airborne cams

ACExemptionRequest August 10, 2015 1 August 10, 2015 Ari Cheren Airborne Cams, LLC 11767 W. Sunset Blvd, suite 206 Los Angeles, CA 90049 ( 310) 948

- 3042 acheren@gmail.com

**Petition of Airborne Cams, LLC**  **For Exemption Pursuant to Section 333 Of the FAA Modernization and Reform Act of 2012** 

To Whom It May Concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Airborne Cams , LLC ( AC ), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial oper ations of small unmanned aerial system ( i.e. , sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, and any other requirements established by the FAA pursuant to Section 333 of the Reform Act. This exemption would permit commercial operation by AC, which uses DJI Phantom 2, DJI Phantom 3, Inspire 1, and S900 to conduct sUAS flight training, education, real estate photography, and videography, film and movie production (including closed set filming) , and demonstrati on flights. AC’s operation under the exemption will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the F AA as required by Section 333.
AC will be operated under controlled VFR conditions at low altitude in airspace that is permitted in accordance with AC’s approved Certificate of Authorization (COA). They will operate the sUAS’s with pilots who have compreh ensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements. Finally, the FAA ATC will approve the airspace in which the sUAS will operate in advance. Airborne Cams respectfully submits this requ est for an exemption because it operates sUAS's. The FAA can have confidence that the operations will be conducted at an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill theairborne cams

ACExemptionRequest August 10, 2015 2 Secretary of Trans portation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.” For your convenience, AC has organized this Exemptio n request as follows:
I. Petitioner's Description II. Relevant Statutory Authority III. Qualifications for Approval Under Section 333 of the Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested VI. Public Interest VII. Privacy VIII. Fed eral Registry Summary IX. Conclusion **I. Petitioner's Description:** Airborne Cams , headquartered in Los Angeles, California, is a company that provides sUAS support to news services, real estate photography, film and television production, education, and demo nstration flights in a compliant and safe environment. AC plans on providing a wide range of services as the sUAS market expands.
AC 's goal is to operate in an accident

-free environment by:

 Demonstrating a commitment by management and all employees to op erate in a compliant manner.

 Identify hazard s and risk while eliminating or controlling all these risks .  Using steps to intervene and report when unsafe work practices appear to exist.

 Train ing all employees involved in flight operations to operate at the highest standard level.
The contact information for Petitioner is as follows:
Airborne Cams 11767 W. Sunset Blvd., suite 206 Los Angeles, CA 90049 Member Managers: Ari Cheren Phone : ( 310) 948

- 3042 Email: acheren@gmail.com **II. Relevant Statutory Au thority:**  This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate theairborne cams

ACExemptionRequest August 10, 2015 3 integration of civil unmanned aircraft systems into the national a irspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the foll owing 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.1 If the Secretary deter mines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System". Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 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 would provide a level of safety at least equal to the existing rules). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its term s, includes exempting civil aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commerc ial service: **The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections.**  **III. Qualifications for Approval Under Section 333 of the Reform Act** The proposed operati ons in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The proposed operations would permit AC the use of small UAS under controlled c onditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

1 AC’s submission places a d uty on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation o f the sUAS. AC welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require modification.airborne cams

ACExemptionRequest August 10, 2015 4 AC uses UASs that are multirotor, weighing less than 25 pounds including payload. They operate, under normal conditions, at speeds not to exceed 45 mph and have the capability to hover, and move in the vertical and horizontal plane. AC’s UASs will operate in line of sight, during daylight hours, and will only operate within a sterile area. AC will operate at or below 400 feet AGL and will file a NOTAM for each flight operated in controlled airspace. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS. Given the small size of the sUAS’s involved and the restricted sterile environment within which they will operate, this AC’s exemption falls within the zone of safety and demonstrate an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will o perate, approval of the application presents no hazard in the NAS. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed o perations, and the significant public benefit, the grant of the requested exemptions is also in the public interest. **IV. Description of Proposed Operations** To assist the FAA in its safety assessment of AC 's proposed sUAS operations, below is a summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:
1. The sUAS will weigh less than 25 pounds. 2. Flights will be operated within line of sight of the PI C and observer. 3. Maximum total flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 25%. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advance of the operation. 6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual Observer. Additional crewmembers consist of a Pilot and a Camera Operator. 7. The sUAS Pilot in Command will have undergone comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements. 8. AC will designate a Pilot in Command ("PIC") for each mission. 9. The sUAS will operate only within a confined "Sterile Area".airborne cams

