September 1 4

, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Skip TV Productions for an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

Director: Flight Standards Service:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and
14 C.F.R. Part 11, Skip TV hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting close set aerial videography and photography filming for the motion picture, television, and web industry

.

This petition for exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying documents;

1. PIC Flight Operations Manual and;

2. Operations Manuals ( Collectively 2 and 3 are referred to as Documents and Manuals)

3. U ser Guide and;

4. Flight Manual 1
( Collectively 3 and 4 are referred to as "Manufacturer's Manuals").

Skip TV submits these supporting materials as confidential documents pursuant to 14 C.F.R. § 11.35(b), as the materials contain confidential commer cial and/or proprietary information that Skip TV has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from relea se under the Freedom of Information Act, 5 U.S.C. § 552 et. seq.

For your convenience, this Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

1 . The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service

information letters and, safety/service bulletins

.U.S Department of Transportation

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A. Close Set A erial videography, photography and cinematogr a phy

III. Rele vant Statutory Authority

IV. Proposed UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions S et Forth in the Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C. 14 C.F.R. §§ 91. 9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privi leges and

Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Prefl ight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

V1. Drug and Alcohol Program

VII. Publi c Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion

I. DESCRIPTION OF PETITIONER

Skip TV , based in Palm Springs , CA provides close set aerial videography, photography and cinematography for the movie, TV and web industry utilizing the latest UAV technology. Skip

TV aims to provide high quality aerial video to every client in a safe and professionalU.S Department of Transportation

September 1 4

, 2015 Page 3

manners. Skip TV works to produce video graphy and photography via controlled flights for the promotional purposes, commercial art and stock footage. The Company’s Principal and Chief

Pilot Skip Fredericks has been flying UAV Quadcopters as a hobby for more than three year s without incident, spen d ing thousands of hours flying. Upon the grant of the 333 Exemption the Company’s business w ill specialize in production of v ideography and photography for their

client base.

Skip TV ’s staff are well trained and experienced in providing support as visual observers (“VO”) for the pilot in command (“PIC”) in addition to any other needed on site ass istance

.
All of the equipment owned by Skip TV is of the highest quality gear and ha s been able to provide these services safely and without any claims or incident

. Skip TV ’s goal is to advise the perspective client that Skip TV is following all the appli cable state and federal rules to ensure the safety of the public while providing the client with a competitive and cost effective product.

Skip TV seeks an exemption to allow for aerial filmmaking as well as photography, videography

services and other rel ated media products.

The contact information for Petitioner is as follows:

Skip Fredericks Skip TV Productions

2700 Sandia Rd Palm Springs, CA 9 2262

Phone: 323

- 369

- 2584

Email: s.fredricks@yahoo.com

II. DESCRIPTION OF PROPOSED OPERATION

Skip TV seeks an exemption pursuant to Section 333 of the Reform Act to operate the

DJI Phanto m 2 ; DJI Inspire 1 ; Rotor Concept F12e; and, 3D Robotics Solo ( all under 55lbs) also known as ( STV

- UAS ) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions on private property where Skip TV has received

verifiable permission to operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance with th e conditions and limitations of this Petition for Exemption and Skip TV ’s Operations Manuals. As detailed in Skip TV ’s Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within

visual line

- of

- sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 mm away from an airport reference point

. Moreover, Skip TV ’s Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area of UAS operations, inclu ding GPS "geo

- fencing" technologies.

A. Aerial C losed

- S et Videography, P hotography and C inematography

Skip TV seeks to use small STV

- UAS for the purpose of conducting closed

- set aerial videography and photography for the movie, television and web industries

. Skip TV has purposefully tailored its operations to meet the requirements established by the FAA in priorU.S Department of Transportation

September 1 4

, 2015 Page 4

grants of exemption authorizing commercial use of UAS in the motion picture and television filmmaking industry, including :

 Astraeus Aerial (Exempti on No. 11062)

 Aerial MOB, LLC (Exemption No. 11066)

 Pictorvision, Inc. (Exemption No. 11067)

 HeliVideo Productions, LLC (Exemption No. 11065)

 Snaproll Media, LLC (Exemption No. 11063)

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11 064)

 Flying

- Cam, LLC (Exemption No. 11080)

 Aerocine, LLC (Exemption No. 11150)

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

All UAS recording operations will occur on private property in a controlled area away from spectators and persons not involved in the film making process . In addition, the filming will be

conducted between dawn and dusk to ensure maximum safety for the public and t hose involved in the manipulation and operation of the UAS ; VFR conditions, at altitudes below 400' above ground level (“AGL”).

