08/20/2015 3:28 AM FAX

September 10, 2015

Daniel Zatz ZatzWorks 

## Inc. 178 

### E. Bunnell Avenue Suite 

### A Homer, AK 99603 907-299-1885 (cell)**Daniel@~-~-t.zwoxks.&QID** 

### (email)

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE 

### Room W12-140, West Building Ground Floor Washington 

### DC 20590 202-493-2251 (Fax)

Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 9l.9(b)(2); 14 

### CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c): 14 CFR 91.121; 14 CFR 91.151(b); 14 CFR 91.203 (a) and 

### (b); 14 CFR 91.405 

### (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14

### CFR 91.417(a) and (b).

To whom itmay concern:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "ReformAct") and 14 CFR Part 11, Zat'.lWorks, operator ofSmall Unmanned aircraft Systems ('"sUA"), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUA, so long as such operations arc conducted within and under the conditions outlined herein or as my be established by the FAA as required by Section 333.

Commercial operation 

### sUA, as described herein, which are equipped with cameras and sensors, would operate in the following manner:



### 1. Aerial photography andforvideo for public andfor private usc including real estate, architecture, land surveying, engineering and other**relatE~d** professional activities. 2. Aerial video and/or photography for public andfor private**us~~** including television, public events, cinematographyand news gathering. 3. Aerial inspection/photography ofresidential/commercial**~.-tructures** under contractwiththe owners orlocal government authority. 4. Aerial video/photography or providing live video feed to assistwith search and

rescue operations in cases ofan emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 

### 141 0001/000908/20/2015 3:28 AM FAX

5. The ability to offer training to personsindividually orbelongingto both private and/orpublic organizations that have interests in 

### the use and application ofsUA for the purpose ofthe safe operation ofsUA to enhance the safety ofthe National · 

### Airspace System (NAS) as well as for the 

### protection ofthe 

### persons and property.

As described fully below, the requested exemption would permit the operation of sUA undercontrolled conditions in the 

### NAS thatwould be a) limited b) controlled c) predetermined and d) 

### will provide safety enhancements to the already safe operations in the industrypresentlyusing conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "

....est."lblish requirements for the safe operation ofsuch aircraft systems in the national airspace system."

The name and address ofthe applicant is: Attn: Daniel Zatz ZatzWorks 178 E. BunnellAvenue Homer, AK 99603 907M299-1885 (cell)**JlML~@z.atzworks.co_.r:n,** (email)
Regulations from which the exemption is requested: 14 CFR Part 21 subpartH 141 0002/0009

14 

### CFR 45.23 

### (b) 14 CFR 61.113 (a) 14 CFR 91.7 

### (a) 14 CFR 91.9 (b) (2) 14CPR 91.103 14

### C.fo'R 91.109 14 CFR 91.119 (c) 14CPR 91.121 14CFR 91.151 (b) 14

### CFR 91.203 (a) 

### &(b) 14 CFR 91.405 (a) 

### 14 CFR 91.407 (a) (1) 14

### CPR 91.409 (a) 

### (2) 14 CPR 91.417 (a) 

### & 

### (b)
My DJI Inspire 1 sUA is a multi-rotorcraftweighing 7.5 lbs. includingpayload. Under normal conditions it operates at a maximum speed of4 7 knots and has the ability hover and move along a vertical and horizontal plane simultaneously.ltwill operate only during daylight and in line ofsightand 

### will operate within a closed offand predetermined area owned andjoperated bythe property representative.

1am in the process ofregisteringmy DJI Inspire 1 as N19ZW.08/20/2015 3:28 AM FAX

Given the small sb;e ofthe sUA and the controlled environment provided the proposed operations will adhere to the Reform Act's safetyrequirements. The approval 

### ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit. reduction in environmental impacts, including but not limited to reduced emissions and noise, 

### the grant ofthe requested exemption is in the public interest.Accordingly the applicantrequests that the FAA grant the requested exemption with minimum delay.



### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalentor higherlevel ofsafety because operationswill further enhance the safety ofthe persons and/orproperty using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the 

### FAA issued exemption as setforth in the User' include:

1.The sUA will weigh less than 

### 55 lbs. 

### 2. Flights will be operated within line ofsight of

### a pilot and/or observer. 3. Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 

### 25o/o batterypower reserve or 

### 20 minut.es offlight time whichever

occurs first. 4. Flights will be operated atan altitude ofno more than 400 feet above ground level (AGL) and notmore than 200 feet above an elevated platform from which filming is planned. S. Minimum crewfor each operation will consistofthe sUA Pilot, the Visual Observer (VO) and mayinclude but not limitedto a Camera Operator. 6. The sUA pilotwill be a designated Pilot in Command (PIC) and hold 

### a current Third orhigher Class Medical Certificate, along with a valid state driver's license. 

### If the 

### PIC feels another operatorto be qualified with the necessary skills to be PIC & possess 

### aThird orhigher Class Medical and 

### a valid state**driver'~** license, thatperson may

### be designated PIC provided they have a minimum of20 hours offlight time with the sUA. 

### 7. Abriefing willbe performed regarding the planned sUA operations priorto each day's flight consisting ofall the days' production activities. 8. The operator

### will file FAA Form 7711·1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 9. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure thatonly consentingpersons will be allowed within 

### 100 

### feet ofthe flight operation, and the radius maybe reduced to 

### 30 feet based upon
an equivalent level ofsafety determination, as required inthe User's Manual. With

. the advanced permission ofthe FSDO, operations at closerrange may be approved. 

### Ill 0003/000908/20/2015 3:28AM FAX

10. The PIC and VO will have been trained in operation ofsUA and receive up-todate information for the particular sUA to be operated. 11. The PIC and VO will be able to communicate byvoice, radio, and/ortext at all. 

### times. 12. Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies. 13. Ifthe sUA loses communications or loses GPS signal, the sUA 

### will have the capability to return to a pre-determined location within a design<lted location and land autonomously. 14. The sUA 

### will have the capability to abort a flight in case ofunpredictcd obstacles, weather, or emergencies. 15. The Safety Guidelines manual for the Inspire 1 

### will be followed by the operator.



### 14C.F.R. Part 21, Subpart H: Ail"Worthiness Certificates 14 C

.. F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the si1.e and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exemptaircraft from the requirement for

an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability. and proximity to airports and populated areas ofthe particularsUA. In all cases. an analysis ofthese criteria demonstrates that the sUA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at leastas safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUA to be operated hereunder is less than 55 lbs. fully loaded. carries neithera pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike othercivil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in c:omplio.:mce with local public safely requirements. The FAA will have advance notice ofall operations. These safety enhancements provide a greater degree ofsafety to the public and property owners than convenlional operations conducted with**~irworthiness** certificates issued under 14 C.f".R. Part 21, Subpart H. Lastly, application ofthese

same criteria demonstrates that there is no credible threat to national security posed bythe sUA, due to its size, speed ofoperation, location ofoperation, lack of explosive materials orflammable liquid fuels, and inability to carry a substantial external load. 

### 141 0004/000908/20/2015 3:29 AM FAX



### 14C.F.R. §45.23 

### (b). MarkingoftheAircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number 

### is displayed on

### limited, restricted orlight-sport

### category aircraft or

### experimental or provisionallycertificated aircraft, the operator must also display on that aircraft

near each entrance to the cabin. cockpit. orpilot station, in letters notless than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the sUA will have no airworthiness certificate, an exemption maybe needed as the sUA will have no entranceto the cabin, cockpit orpilot station on which the word "Experimental" can be placed. Given t:he size ofthe sUA, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (t).

The equivalent level ofsafety will be provided by having the sUA marked on its fuselage as required by

### §45.29 (f) where the pilot, observer and others working with the sUA 

### will sec::: the identification ofthe sUA as HExperirnental.H



### 14

### C.F.R. § 

### 61.113 (a):Private Pilot Privilegesand Limitations: Pilotin 

### Command. Pursuantto 14 CFR 61.113 (a), no person who holds a private pilot certificate may

.act as a pilot in command ofan aircraft thatis carrying passengers or propertyfor compensation or hire. Our sUA does notcarry any pilots orpassengers norproperty therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot's license will not ensure remote control piloting skills. The risks attendant to the operation ofsUA is far less than the risk levels inherentin the commercial activities outlined in 14 CFR 61. I feel the operation and limitations setforth in the User Manual will equate to the safe operation ofthe sUA.