ACExemptionRequest August 10, 2015 5 10. Prior to the operations at a particular location, a site inspect ion will have been conducted. On the day of the mission the management person with operational control and the PIC will concur on dispatching of the mission. 11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's mission s. It will be mandatory that all personnel who will be performing duties within the boundaries of the sterile area be present for this briefing. 12. AC crew will use the checklist and callouts required in the Operations Manual. 13. All sUAS’s will be maintained in accordance with inspection program specified in the manufa cturer’s guidelines. 14. In the event of an accident involving an AC sUAS, they will cease operations and report the a ccident to the NTSB and AFS

- 80. 15. Pilot in Command and Visual Observer will at all times b e able to communicate by voice. 16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will have been trained and tested in accordance to FAA, N TSB, and AFS

- 80 best practices. 17. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other app ropriate governmental agencies. 18. AC management will submit a written “Plan of Activities” to the local Flight Standards District Office (FSD O) having jurisdiction over the area of proposed filming three days in advanced of operations du ring film or movie productions. 19. If the sUAS loses communications signal, the sUAS will have the capability to return to a pre - determined location wi thin the Ste rile Area and land. 20. Contingency plans will be in place to safely terminate flight if there is a loss of communication betw een the pilot and the observer. 21. The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergencies. 22. AC, by following FAA, NTSB, and AFS

- 80 best practices, will assure no individuals’ privacy is violated. 23. Procedures have been established in AC’s Operations Manual to contact ATC prior to operating in airspace other than G.
**V. Regulations From Which Exemption**  **is Requested**
**A 14 CFR § 91.103: Preflight Action**  **B 14 CFR § 91.113: Right** 
**- of** 
**- Way Rules**  **C 14 CFR § 91.119 (c): Minimum Safe Altitudes**  **D 14 CFR § 91.121: Altimeter Settings**  **E 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions**  **F 14 CFR § 91.405(a)**  **, 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance**  **Inspections G**  **14 CFR § 91.203: Airworthiness Certificate H**  **H. 14 C.F.R. § 45.23 (b). Marking of the Aircraft** airborne cams

ACExemptionRequest August 10, 2015 6 **A. 14 CFR § 91.103: Preflight Action** 
AC requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions under which aircraft may operate: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

a. Flight under I FR 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. Fo r any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:
i. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, t he takeoff and landing distance data contained therein; and
ii. For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values o f airport elevation and runway slope, aircraft gross weight, and wind and temperature.
AC will not operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. DJI’s sUAS’s do not have published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data. **Equivalent Level of Safety** In adherence to FAA, NTSB, and AFS

- 80 best practices, the PIC along with the person having operational control must follow to assure t hat the weather will be adequate to complete the mission in VFR condition. Since AC operates in California where the density altitude is never usually above 2000 feet, UAS performance is not affected. When AC is allowed to operate in other parts of the Uni ted States the UAS used in those locations will be test flown at gross weight to test performance limitations prior to conducting commercial operations. **B. 14 CFR 91.113: Right**
**- of** 
**- Way Rules**  AC request an exemption from 14 CFR 91.113 Right

- of

- way rules, r equiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

- way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unles s well clear. Airborne Cams operates small pilotless UAS’s and cannot comply with these rules as they have been written.airborne cams

ACExemptionRequest August 10, 2015 7 **Equivalent Level of Safety** AC operates sUAS’s at or below an altitude of 400 feet AGL, well below the normal operating altitude of other aircraft. AC management require that a Pilot in Command with experience will oversee each mission and has knowledge of the avoid rules. A Visual Observer will assist the PIC in looking for aircraft entering the operations area. It’s the responsibility of the PIC to cease operations and land the UAS immediately whenever and aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until the threat is clear. **C. 14 CFR. § 91.119: Minimum Safe Altitudes** AC requests an exe mption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may operate:

 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.

 Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircra ft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without 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." To provide the intended operations, the sUAS is normally operated below 400 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation.
**Equivalent Level of Safety** Compared to flight normal aircraft, AC’s multi

- rotor aircraft weigh a maximum of 25 pounds, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level o f safety will be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As set forth in the FAA, NTSB, and AFS

- 80 best practices, the sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

obtained consent. Because of the advance notice to the property owners and participants, all affected individuals will be well aware of the planned flight operations prior to commencement of operations. Further more, by operating at such lower altitudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments.airborne cams

ACExemptionRequest August 10, 2015 8 **D. 14 C.F.R. § 91.121: Altimeter Settings** AC seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimete r that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the sUAS does not have a barometric altimeter, but rather a GPS altitude read out. **Equivalent Level of Safety** An equivalent level of safety w ill be achieved by following the procedures set forth in the FAA, NTSB, and AFS

- 80 best practices. AC will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to c onstantly monitor the sUAS's height, thus ensuring operation at safe altitudes. **E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions** AC requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: a. No person 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

– i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes. The batteries powering AC’s UAS’s provide approximately 10

- 25 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91. 151, sUAS flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve amount of battery life is needed. AC will not be conducting any sUAS flights at night. **Equivalent Level of Safety** An equivalent level of safety will be achieved because the operations will be conducted on

- site without significant transit time by the sUAS. All flights will be planned to terminate with n o less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to its planned landing zone from anywhere in its confined area of operation even in the event of an unexpected occurrence. Operati on of the sUAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed. **F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections** AC al so seeks an exemption from the maintenance inspection requirements contained in 14airborne cams

ACExemptionRequest August 10, 2015 9 CFR 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 CFR Part 43. 14 CFR 91.405( a) (stating that each owner or operator of an aircraft "shall 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 to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have. **Equivalent Level of Safety** An equivalent level of safety will be achieved because maintenance and i nspections will be performed in accordance with FAA, NTSB, and AFS

- 80 best practices. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The oper ator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight op erations will only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation.
**G. 14 C.F.R. Part 21, Subpart H: Airworthiness Certific**  **ates 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 o f the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. **Equivalent Level of Safety** The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. Thes e safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to the public and property owners thanairborne cams

ACExemptionRequest August 10, 2015 10 conventional operations conducted with airworthines s certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of ex plosive materials or flammable liquid fuels, and inability to carry a substantial external load. **H. 14 C.F.R. § 45.23 (b). Marking of the Aircraft**  The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

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

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

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). **Equivalent Level of Safety**  The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

**VI. PUBLIC INTEREST** Granting Airborne Cams an exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. The one vision of AC is to help facilitate safe integration of sUAS’s into mainstream USA in the following areas:

• **Movies and Videography**

 Whet her the shot requires unique views and expansive panning or extreme altitude with radical views, the UAS is designed to hold up under demanding conditions. Because of the autopilot feature with pre

- designed mission management and R/C control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD still photos. When working close in on a closed set the hazards to the actors are greatly reduced due to the size of the sUAS.

• **News Gathering**

 Similar to movies and videog raphy, each news assignment may require a completely different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the UAS is the perfect solution to allow for easy news gathering forairborne cams

ACExemptionRequest August 10, 2015 11

a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, while the traditional helicopter must hover over persons and property increasing the danger to individuals.

• **Real Estate**

 The sUAS can be used in all areas of real estate, including commerc ial, residential and industrial properties. Using a sUAS, real estate professionals can create promotional videos, photos and unique shots that normal camera aspects cannot capture. AC’s easy

-to

- use video and photo platform enables properties to stand out, providing dazzling views that are typically shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high

- rise condo in stunning high definition that shows your potential customer the actual view from the residen ce. The remote platform is great for new planning, zoning and large developments. Simple and easy

-to

- use video and photos allow for multiple height pictures and elevation views. **VII. Privacy** Airborne Cams is deeply committed to protecting public privacy. AC knows that many individual have concerns about privacy from the operations of sUAS’s. AC has created a privacy notice that informs residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commerc ial drone operations in proximity to their property. **VIII. Federal Registry Summary** Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Airborne Cams seeks an exemption from the following rules: 14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b). Approval of this exemption request allows AC to c onduct commercial operations with small and lightweight unmanned aerial systems. AC’s singular vision is to enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners. The DJI sUAS, weighing less than 25 pou nds and powered by batteries, eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on bard. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant fr om the requirements of several regulations and allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far saferairborne cams

ACExemptionRequest August 10, 2015 12 than conventional aerial survey and inspectio n operations conducted with fixed wing aircraft or helicopters. If additional information is required, or if you have any questions regarding this Petition for Exemption, please contact the undersigned at: With Best Regards, Ari Cheren, owner Airborne C ams, LLC Office: ( 310) 948

- 3042 Email: acheren@gmail.com

**IX. Conclusion** For the foregoing reasons, it is requested that the regulatory exemptions requested herein be respectfully granted, and the Petitioner be permitted to conduct small UAS operations a forementioned purposes.