As set forth below, Skip TV ’s operations provide an equivalent level of safety which is superior to performing the same work u sing conventional fixed

- wing aircraft or helicopters.

Small UAS recording operations is also safer than traditional manned aircraft performing the same function. Conventional operations using rotorcraft and fixed

- wing aircraft in low level operations pres ent risks associated with vehicles weighing tens of thousands of pounds (including payload) and carrying large amounts of fuel which inherently presents significant fire hazards as well as exposure to other chemical contaminates

. It is important to note t he use of small UAS in this area will not only be safer and more cost effective to the perspective user or purchaser of the service , but the quality and expanse of acquired information will be far more robust given the low cost associated with its acquisit ion and other potential consumers an inexpensive product

.

UAS recording is more reliable, and allows for the collection, dissemination, and storage of visual and other sensory data with greater precision and duration at a very low cost . Small UAS

will a lso be capable of accessing and inspecting areas that would otherwise be inaccessible or highly dangerous using conventional aircraft or other inspection methods.

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Sect ion 333(a) through (c) of the FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permitU.S Department of Transportation

September 1 4

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u nmanned aircraft systems to operate in the National Air Space ("NAS") where it is safe to do so

b ased on the following considerations:

● The UAS's size, weight, speed and operational capability; ● Operation of the UAS in close proximity to airports and populated areas; and ● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has gene ral authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 4 4701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702

– 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or

how it w ould provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. SKIP TV ’S PROPOSED STV

- UAS OPERATIONS MEET THE REQUIREMENTS

OF SECTION 333 OF THE REFORM ACT

The small STV

- UAS operations proposed by Skip TV as noted above in this Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the UAS s due to their size weight, speed, and operational capability.

 The STV

- UAS ’s utilize d by Skip TV have been approv ed for use in prior Section

333 Grants of Exemption from the FAA. 2

 The STV

- UAS s weigh less th an 55 pounds, including payload

 The STV

- UAS s will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA S as specified using G PS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. This information will be transmitted to the pilot via telemetric data feed.

2 See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to LowCountryRC, Corp. (Exemption No. 11184); Grant of Exempti on to Alan Purwin (Exemption No. 11161); Grant of Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total Safety U.S., Inc. (Exemption No. 11156).U.S Department of Transportation

September 1 4

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 The STV

- UAS will have system redundancies and independent functionality to

e nsure the overall safety and predictability of the system. If connection to the remote control or ground control station is lost, failsafe systems will permit the UAS s to return to a predetermined location and safely land without injury or damage.

 The rad io frequencies used for operations and control of the STV

- UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. T he operating frequency for the STV

UAS is 2.4 GHz frequency bands.

If the same operations were conducted using a helicopter, the aircraft's take

- off weight would likely exceed 6,000 pounds depending on payload . The difference in weight between the STV

UAS and a helicopter significantly reduces the potential harm to the parti cipating and non

participating individuals and/ or surrounding property in the event of an unintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restr ictions Set Forth in Skip TV ’s Operations Manuals

Skip TV ’s Operations Manuals and the Manufacturer's Manual for the selected STV

- UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety

assessment of Skip TV ’s proposed operations, below is a summary of operational limitations and

conditions that Skip TV will adhere to, and which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The STV

- UAS weighs less than 55 pounds, with payload

.

2. All operations shall be conducted over private or controlled

- access property with verifiable permission from the land owner/control ler or authorized representative. Permission from land owner/controller or authorized representative will be obtained

for each scheduled flight prior to operation

.

3. All UAS operated under the Grant of Exemption will be identified by serial number, register ed in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot

- in Command ("PIC") of the STV

- UAS , and one or more Visual Observers ("Observer") as necessary to safely conduct the mission.

