### FROM: Adam Hall

Rainbow Bridge Media , LLC

. 46

- 039 Lilipuna Road Kaneohe, HI 96744

TO: Federal Aviation Administration US Department of Transportation Docket Management System 1200 New Jersey Ave. S.E Washington, DC . 20590

October 23 , 2015 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR Part 21 subpart H , 14 CFR 45.23 (b) , 14 CFR 61.23 (a) , 14 CFR 61.113 (a) & (b) , 14 CFR 61.315(a) , 14 CFR 91.7 (a) , 14 CFR 91.9 (b) (2) , 14 CFR 91.103 , 14 CFR 91.109 , 14 CFR 91.119 (c) , 14 CFR 91.121 , 14 CFR 91.151 (a) & (b) , 14 CFR 91.203 (a) & (b) , 14 CFR 91.405 (a) , 14 CFR 91.407 (a) (1) , 14 CFR 91.409 (a) (2) & 14 CFR 91.417 (a) & (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Adam Hall , Owner and O perator of an Rainbow Bridge Media, LLC , hereby applies for an exemption from the listed Federal Aviation Regulatio ns (“FARs”) to allow commercial operation of its UAS including closed

- set motion picture and television filming , so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Rainbow Bridge Media’s c ommercial operation of the Unmanned Aircraft System ( UAS ) , as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, mapping, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, motion picture, public events, cinematography and news gathering including closed

- set filming for the motion picture and television industry in accordance with the Motion Picture and Television Operations Manual (MPTOM) for flights covered under this Exemption Request, specifically those for sterile environments and clo sed set motion picture and television productions.

 Aerial inspection/photography of residential/commercial structures under contract with the ownersor local government authority.

 Aerial inspection/photography of residential/commercial utility infrastruct ure including but not limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local autho rities or government has requested it by contract or donation.

As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilit ies to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant is:

Adam Hall DBA: Rainbow Bridge Media, LLC. 46

- 039 Lilipuna Road, Kaneohe, HI 96744 Email: 

### adamhall. 02 @gmail.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.23 (a) 14 CFR 61.113 (a) & (b) 14 CFR 61.315(a) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) & (b) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)Introduction & Background

Rainbow Bridge Media LLC is a professional photographer, videographer , data collection and production
company operating primarily in Oregon and Hawaii . Adam Hall, operator, has over 7 years of professional experience in Communication Information Technology and is recognized as an expert in telecommunications network infrastructure. In addition, He has over 5 years recreational/hobby experience in all aspects of aerial video and photography. The objective s of Rainbow Bridge Media LLC’s aerial video and photography operations are to provide high quality imagery and data for a var iety of commercial, agricultural, and residential uses

. Rainbow Bridge Media provides its clients with solutions to increase efficiency, productivity and effectiveness.

One example of Rainbow Bridge Media’s benefits to society can be found in aerial videography for real estate. Aerial photography for real estate has been around for a long time through manned fixed wing aircraft and helicopters. With such a large expense, small budget real estate companies and as well as simple homeowners cannot partake in the benefit of having aerial imagery because the cost is so prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. This has depriving non

- luxury homeow ners and lower budget Rea ltors from a valuable marketing tool.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act.

Granting Rainbo w Bridge Media’s exemption reque st furthers the public interest through academic/visual awareness of the geograph ical benefits in and around Hawaii and Oregon . Our ultra

- light weight UAS ’ are battery powered and create no emissions that can harm the enviro nment. The consequence of either ultra

light weight UAS crashing are far less than a ful l size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furth ered by minimizing ecological and crash threats by permitting Rainbow Bridge Media with the ability to capture aerial video/photo /data through the battery operated ultra

- light weight UAS's. Furthermore, p ermitting Rainbow Bridge Media LLC, to immediately f ly within national air space furthers economic growth. Granting our exemption request substantially furthers the economic impact for the local community as well as for companies looking to relocate or build in the area as well as individuals looking to relocate for career advancement.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

As the primary pilot, Adam Hall, has an in

- depth understanding of the capabilities and safety concerns involved in using this technology as an asset to the community. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of Rainbow Bridge LLC’s UAS.

