November 13, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Re

form Act”) and 14 C.F.R. Part 11, Home Course Aerials , an operator of Unmanned Air

craft Systems (“UAS”) for producing high-definition aerials videos/cinematography for golf courses, golf clubs and private country clubs, hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS platforms. Home Course Aerials(HCA) requested exemption would permit the operation of small, unmanned UAS under controlled conditions in airspace that is: (1) limited, (2) predetermined, (3) subject to controlled access, and (4) provide greater safety in connection with aircraft operations in the outdoor film and television industry. As es

tablished by the exemptions already granted by the FAA, approval of Home Course Aerials exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to establish requirements for the safe opera

tion of such aircraft systems in the national airspace system. Section 333 © of the Re

form act. 

## HOME COURSE AERIALS

215-221-4340 padzeke@me.com 2003 Grace Lane Flourtown, PA 19031

### Benefits of UAS

HCA is owned by Paul Pizzica, and is the operator and current owner of a Phan

tom Vision2 Plus, Phantom 3, and DJI Inspire 1. I have been flying at least one of these UASs for 24 months now without incident as a hobbyist, and have kept detailed flight logs for each flight. The services provided by HCA would mainly serve golf clubs in the golf association of Philadelphia and surrounding area, and would provide an economical benefit to its members and member clubs. As this area is rich in golf his

tory, HCA services of high-definition overhead aerials videos through the use of a sUAS would provide each golf course and their owners with videos for golf course historical preservation use, as well as for marketing use for their current and prospec

tive members. Aerial footage of golf course holes can provide competitive golfers an awareness of or knowledge of the course before playing , as well as giving respective greenskeepers visuals of their home golf courses for maintenance purposes. HCA services are a safe, low cost, and effective solutions to obtaining these aerials videos without the use of a helicopter or manned aircraft with fuel and persons on board. Further safety is ensured as all flights will be conducted over privately held property, with very few or no structures and nonparticipating persons around during flights. The desired shots or video captured for these purposes is envisioned with no persons visible in the camera frame.

This application is submitted by:
Home Course Aerials Owner: Paul Pizzica 215-221-4340 padzeke@me.com 2003 Grace Lane, Flourtown, PA 19031Regulations from which the exemption is requested:
14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) HCA UASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will op

erate only in line of sight and will operate only after all safety protocols and preflight checks have been completed. Given the small size of the UASs involved and the restricted controlled environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by ex

emption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant UASs will oper

ate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Avi

ation Act, as amended; the strong equivalent level of safety surrounding the pro

posed operations, and the significant public benefit, including enhanced safety, re

duction in environmental impacts, including reduced emissions associated with allow

ing UASs for movie and television operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption. The substance of this request is essentially the same as granted to Mile Sky Produc

tions LLC, Regulatory Docket No. FAA-2015-0612, and Thomas Goodall, Regulatory Docket No. FAA-2015-1333.AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limi

tations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe filming operations conducted with conven

tional aircraft. These limitations and conditions to which HCA agrees to be bound when conducting commercial operations under an FAA issued exemption include:
1. The UAS will weigh less than 55 lbs including payload(camera, etc) - UASs for this exemption include DJI Phantom2 Vision Plus (2.74l bs), Phantom 3(2.82 lbs) and DJI Inspire 1 (6.47 lbs).
2. Flights will be operated within visual line of sight of a pilot.
3. Flights will be operated at an altitude of no more than 400 feet AGL.
4. The UASs will not exceed speeds of 15m/s(30 knots).
5. Minimum crew for each operation will consist of the UAS Pilot, and a Visual Ob

server. 6. Observer and pilot will at all times be able to communicate by voice.
7. UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the UAS Pilot, who possess the necessary PIC qualifications, is also present, that per

son can also be designated as PIC.
8. UAS flights will not be conducted at night.
9. The UAS will not operate within 5 miles of an any airport, unless a letter of agreement is obtained from that airport’s management, or an additional COA is issued. The letter of agreement or additional COA will carried by PIC during all operations and flights.
10. If the UAS loses communications or loses its GPS signal, the UAS will have capa

bility to return to a pre-determined location within the Security Perimeter and land.
11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.12. Any flights will be prohibited from beginning if there is insufficient power avail