5. PICs shall possess either a private, recreational, or sport pilot certificate. The PIC

must also hold a current Class III medical cer tificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in wh ich the PIC is rated on his or her pilot

certificate.U.S Department of Transportation

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6. The STV

- UAS shall be operated within VLOS of the PIC and Observer at all times. The PIC must use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

- issued m edical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to

the Skip TV ’s Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and S kip TV ’s Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and must be followed. Otherwise, Skip TV shall follow the procedures outlined in their Operations Manuals.

10. Skip TV may update or revise its Operati ons Manuals. Revisions will be tracked and a revised copy of the Manual will be provided to the Administrator upon request. Skip TV will also present an updated and revised Operations Manuals if it petitions

for extension or amen d ment to its Grant of Exem ption. If an update or revision would affect the basis upon which the FAA grants the exemption, Skip TV will seek an amendment to its Grant of Exemption. Skip TV will contact the FAA’s UAS

Int e gration Office (AFS

- 80) if questions arise regarding updates or revisions to the

ope r ating documents.

11. Skip TV Operations Manuals and its Grant of Exemption will be available to the PIC at the ground control station anytime the STV

- UAS is operating.

12. The PIC is prohibited from beginning a STV

- UAS flight unless (consid ering wind and forecast weather conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10

minutes.

13. Maximum total flight time for each operational flight using the STV

- UAS will be

limited to 40 minutes or the amount of time the UAS can be flown and still maintain a reserve battery power of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the

struct ure, and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and struct ures unless:U.S Department of Transportation

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a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a

situation a rises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicl es or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essentia l persons do not present an undue hazard to those persons per § 91.119(a).

16. The STV

- UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. The STV

- UA S may not operate within 5 nm of an airport reference point as denoted

on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as requi red by the Skip TV COA. The letter of agreement with the airport management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the STV

- UAS to confirm that it is in a condition safe for flight. The pre

- fli ght inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents as well as equipment updates . The PIC shall not

operate any STV

- UAS if the inspectio n reveals a condition that affects the safe operation of the STV

- UAS until the necessary maintenance has been performed and

the STV

- UAS is found to be in a condition for safe flight. The ground control station shall be included in the preflight inspection. All maintenance and alternations must be properly documented in the UAS ’s records as required by Skip TV ’s Operations

Manuals.

19. Skip TV will timely carry out its maintenance, inspections, and record keeping requirements in accordance with the Operations M anuals. Maintenance, inspection,

and alterations will be fully noted in the STV

- UAS records, including total time in service, description of work accomplished, date completed and the signature of the authorized person returning the STV

- UAS to service.

20. Any STV

- UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement of a flight critical component)

must timely undergo a functional test flight in accordance with Skip TV ’s Operations

Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and STV

- UAS record entry shall be included in the Skip TV ’s Operations

Manuals.U.S Department of Transportation

September 1 4

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21. The STV

- UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates

.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on Ski p TV ’s Operations Manuals.

23. Skip TV will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of Exemption. A NOTAM will be issued as require d by the COA. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

24. All required permissions and permits will be obtained from te rritorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the STV

- UAS loses communication with the PIC , it will have the capability to safely return to a pre

- determined location wi thin the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the Observer.

27. The STV

- UAS will have the capability to safely abort flight in the case of unpr edicted obstacles or emergencies.

28. PICs and Observers will have at least a curren t Class III Medical Certificate or a valid

and current state driver’s license issued within the United States

.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS

p i lot with a similar STV

- UAS type platform

. This requirement can be achieved by flights conducted and logged as a hobbyist

.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged,

in a manner consistent with 14 CFR § 61.51(b) , a minimum of hours pursuant to 54 CFR § 61.51(b) as UAS pilot o perating the make and model of STV

- UAS to be utilized for operations under the exemption and three take

- offs and three landing in the preceding 90 days

.

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under special visual flig ht rules ("SVFR") shall not be conducted.

32. The STV

- UAS shall remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activitie s, hang gliders, etc.).U.S Department of Transportation

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33. STV

- UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The STV

- UAS will not be operated from an elevated platform or moving

device/vehicle.