Rainbow Bridge Media only utilizes safe and reliabl e UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breakin g software enabling the user to set parameters which will not allow flight into controlled a irspace. Parameters can also be set to limit flight to no higher t han a predetermined and set alti tude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)UAS : DJI Inspire 1 and DJI Spreading Wings S1000+.

The DJI Inspire 1 and DJI Spreading Wings S1000+ are vertical takeoff a nd landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems

.
The DJI Inspire 1 has a maximum gross weight of 6 poun ds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approxi mately 40

- 42 knots. The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer b attery p owered electric motors

The Spreading Wings S1000+ has a maximum gross weight of 13

- 22 pounds, a length of 19.3 inches, width of 19.7 inches, height of 14.8 inches, and a maximum speed of approximately 30 knots. The Spreading Wings S1000+ is equipped with eight main rotors; driven by Lithium Polymer battery powered electric motors and the S1000+ is built to carry a heavier payload for an d supremely stable platform that is designed for advanced photography and cinematography.

Further Details on EACH UA can b e found in the appendix

Both Models feature autonomous control and manual control abilities. Both can be programmed to limit their altitudes, and to avoid airspace with lateral limitations They also feature the ability to automatically compensate for moto r failures, and will automatically return to base for low battery situations and signal disruptions.
Both of these models have operational speeds and weights that are well in line with the FAA limitations (less than 25 pounds max with payload, around 40 kn ots max speed) and they have been previously approved on multiple occasions. Rainbow Bridge chose DGI as a manufacturer due to their industry leading expertise and experience. These models have many hours of operational history behind them, and are inhere n tly safer due to their having 4

- 8 rotors for redundancy, rigid construction, and light weight.
Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements. The approva l of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant o f the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

Further limitations and conditions to which Rainbow Bridge Media agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs including payload

.

 The UAS will have a maximum operating speed of no more than 35mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

 Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve or 20 min utes of flight time whichever occurs first. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.

 The UAS pilot will be a designated Pilot in Command (PIC) and will take and pass all necessary certifications currently being approved by the FAA admin istration for commercial use.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) o nly.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. The DJI Inspire has built in software for all FAA regulated ‘No Fly Zones’ and was uploade d by DJI (2015) for all DJI drones to download and prevent any possible flights occurring within no

- fly zones. DJI Spreading Wings S1000+ has installed software (code) that denies flights within the FAA no

- fly zones.

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent infor mation.

 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.

 T he operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equiva lent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

 The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the parti cular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.

 The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires thePIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S . driver’s license.

 The UA must remain clear and give way to all manned aviation operations and activities at all times.

 The UAS may not be operated by the PIC from any moving device or vehicle.

 The operator must have a motion picture and television oper ations manual (MPTOM) as documented in this grant of exemption.

 Any incident, accident, or flight operation that trans gresses the lateral or vertical boundaries of the operational area will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 2 4 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

 We are further requesting that this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply:

 Rainbow Bridge Media will have a motion picture and television operations manual ( MPTOM) as documented in this grant of exemption.

 At least 3 days before aerial filming, Rainbow Bridge Media will submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a) Dates and times for all flights;

b) Name and phone number of the operator for the sUAS aerial filming conducted under this grant of exemption;

c) Name and phone number of the person responsible for the on

- scene operation of the sUAS;

d) Make, model, and serial or N

- Number of the sUAS to be used;

e) Name and certificate number of sUAS PIC s involved in the aerial filming;

f) A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission will be made available to the inspector u pon request;

g) Signature of exemption holder or representative; and

h) A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to ac complish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the MPTOM.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

Rainbow Bridge Media pilots will be highly trained, will practice emergency procedures regularly, and will always have the safety of the public as the primary concern.

Rainbow Bridge Media’s Reque st are In the Best Public Interest;

Granting Rainbow Bridge Media ’ s present Petition will further the public interest by allowing Rainbow Bridge Media to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape as well as data collection over certain areas of the United States.

Additionally, use of the DJI Inspire 1 and Spreading Wings S10 00+ UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Rainbow Bridge Media ’ s proposed operation of the DJI Inspire 1 and Spreading Wings S1000+ UASs will be realized with out implicating any privacy issues.