### 14C.F.R. §91.7(a): Civil Aircraft:Airworthiness. The regulation requires that no person may operate a civil aircraft unless itis in airworthy condition.As there will be no airworthiness certificate issued for the aircraft, should this exemption 

### be granted, no FAA regulatory standard

### will exist for determining airworthiness. Given the size ofthe aircraft for maintenance and use of safety check lists prior to each flight an equivalentlevel ofsafetywill be provided.



### 14C.F.R. 

### § 91.9 (b) (2): Civil AircraftFlightManual in theAircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) Forwhich an Airplane orRotorcraftFlight Manual is not required by 

### §21.5 of this chapter, unless there is available in the aircraft a currentapproved airplane or Rotofcraft Flight Manual, approved manual material, markings. and placards. or any combination thereof. The sUA, given its size and configuration has no ability orplace to carry such a flight manual on the aircraft, not only because there is no pilot on board, butbecause there is no room or capacity to carry such an item on the aircraft 

### 141 0005/000908/20/2015 3:29 AM FAX



### The equivalent level ofsafety will be maintained 

### by keeping the flight manual atthe ground control point where the pilot flying the sUA will have immediate access to 

### it.



### 14

### C.F.R. § 91.103: 

### PreflightAction. This regulation requires each pilot in command to take certain actions before flight to ensure the safety offlight As 

### FAA approved**rotorcr;;~ft** 

### flight manuals will 

### notbe provided for the aircraft an exemption will be needed. The PIC 

### wHl take all actions including reviewing weather, flight battery requirements, landing andtakeoff distances and aircraft performance data before initiation offlight.

14 C.F.R. §91.109: Flight Instruction. 

### Section 91.103 provides that no person may operate a civil aircraft (excepta manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls. sUA and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the

usc ofa control box thatcommunicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraftand by the size and speed ofthe aircraft.



### 14

### C.F.R. §91.119: 

### Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil air,craft. Section 91.119 

### (d) allows helicopters to be operated atless than the minimums prescribed. provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters 

### by the FAA. As this exemption is for a sUA that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned. an exemption may be needed to allow such operations. As setforth herein, the sUA will never operate athigher than 400 AGL with the exception that in circumstances where the sUA is used to survey orphotograph a structurewhose height exceeds 400 

### feetAGL. the sUA 

### will notbe operated more than 100' 

### above the highest point on the structure. ll

### will however be operated in a restricted area with security perimeter, where buildings and people will notbe exposed to operations without their pre-obtained consent.

The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUA as well as the location where itis operated. No flight will be taken withoutthe permission ofthe property owner orlocal officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum SSlbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operarjng at or below 500 AGL. In addition, the low-altitude operations ofthe sUA 

### will ensure separation 141 0006/0009OB/20/2015 3:29 AM FAX



### between these small- UAS operations and the operations ofconventic>nal aircraft that must comply with Section 91.119.



### 14C.F.R. §91.121AltimeterSettings. This regulation requires each person operating 

### an aircraftto maintain cruising altitude by reference to an altimeter thatis set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure."

### As the sUA may nothave 

### a barometric altimeter, but instead a GPS 

### altitude read out. an exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuantto the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight



### 14

### C.F.R. § 

### 91.151(b): 

### Fuel Requirements for 

### Flight in VFR C<l,nditions Section 91.151 (b) prohibits an individual from beginning "(b) No person may begin

a flight in a rotorcraft underVFR conditions unless (considering wind and forecast weatherconditions) there is enough fuel to fly 