35. Before conducting operations, the radio frequency spe ctrum used for operation and

control of the STV

- UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

V

. REGULATIONS FROM WHICH EXEMPTION IS REQ UESTED

The Federal Aviation Act exp ressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, including UAS , from its safety regulations and minimum standards when the

A dministrator decides a requested exemption is in the public interest. 3

Skip TV seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the

reque sted operations using STV

- UAS platforms noted above . Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. 4

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a findi ng is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met and in point of fact

exceeded

, and therefore no exemption is needed. 5 If , however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

3 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requiremen ts of regulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702

- 44716).

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that

pr o vided by the rule from which you seek exemption.

5 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at pgs. 13

- 14, 22).U.S Department of Transportation

September 1 4

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Skip TV ’s use of the STV

- UAS are safe when taking into account their size, weight, speed, and operational capability. As set forth in the description of proposed operations in Section IV ( A),

the STV

- UAS weigh less than 55 poun ds , including payload and will not be flown at a ground speed in excess of 50 knots. The S TV

- UAS are also equipped with safety features which will allow Petitioner to operate the STV

- UAS safely after experienc ing certain in

- flight contingencies

or failures as noted below

. 6 7 Additionally, the STV

- UAS carry neither pilots nor passengers,

carry no explosive materials or flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in Skip TV ’s Operations Manuals

.

Operations conducted under this exemption will b e closely controlled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area of operation. Skip TV will also provide the FAA with advance notice of all operations via NOT

AMs as required by the applicable COA. In all cases, operation of the STV

UAS under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate

. Lastly, the STV

- UAS do not need a m eans to communicate with other aircraft or ATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the STV

- UAS

. 8 In addition, no sense

- and

- avoid technology is necessary for the STV

- UAS because they will be ope rated at all times in VFR conditions and within VLOS of the PIC and Operator

. 9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

6 See e.g., Grant of Exemption No. 11184 to LowCo untryRC, Corp. (FAA

- 2014

- 0803 at pg. 3): "The [DJI S1000] has the capability to operate safely after experiencing certain in

- flight contingencies or failures and uses an auto

pilot system to maintain UAS stability and control. The UAS is also able to respo nd to a loss of global positioning system (GPS) or a lost

- link event with a pre

- coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level of safety compared t o a manned aircraft performing a similar operation."

7 See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA

- 2014

- 0382 at pgs. 4

- 5): The STV

- UAS can be operated entirely by a touch

- screen, map

- based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The STV

- UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre

- planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built

- in intelligent fault handling which al lows the STV

- UAS to detect a system fault while in the air and automatically fly back to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding pre

- set wind thresholds; and low battery levels.

All flight opera tions are global positioning system (GPS) controlled, making the system easy to navigate. At any point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS position. The flight control system employs not o nly GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight termination link

– to prevent a 'fly away' or other potenti ally dangerous situation

– is available to the operator."

8 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at pg. 13).

9 . IdU.S Department of Transportation

September 1 4

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Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal c ategory rotorcraft. To the extent that Skip TV ’s small STV

- UAS would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C. F.R. R. Part 21, Subpart H, supra

.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Skip TV seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23 (b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, 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 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, "experimental," or "provi sional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determi ned that exemption from these requirements was warranted provided that the aircraft "have identification (N

- Number) markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." 10

Equivalent Level of Safety

All STV

- UAS flown by Skip TV will bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11

10 FAA Docket No. FAA

- 2014

- 0352.

11 See, e.g., FAA Docket No. FAA

- 2014

- 0352, at 14.U.S Department of Transportation

September 1 4

, 2015 Page 13

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

Skip TV seeks an exe mption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a ) ( 2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which

the UAS platforms to be operated under this grant of exemption will not have

. (Emphasis added)

Equivalent Level of Safety

An equivalent level of safety will be achieved or exceeded because maintenance and inspections

will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Skip TV ’s Operations Manuals, the PIC will conduct a pre

- flight inspection of the STV

- UAS and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions po tentially affecting safe operation of the STV

- UAS and no flights will occur unless, and until, all flight critical components of the STV

- UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be

conducted f

ollowing the replacement of any flight

- critical components. As required by Skip TV ’s Operations Manuals, the PIC who conducts the functional test flight will make an entry in the

STV

- UAS aircraft records of the flight.