1. The Public Will Benefit From D ecreased Congestion Of The NAS. The DJI Inspire 1 and Spreading Wings S1000+ UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery/data. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption al lowing the use of the DJI Inspire 1 and Spreading Wings S1000+ UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by re ducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft wil l be reduced. The DJI Inspire 1 and Spreading Wings S1000+ 1 UAs do not require an airport to takeoff or land. Likewise, a re duction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. T he Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 and Spreading Wings S1000+

. Conducting aerial acquisitions with the DJI Inspire 1 and Spreading Wings S1000+ , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 and Spreading Wings S1000+ UASs produce no air pollution, and is the most viable environmentally conscious alternative to the typical engine aircraft that are often utilized for aerial video and photography and Data Collection . The DJI Inspire 1 and Spreading Wings S1000+ UAs, while reducing the carbon footprint of aerial acqu isitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. 3. B y using the DJI Inspire 1 and Spreading Wings S1000+ UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated.Aside from the lack of flight crew members located onboard the a ircraft, the DJI Inspire 1 and Spreading Wings S1000+ UAs (weighing so little even at their fully loaded weight), have far less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft tha t typically conduct similar operations

. 4. Performing Aerial Video, Data Collection, and Photography Operations With The DJI Inspire 1 and Spreading Wings S1000+ UASs Will Benefit The Economy. In addition to being safe and efficient, the DJI Inspire 1 and S preading Wings S1000+ UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the the DJI Inspire 1 and Spreading Wings S1000+ UASs will allow United States based companies, like Rainbow Bridge Media , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and oper ated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 and Spreading Wings S1000+ UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 and Spreading Wings S1000+ UASs, Rainbow Bridge Media can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 and Spreading Wings S1000+ UASs, provide a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. 5. There Are N o Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for years , Rainbow Bridge Medias proposed operation of the the DJI Inspire 1 and Spreading Wings S1000+ UASs will not implicate any privacy issues. Speci fically, the DJI Inspire 1 and Spreading Wings S1000+ UASs will be operated only in compliance with operating documents (i.e., the Rainbow Bridge Media Operations Manual, Monthly Maintenance Log s , and the DJI Inspire 1 and Spreading Wings S1000+ Instruction Manual s ) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulation.

Exemption Requests:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §9 1.203 (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 Rainbow Bridge Media , 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 of 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

c ases, 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 rot orcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger,

carries no explosive materials or flammable l iquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local p ublic safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued unde r 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 explosive materials or flamm able 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,
rest ricted 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 in ches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption will 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 UAS, two

- inch lettering 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 UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”

14 C.F.R. § 61.23(a)

The P.I.C. may have a valid U.S. driver’s license in lieu of a medical certificate. This is per FAA guidance. As each UAS can land itself the physical integrity of the PIC is not as important as that of a manned aircraft. Also, redundancy in the form of a visual observer will certainly add to safety. See previous Exemption No. 11343

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. An equivalent level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pilots or
passengers nor prop erty. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will equate to the safe operation of the UAS. See Exemption No. 1121314 C.F.R. § 61.315(a)

Sport pilot limitations on commercial activity are not bei ng applied to UAS. Rainbow Bridg e also request the ability to utilize sport pilots assuming they will be held to the same training standards, as dictated by the F.O.M. See previous Exemption No 11407

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 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 of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. See Exemption Nos. 11062, 11063, 11064, 11065.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Sect ion 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 R otorcraft Flight Manual, approved manual material, markings, and placards, or any combination 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 b oard, 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

.
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 provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre

- flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data befor e 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 functioning dual controls. UAS 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 communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls f or a number of aircraft and for flight instruction in experimental aircraft. 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 (c) : Minimum Safe Altitudes.

As in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not bepossible without a dditional relief. The petitioner requests modification, waiver or exemption and clarification

concerning the terms “congested areas” and “densely populated”. The Petitioner requests waiver for this condition to allow reasonable and responsible operations n ear persons or property as needed. It should be noted that due to the small weight, controlled area of operation, lower speeds, computer backup, and lack of flammable fluids the UAS is inherently safer than equivalent manned aircraft. See Previous Exemptio n 11138

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 setti ng available before departure.” The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 and Spreading Wings S1000+ UAs will be provided to the PIC via GPS equipment and a radio c ommunications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Rainbow Bridge Medias operation of the Spreading Wings S1000+ and DJI Inspire 1 UAs wi thin visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation
po int is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein See Previous Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

Section 91.151 (a) prohibits an individual from beginning “ 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 le ast 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to app roximately 10 minutes in length. Given the limitations on the DJI Inspire 1 and DJI Spreading Wings S1000+ proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable.

