

have discrepancies repaired as prescribed in part 43 of the chapter.

Section 91.407(aX1)prohibits, in pertinent part, any person from operating an aircraft

that has undergone maintenance, preventative maintenance, rebuilding, or alteration

unless it has been approved for return to service by a person authorized under $ 43.7 of

the same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had an inspection for the

issuance of an ainrvorthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent paft, that-

(a) Each registered owner or operator shall keep the following records for the

periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventative maintenance, and alteration

and records of the 1O0-hour, annual, progressive, and other required

or approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an

aircraft. The records must include-

(i) A description (or reference to data acceptable to the

Administrator) of the work performed; and

(ii) The date of completion 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 information:
(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 all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The 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 ainrvorthiness directives (AD)

and safety directives including, for each, the method of

compliance, the AD or safety directive number and revision

date. lf the AD or safety directive involves recurring action, the

time and date when the next action is required.

(vi) Copies of the forms prescribed by S 43.9(d) of this chapter for

each major alteration to the aifframe and currently installed

engines, rotors, propellers, and appliances.

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

prescribed:

(1)The records specified in paragraph (aX1) of this section shall be

retained until the work is repeated or superseded by other work or for 1

year after the work is performed.

(2) The records specified in paragraph (aX2) of this section shall be

retained and transferred 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 service.

Unmanned Aircraft System

The petitioner states that the unmanned aircraft (UA) to be operated under this request

is less than 55 lbs. fully loaded, flies at a speed of no more than 50 knots, carries

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels,

and operates exclusively within a secured area as set out in the Pilot Training Guide.

The craft to be utilized is the Inspire 1 manufactured by DJl. The quadcopter has 4
motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground

control.

In addition, the craft has integrated safety features built into the design of the UAS, as

described in the Pilot Training Guide, to ensure the safety of persons and property

within and surrounding the limited operating area, The petitioner further desqibes that,

in the event the UAS loses communications or its GPS signal, the UA will have the

capability to return to a pre-determined location within the Security Perimeter and land.

It will also have the capability to abort a flight in the event of unpredicted obstacles or

emergencies.

Petitioner's UAS will be identified by serial number, registered in accordance with 14

C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14

C.F.R. Part45, Subpart C. Markings will be as large as practicable.

The Petitioner has Supplied the Following Additional Information:

DJI Inspire 1 User Manual, Maintenance Manual, and Safety Guidelines.

Pre-flight Inspection, Maintenance

Before each flight the PIC will perform a series of pre-flight and takeoff checks as

defined by the Pilot Training Guide supplied. After each 60 minutes of airtime, the craft

will undergo a thorough inspection of all aircraft components, including, but not limited

to:

a. Actuators / Servos

b. Motors, wiring and connectors

c. Propellers, smooth, no chips

d. Electronic speed controller, wiring and connectors

e. Batteries, wiring and connectors

f. Remote command and control

g. Ground control station

UAS Operating Parameters

The petitioner states that all flights will be operated within visual line of sight (VLOS) of

pilot, in daytime VFR flight conditions and all operations will be conducted with the
assistance of a second spotter/observer. The UAS flights will be limited to a maximum

altitude of 400 feet AGL. Altitude is accurately measured by GPS and barometer. The

petitioner further states that an operator will ensure that only consenting production

personnel will be allowed within 100 feet of the UA operation, and UAS will be kept at

least 100 feet from any inhabited structure. Generally the petitioner's UAS will be

operated in rural or suburban areas that will permit significantly larger safety zones.

Flight Standards District Offices (FSDOs) will be notified as required prior to operations

to describe intended coordination for proposed operation(s). Petitioner will obtain an Air

Traffic Organization ("ATO") issued Certificate of Waiver or Authorization ("COA") prior

to conducting any operations under this grant of exemption. In fulfilling its requirements

under the COA, Petitioner will be required to request a NOTAM not more than 72 hours

in advance, but not less than 48 hours prior to the operation Petitioner's UAS will remain

clear and yield the right of way to all manned operations and activities at all times

(including, but not limited to, ultralight vehicles, parachute activities, parasailing

activities, and hangliders). Petitioner will not conduct UAS operations within 5

nautical miles of the geographic center of a non-towered airport unless a letter of

agreement with that airport's management is obtained and the operation is conducted in

accordance with a Notice to Airmen ("NOTAM").

Pilot in Command (PlC)

Regarding Petitioner's requested relief from 14 C.F.R. S 91.103(bXl ), Petitioner will

comply with the other applicable procedures and requirements stated in g 91.1 03(a)

and (b). Specifically, the PIC will take all actions including reviewing weather, flight

battery requirements, aircraft performance data, and landing and takeoff distances

before initiation of a flight. The PIC will also account for alt relevant site-specific

conditions in their preflight procedures. Risks presented by sun glare will be mitigated

by the PIC's and VO's ability to see other air traffic and initiate a return-to-home

sequence if needed.

Radio Frequencies

Radio frequencies used will be those allotted by the FCC for data transmission and

vehicle control in unlicensed frequency bands. All devices used will comply with FCC

usage and emissions regulations.

Safety and Benefits of the UAS

The petitioner will be using the UAS in a variety of applications that generally require

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles

offer many benefits over the use of full-sized manned aircraft for electric power line

inspection, oil/gas pipeline inspection, advanced agriculture, and film and still
photography. Replacing significantly larger manned aircraft carrying crew and

flammable fuel with small UAS carrying no passengers or crew creates a much greater

margin of safety for the pilots and crew.

By granting Petitioner's requested exemptions, the FAA will help drive development of

safe and successful commercial UAS operations and will advance the public knowledge

base for such operations. Petitioner is committed to promoting the UAS research efforts

of policymakers_including the FAA, NASA, DOD and DARPA by sharing data from its

commercial UAS operations and serving as a resource for future UAS iesearch

operations. Thus, the FAA has good cause to grant this Petltion.

Conclusion

For the foregoing reasons, the exemptions requested herein should be granted and

Petitioner should be permitted to conduct small UAS operations in accoidance with its

manuals and all other operating parameters deemed necessary and appropriate by the

FAA.

Michael R Jarrett, CEO

CineVistaMedia, LLC

Sincerely,