Skip TV ’s Operations Manual also inc ludes requirements to follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics

and control su rfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Skip TV ’s Operations Manuals also include procedures to document and maintain

a record of the STV

- UAS ’s maintenance, preventative maintenance, alterations, status of replacement /overhaul component parts, and the total time in service of the STV

- UAS used under this Grant of Exemption. As a whole, the maintenance and inspect ion procedures required in Skip TV ’s Operations Manuals ensure that an equivalent or higher level of safety will be

achieved.

PILOT

- IN

- COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations Skip TV seeks exemption from 14 CFR § 6 1.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches

the airs pace in which the PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for hire. In this case, while the STV

- UAS will be operated as part of a commercial oper ation, they carr y neither passengers no r cargo. In the Grant of Exemption to Astraeus Aerial, the FAA determined that the unique characteristics of UASU.S Department of Transportation

September 1 4

, 2015 Page 14

operation outside of controlled airspace did not warrant the addition al cost and restrictions attendant with requiring the PIC to have a Comme rcial Pilot Certificate and Class II Medical

Certificate. 12 The fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved.

Eq uivalent Level of Safety

The restrictions Skip TV has placed on its STV

- UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial. Skip TV will operate on private property away from persons and property not involved in the operat ion. Skip TV will also obtain an ATO issued COA prior to conducting any operations under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level a nd potential transponder requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Skip TV will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects of STV

- UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in STV

- UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf of Skip TV . The pilot qualification, training, and currency requirements in the Operations Manuals ensure that Skip TV pilots are

comp etent and proficient in the STV

- UAS they are operating. Skip TV ’s training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants of Exemption, and will provide a higher level of competency and proficiency for it s pilots and will ensure at least an equivalent level of safety to the public

.

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

I nasmuch as there will be no airworthiness certificate issued for the UAS, Skip TV seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found i napplicable. 13 Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance with

Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil A ircraft Certification and Registration

12 Exemption No. 11062 (FAA D ocket No. FAA

- 2014

- 0352).

13 See Id. at 13

- 14, 22

.U.S Department of Transportation

September 1 4

, 2015 Page 15

Title 14 C.F.R. § 91.9(b) (2) and § 91.203(a) and (b) require the operator to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2):

(b) No person may op erate a U.S.

- registered civil aircraft

–

... (2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual mater ial, markings, and placards, or any combination

thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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 airwort hiness 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.

Given the small size and configuration of the STV

- UAS , it would be impossible to keep

airworthiness documents and other aircraft manuals on board the STV

- UAS because there is simply no room and the STV

- UAS has no cabin or cockpit. As a way to comply with the code Skip TV will maintain the documents with the PIC and make them available for inspection.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E.

Grif fith, Attorney, AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safe ty will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Skip TV seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA

approved Flight Manual on board the aircraft. While the PIC will be familiar with all information

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA

- 2014

- 0352 at 16

- 18.U.S Department of Transportation

September 1 4

, 2015 Page 16

necessary to safely conduct the flight, an e xemption is requested to the extent that an FAA

approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Skip TV ’s Operations Manuals and the Manufacturer's Manual. The PIC will perfor m a series of checklists designed to identify any defects or inoperable components in accordance with the Skip TV ’s Operations Manuals, including checklists covering Pre

- Flight, Launch, Landing, and Post

- Flight procedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency landing areas

— before initiation of flight. Skip

TV ’s Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

Skip TV seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o person may operate a civil a ircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UAS and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a device that communicates with the aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UAS that Skip TV intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required by the Skip TV ’s Operations Manuals, all persons will be a safe distance away in the event that the UAS experiences any difficulties during flight instruction. Moreover, as required by the Skip TV ’s Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures provided for in Skip

TV ’s Operations Manuals ensure that the proposed UAS operations provide an equivalent or higher level of safety than that provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitu des

Skip TV requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 15 Section 91. 119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any pe rson, vessel, vehicle, or

structure in non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without

15 Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slugwear, Inc., dba Likeonatree Aerial (FAA

- 2014

- 0534 at 15).U.S Department of Transportation

September 1 4

, 2015 Page 17

hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed STV

- UAS operations will normally need to

o c cur below 400 feet AGL . In circumstances where the STV

- UAS is used to inspect a structure whose height exceeds 400 feet AGL, the STV

- UAS will not be operated more than 100 feet above the highest point on the structure, and within 50 feet horizontally of the structure.