### to the first pointofintended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes."

The batterypowering the sUA provides approximately 20 minutes ofpowered fllght. To meetthe 20-minutc reserve requirement in 14 CFR §91.151, sUA flights would be limited to approximately 0 minutes in length. Given the limitations on the sUA's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ortwilight VFR conditions is reasonable.
Applicant believes thatan exemption from 14 CFR §91.151(b) fa:tls within the scope ofprior exemptions. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 20 minutes ofreserve fuel, does not constitute the type ofrisks that Section 91.151(b) was intended to alleviate given the size and speed ofthe small UAS. Applicant believes that an equivalent lev•el ofsafetycan be achieved by limiting flights to 20 minutes or 25% ofbatterypower- whichever happens first. This restriction would be more than adequate to**r·~turn** 

### the sUA to its planned landing zone from anywhere in its limited operating area.

14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part:
(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it 

### has within itthe 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 ofthe applicable operations specifications issued under §21.197(c) ofthis 

### Ill 0007/0009**U~/ZU/ZU15** 

### 3:29 AM FAX

chapter, appropriate sections ofthc air carrier manual required by parts 121 and 135 

### ofthis chaptercontaining thatportion ofthe operations specifications issued under §21.197(c). or an authorization under 

### §91.611) musthave on it 

### the 

### registration number assigned to the 

### aircraft under part 4 7 of

### this chapter. However, the airworthiness certificate need not have on it an assigned special identification numberbefore 10 days after that number is first affixed to the aircraftArevised airworthiness certificate having on itan assigned special identification number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section ora special flight authorization issued under §91.715 

### is displayed atthe cabin or cockpit entrance so thatitis legible to passengers orcrew.

The sUA fully loaded weighs no more than 55 lbs. and is operated without an
onboard pilotAs such, there is no ability or place to carry certification and registration documents orto display them on the sUA.

An equivalent level ofsafety will be achieved by 

### keeping these documents atthe ground control pointwhere the pilot flying the sUA will have immediate access to them, to the extentthey are applicable to the sUA.



### 14C.F.R. §91.405 (a); 

### 407 (a) (1); 409 (a) (2); 417(a) & 

### (b): Maintenance Inspections. These regulations require thatan aircraft operator or owner "shall have that aircraft inspected as prescribed in subpartEofthis partand shall betwe·en required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43.

Given thatthese section and Part 43 

### apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by 

### the operator in accordance with the flight mam.1al and operating handbook. An equivalent level ofsafety will be achieved because these small sUAs

are very limited in size and will carry a small payload and operate only in restricted

areas for limited periods oftime. 

### Ifmechanical issues arise the sUA can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the sUA is in working orderpriorto initiating flight. perform required maintenance, and keep a log of

### any maintenance**perfo~rmed.** 

### Moreover, the operatoris the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condilion to provide the equivalentlevel ofsafety.

An equivalent level of

### safety 

### will be achieved because maintenance and inspections will be performed in accordance with the sUA Maintenance Manual. The operator 141 0008/0009UG/ZU/ZU15 J:29 AM FAX



### will ensure that the sUA is in working order as per the User Manual, priorto initiating flight and perform required maintenance needed.



### Additional Information Daniel Zatz, the 

### ownerofZatzWorks, is a 25 year Alaskan with roots in the Southern California broadcast market working in LA and San Diego. He has four Ernmy Awards and clients include BBC Natural History, an array ofDiscovery and National Geographic series, The History Channel, 

### NHK, CBC, German television, and commercial clients like Smuggler, AeroFilm, etc. He's filmed in every corner of Alaska and has more than 3000 hours ofaerial Cineflex® filming in the state- more than any otheroperatorin the world. Jn addition to operating the Cineflex, Zatz founded and led an Alaska-based robotics company and he provides regular technical supportto Cineflex owners throughout the world. He is also an FAA licensed fixed wing and helicopter Private Pilot 

### (#3282151)- giving him a good understanding ofthe challenges operating sUAs 

### could presentto othertypes of aircraft 

### ifnotresponsibly operated within the boundaries ofFAA regulation. He holds a third class medical certificate and a currentAlaska Driver's License 

### (#6501521).

Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide

more than adequatejustification for the grant ofthe requested exemptions allowing the commercial operation ofthe applicant's sUA. 

### 141 0009/0009