Rainbow Bridge Media believe that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the DJI Inspire 1 and DJI Spreading Wings S1000+ , in a tightly controlled area, 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 Rainbow Bridge Medias flights to 10 minutes would greatly reduce and constrain the practicality of any aerial video or still photo flight operations that Rainbow Bridge Media proposes to conduct pursuant to this Petition.
Rainbow Bridge Media believes that an equivalent level of safety can be achieved by limiting flights to 20 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.A grant of part B exemption would ensure an equivalent level of safety established by (1) the technical

specifications of the DJI Inspire 1 and DJI Spreading Wings S1000+ UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flig ht operations. Accordingly, Rainbow Bridge Media will ensure that it will safely operate the battery powered DJI Inspire 1 and DJI Spreading Wings S1000+ UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Furthermore, sa fety will be ensured as the DJI Inspire 1 and DJI Spreading Wings S1000+ provide aud ible and visual warnings to the PIC at the GCS when the UAs experiences low battery volta ge, the first warning occurring at approximately 30 % remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 an d DJI Spreading Wings S1000+ UASs will descend and land automatically.

Significantly, previous exemptions granted by th e FAA concerning Section 91.151 establish that safety is not adversely affected when th e technical characteristics and operating limitat ions of the UAS are considered.

Rel ief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Additionally , the FA A has previously granted relief from Section 91.151 specific to UAS, in circumstances simila r, in all material respects, to those presented by Rainbow Bridge Media See Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 111 36, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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 certific ate 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 DJI Inspire 1 and DJI Spreading Wings S1000+ fully loaded w eighs no more than 55 lbs. and are operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS ’

.
An equivalent level of safety will be achieved by keeping these d ocuments at the ground control point where the pilot flying the UAS will have immediate access to them; to the extent they are applicable.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require t hat an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, 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 aircraft in compliance with Part 43.Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections

will not apply to the applicant. Maintenance w ill be accomplished by the Rainbow Bridge Media operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the DJI Inspire 1 and DJI Spreading Wings S1000+ UAS are both very limited in size, will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the DJI Inspire 1 and DJI Spreading Wings S1000+ UAS can land immediately and will be operating from no higher than 400 feet AGL. The Rainbow Bridge PIC 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 PIC is the person most familiar with the airc raft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the DJI Inspire 1 an d DJI Spreading Wings S1000+ UAS Manufacturer's User Manual. As provided in the FOM, the PIC will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.

CONCLUSION

As previously shown i n Grants of Exemption Nos. 11062 to Astraeus Aerial (see D ocket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using a n unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, and gave good cause to fi nd that the UAS operation enabled by this exemption is in the public interest and Rainbow Bridge Media is requesting the same exemptions

. As set forth herein, Rainbow Bridge Media se eks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Moder nization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 and DJI Spreading Wings S1000+ UASs commercially, without an airworthiness certificate, for the commercial purposes of conducting aerial video, data collection and photography over certain areas of the United States including closed

- set filming for the motion picture and television industry . By granting this Petition, the FAA Adm inistrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Rainbow Bridge Media to safely, efficiently, and economically operate the DJI Inspire 1 a nd DJI Spreading Wings S1000+ commercially within the NAS.
WHEREFORE, in accordance with the Federal A viation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Adam Hall and Rainbow Bridge Media respectfully requests that the Admini strator grant this Petition for an exemption from the requirements set forth above and permit Rainbow Bridge Media to operate the DJI Inspire 1 and DJI Spreading Wings S1000+ commercially for the purpose of conducting aerial video , data collection and photo graphy over certain areas of the United States including closed set filming

. Respectfully Submitted ,

Adam Hall Owner Rainbow Bridge Media LLC.