Add i tiona lly, due the nature of the proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the STV

- UAS

.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights

pro posed herein, and given the lack of flammable fuel with the above noted UAS, any risk

a s sociated with these operations is far less than those which presently exist with conventional

ai r craft. An equivalent level of safety will be achieved given the size, w eight, and speed of the

STV

- UAS , as well as the controlled location where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below, or when inspecting a U.S. structure whose hei ght exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the STV

- UAS will be operated in a restricted area, and all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person is in a position where he or she is shielded from the STV

- UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights wi ll be terminated if a nonparticipating person within 500 feet of the STV

- UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timely has granted permissi on and the PIC has made a safety assessment of the risk of operating closer to those objects and, operations near the PIC or Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in Skip TV ’s Operations Manuals will en sure operations can be conducted without compromising public safety. 16

K. 14 C.F.R. § 91.121: Altimeter Settings

Skip TV seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight leve l by reference to an altimeter that is set to the

16 See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (F AA

- 2014

- 0481 at 19): "If ba r riers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection. The oper ator must also ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately. When conside r ing how

t o immediately cease operations, the primary concern is the safety of those nonparticipating persons. In add i tion, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment of the risk of operating closer to those objects and determines that it does not pr e sent an undue

haz ard."U.S Department of Transportation

September 1 4

, 2015 Page 18

elevation of the departure airport or barometric pressure. An exemption is required to the extent that the UAS do not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Sa

fety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 can be achieved in circumstances where: (1) the UAS will be operated below 400 feet AGL or

below 17 , (2) within VLOS, (3) where GPS based altitude informatio n is relayed in real time to the operator at a ground

- based on

- screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS. 18

The STV

- UAS that Skip TV intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Skip TV ’s Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior

FAA Section 333 Grants of Exemption, the STV

- UAS Skip TV intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level of safety or greater level will be achieved, and a Grant of Exemption to the requiremen ts of § 191.121 is therefore appropriate

.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Skip TV requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No per son may begin 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 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.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30

- minute battery res erve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, it is not Skip TV ’s intention to fly the STV

- UAS s at night.

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the F AA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a STV

- UAS flight unless (considering wind and forecast weather conditions) there was enough power to fly to the first intended point of landing and,

17 If the height of the structure being insp ected exceeds 400 feet AGL, the UAS will not be ope r ated more than 100 feet above the highest point on the structure.

18 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at 21).U.S Department of Transportation

September 1 4

, 2015 Page 19

assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the STV

- UAS provide approximately 50 minutes of powere d flight (with payload) and provided battery level and battery time remaining in minutes and seconds to the PIC. 19 The FAA also considered the fact the STV

- UAS operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, and

that in the event that the STV

- UAS should run low on power, the PIC will be alerted and can safely land the

- STV

- UAS as soon as possible. Like the VDOS Grant of Exemption, Skip TV ’s

use of the STV

- UAS , combined with the requirements of Petitioner's Op erations Manuals, ensure that an equivalent level of safety can be achieved and in fact exceeded

.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a flight with the UA unless (considering wind and forecast weather conditions), there was enough power to safely fly at normal cruising speed to the intended landing point an d land the UA with 25% battery power remaining. Skip TV will adhere to this limitation for its STV

- UAS flights.

The STV

- UAS includes a low battery warning system and the amount of battery reserve power remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from

the STV

- UAS to a ground

- based

- on

- screen display. 20 As required by Skip TV ’s Operations Manuals, the PIC will promptly fly the STV

- UAS back to the home launch location or pre

det ermined abort location where it may safely land, while still maintaining a minimum of 25% reserve battery power. Skip TV submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that flights only be condu cted within a secure, isolated area, using a UAS weighing less than 5 5 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent or higher level of safety to the public to that provided by the regulat ions from which exemption is sought

.