able for the UAS to operate for at least 5 minutes or with the reserve power rec

ommended by the manufacturer if greater.
13. All flights will be conducted on private property with written or oral permission granted by the relevant property owners
14. All flights will be conducted at least 500 feet from all nonparticipating persons, vehicles or structures, unless said owners of any of those vehicles or structures has granted permission to fly closer to them.
15. All flight accidents will be reported to the FAA’s UAS Integration Office with 24 hours.
16. Additionally, for our operations, we have a Standard Operations Procedure before each flight. This SOP will provide for the level of safety as required for this exemp

tion request, as well as a pre-flight checklist that is listed in each of the manuals for the Phantom2 Vision Plus, Phantom 3 and Inspire 1. This SOP will be communicat

ed between PIC and VOS before each flight operation.

• determine if area of flight is in a non-flight zone specified by local laws and regulations

• first observe the flight area for any mobile phone base stations, radio transmission towers, power lines or any other electromagnetic interfer

ence that could disrupt flight

• check weather conditions, not flying in winds speeds in excess of 10m/s, snow or rain

• check the UA and battery performance are subject to safe air density and temperature

• check that remote controller, wifi transmission range extender, aircraft batteries and mobile devices are fully charged

• place aircraft on open, flat ground with battery indicator facing toward pilot

• propellers are mounted correctly and firmly, as is camera and gimbal

• power on the remote controller, wifi transmission range extender and mobile device, followed by the Intelligent Flight Battery• check that the DJI camera app(either Vision and Pilot) can connect to air

craft and video transmission is being sent and received, and the proper camera settings for each particular flight are set

• mobile phones(primary and backup) have cell service to access maps apps for GPS waypoint plotting and auto-piloting, or by previously caching maps

• camera and gimbal are are operational

• wait until aircraft indicator turns green, recording a Home Point via GPS

• calibrate the compass flight location(according to manuals), maintaining a good distance from all electromagnetic sources of interference in do

ing so

• start motors, checking that they are fully functional

• set waypoints with DJI camera app with desired height(never above 400” AGL) and speed(never over 15m/s)

• begin takeoff and flight, shooting video and still photos using the DJI camera app

• initiate a return to home through the DJI camera app, or toggle remote switch to gain control of aircraft if in waypoint plotting auto-pilot

• land over a level flat surface by gently pulling down on the throttle slowly to descend, as per training, and then holding throttle at its lowest posi

tion for 3 seconds or until motors stop

• turn off the Intelligent Flight Battery, followed by the remote controller and/or range extender

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural require

ments 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 anequivalent level of safety under Part 11 and Section 333 of the Reform Act. The Fed

eral Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both autho

rize 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 air

worthiness certificate without the restrictions and conditions proposed. There is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

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 pro

visionally 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," "experimen

tal," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAV, two-inch let

tering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAV marked on its fuse

lage as required by §45.29 (f) where the pilot, observer and others working with the UAV 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.14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to non-commercial operations

. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the air

craft to have a private pilot’s license rather than a commercial pilot’s license to oper

ate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements and limita

tions by the manufacturer of this UAS exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the UAS are so diminished from the level of risk as

sociated with commercial operations contemplated by Part 61 when drafted, that al

lowing operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.7(a): Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless it is in airwor

thy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determin

ing airworthiness. Given the size of the aircraft and the requirements for maintenance and use of safety check lists prior to each flight as recommended by the manufactur

er, an equivalent level of safety will be provided. 14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft. (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotor

craft Flight Manual, approved manual material, markings, and placards, or any combi

nation thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. 91.103: Preflight action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be pro

vided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the Manual. The PIC will take all actions including review

ing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 C.F.R. 91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully func

tioning dual controls. UASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that commu

nicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less 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 UAS 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 set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It will how

-ever be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in Section K of the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional air

craft operating at or below 500 AGL in the movie industry. In addition, the low-altitude operations of the UAS will ensure separation between these small- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. 91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane un

der 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 cruis

ing 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.” The battery powering the UAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s pro

posed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tight

ly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.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 it the following: (1) An appropriate and current airworthiness 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. The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration docu

ments or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. The FAA has issued numerous ex

emptions to this regulation. A representative sample of other exceptions includes Ex

emption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspec

tions, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the air

craft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certifi

cate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in re

stricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator 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.
*********

Sincerely,

Paul Pizzica
Home Course Aerials