### GLOSSARY OF ABBREVIATIONS

AGL : Above Ground Level AOI : Area of Interest ATC : Air Traffic Control ATO : Air Traffic Organization CFR : Code of Federal Regulations COA : Certificate of Authorization FAA : Federal Aviation Administration FAR : Federal Aviation Regulation GCS : Ground Control Station GPS : Global Positioning System LOL : Loss of Link NAS : National Airspace System NOTAM : Notice to Airman PIC : Pilot In Command SO : Safety Observer SOP : Standard Operating Procedures UA : Unmanned Aircraft UAS : Unmanned Aircraft System VFR : Visual Flight Rules VLOS : Visual Line of Site VMC : Visual Meteorological Conditions VTOL : Vertical Takeoff and Landing

### DJI Inspire

GENERAL FEATURES

 Ready to fly

 3

- axis camera stabilization

 Precision flight and stable hovering

 GPS/GLONASS positioning & auto return home

 Onscreen real

- time flight parameters

 High Definition 4k Camera

 Camera tilt control

 Film straight down

 Supports Adobe DNG RAW

 Adobe lens profile support

 Camera parameter settings

 Album synchronization

 FAA no

- fly zones locked out via installed softwa re

TRANSMITTER

 Operating Frequency:2.400 GHz

– 2.483 GHz

 Communication Distance ( open area ) : CE: 2000m; FCC: 2000m

 Receiver Sensitivity ( 1%PER ) :
- 101dBm +/

- 2dBm

 Transmitter Power: CE: 16dBm; FCC: 20dBm

 Working Voltage: 1.2A @ 7.4V

 Battery: 6000 mAh LiPo 2s

CAMERA

 Operating Environment Temperature : 0 °C

- 40 °C

 Max Resolution: 4096 x 2162p @ 24/25fps

 FOV: 94°/ 85°

 Sensor size: 1/2.3"

 HD Recording: 4k p 24/25fps / 720p 60fps

DJI VISION APP

 System Requirement of Mobile Device: iOS version 6.0 or above/ Android system version 4.0 or above

 Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, iPod Touch5;



### DJI Inspire 1 Details

Aircraft

Model

– T600 Weight (Battery Inc luded)

– 6lbs 7.5291oz (2935g) Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal:2.5m

### Max Angular Velocity

– Pitch: 300 /s; Yaw: 150 /s

Max Tilt Angle

- 35 Max Ascent Speed

– 5m/s Max Descent Speed

– 4m/s Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) Max Flight Altitude

– 4500m Max Wind Resistance

– 10m/s Max Flight Time

– Approximately 18 minutes Motor Model

– DJI 3510 Propeller Model

– DJI 1345 Operating Temperature Range

– 14F to 104F (

- 10C to 40C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12” Gimbal Model

– ZENMUSE X3 Output Power (with camera)

– Static: 9W; In Motion: 11W Operating Current

– Static: 750mA; In Motion: 900mA Angular Vibration Range

- ±0.03 Mounting

– Detachable Controllable Range

– Pitch:

- 90 to +30; Pan: ±320 Mechanica l Range

– Pitch:

- 125 to 45; Pan: ±330 Max Controllable Speed

– Pitch: 120/s; Pan: 180/s Camera Name

– X3 Model

– FC350 Total Pixels

– 12.76M Effective Pixels

– 12.4M Image Max Size

– 4000x3000 ISO Range

– 100

- 3200 Field of View

- 94 CMOS

– Sony EXMOR 1/2. 3” HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 Operating Temperature Range

- 32 F

- 104 F (0 C

- 40 C) Transmitter Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483 GHz Communicating Distance (unobstructed)

– 2000m Output Power

– 9W Operating Temperature Range

- 14F to 104F (

- 10C to40C) Battery

– 600mAh LiPo 2S DJI Inspi re 1 Manufacturer’s User Manual may be found at:

### http://download.djiinnovations. com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

DJI Spreading Wings S1000+Details

Aircraft
Diagonal Wheelbase: 1045mm Frame Arm Length: 386mm Frame Arm Weight (Including Motor, ESC, Propeller):325g Center Frame Diameter: 337.5mm Center Frame Weight (with Landing Gear Mounting Base, Servos): 1330g Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm) Foldable Propeller: High strength performance engineered plastics, Size 15×5.2inch Flight Parameters: Takeoff Weig ht 6.0Kg ~ 11.0Kg (depending on camera/gear attached) Power Battery: LiPo (6S
、 10000mAh~20000mAh 、 15C (Min), Max Power Consumption4000W Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight) Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature

- 10 °C ~ +40 °C