VI. DRUG AND ALCOHOL PROGRAM

Skip TV will have policies in place to ensure that no person may participate in STV

- UAS flight operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

T he public interest will be served by granting Skip TV ’s Petition for Exemption. Congress has established a national policy that favors early integration of UAS into the NAS in controlled, safe working environments such as those proposed in this Petition. G ranting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA

- 2014

- 0382 at 10).

20 The STV

- UAS ground control station displays, the UASs position, navigation route, tail number, altitude,

hea d ing, north seeking arrow, range to targets, calculated target position, date/time, and sens or heading and

orientation rel a tive to the UAS.U.S Department of Transportation

September 1 4

, 2015 Page 20

Act

— the FAA Administrator's assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily required r ulemaking.

The proposed STV

- UAS operations in this Petition for Exemption significantly improve s the safety and reduce s risk of harm, physical injury and property damage to the public at large, the property owners from whom permission was granted for use by Petitioner and abutting properties, staff of Petitioner, unsuspecti n g passersby, inspecting engineers from relevant organizations and all those who may be in the local vicinity . Traditional methods of inspecting

and monitoring potential filming location s and relevant sites and facilities requires location personnel to climb towers

, trees, venture onto precarious roofs and other dangerous scenarios

, perform elevated work for which the individual is neither trained n or equipped to perform , which exposes th em to unnecessary risk of serious physical injury from dangerous falls or other physical mishaps

. Moreover, inspectors/surv eyors are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations and other hazards as sociated with identifying specific locations for potential recording sites to be used in film or TV production. The use of small UASs can eliminate these hazards and ultimately creating a much safer method of performing these types of inspections creating a safer environment for the public as well as Skip TV employees.

The use of small UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands of pounds, carrying crew in addition to flammable

fue l, the UAS carry no passengers, crew or explosive fuel . Further more , in the unlikely event of an accident, Skip TV ’s small battery powered STV

- UAS presents significantly less danger to

persons on the ground when compared to operations by conventional manne d aircraft. 21 As

Petitioner's STV

- UAS are battery powered, the public will also benefit from a reduction in

harmful petroleum emissions associated with conventional aircraft performing in the same functions proposed herein. Air quality will naturally be im proved with the reduction of fuel powered vehicles.

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater de gree of flexibility, which supplements the current capabilities offered by manned

aircraft. 22 The quality of the finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide additional jobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created . The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibil ity of production ; therefore, given the lower cost,

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA

- 2014

- 0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to partici pating and nonparticipating individuals or property in the event of an incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming operation."

22 See e.g., Grant of Exempt ion No. 11178 to Picture Factory, Inc. (FAA

- 2014

- 0794 at 18).U.S Department of Transportation

September 1 4

, 2015 Page 21

owner/operators and others in the relevant industry will be more inclined to utilize the services of

commercial UAS along with a n appropriate licensed PIC’s

.

VIII. PRIVACY

All STV

- UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permissio n from land owner/controller or authorized representative will be obtained for each flight to be

conducted.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.1 19(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a ) ( 1); 91.409(a ) ( 1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed

- wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

Skip TV ’s Petition for Exemption satisfies the criteria articulated i n Section 333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation within VLOS and national security. The proposed STV

- UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. In consideration of the foregoing, this Petition for Exemption provides the

FAA with more t han adequate justification for granting the requested exemptions allowing Skip

TV to use small STV

- UAS in the recorded production of its product.U.S Department of Transportation

September 1 4

, 2015 Page 22

We thank you for your prompt consideration of our requested exemptions.

Respectfully Submitted,

Skip Fredericks Skip TV Productions

2700 Sandia Rd Palm Springs, CA 92262

Phone: 323

- 369

- 2584 Email: s.fredricks@yahoo.com

(The following attached items contain proprietary and commercial information exempt from

disclosure under the Freedom of Inf ormation Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments: 0. MPTOM Motion Picture and Television Operations Manual 1. General Operations Manual 2. PIC Operating Manual

3. Company Protocols

4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols

7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist 10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manu als