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ATTORNEYS



### expectmore

July 20, 2015 VIA FED EX ONLY(TRACKING # 80628187 2434) U.S. DepartmentofTransportation Docket ManagementSystem 1200 NewJerseyAve., SE Washington, DC 20590 .. -- !

**~I**

Re: Petition ofi Drone Corp. for Exemption PursuanttoSection 333ofthe

### FAA ModernizationandReformActof 2012 Dear Sir or Madam: Pursuantto Section 333 ofthe 

### FAA ModernizationandReformActof 2012 ("FMRA") and 14C.F.R. Part 11, i Drone Corporation ("i Drone"), operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial videography, cinematography for pre-planned, controlled area, photographic and other aerial data collection services, hereby applies for an exemption from the below listed Federal Aviation Administration Regulations ("FARs") to allowcommercial operation ofits sUASs, so longas such operations are conducted within and underthe conditions outlined herein, in accord withthe enclosed i Drone Operations Manual ("Flight Operations Manual"), in compliance with the sUAS Operator's Handbook and all manufacturers' operations and/or instructions manuals ("Operator's Handbook")1

, and in strict compliance any and all rules, regulations, and practices as may be established by the Federal Aviation Administration 

### ("FAA") forthe operation ofasUAS. LEGAL AUTHORITY AND OVERVIEW

1. Legal and Regulatory Framework The FMRA provides that "the Secretary ofTransportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system

..." priorto final completion ofthe required Reform Act plan and the subsequent rule-making. § 333(a). In makingthis determination,the SecretaryofTransportation shall determine, ata minimum- (1) Which types of unmanned aircraft systems, if any, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users ofthe national airspace system or the publicor pose athreatto national security; and

1 The Flight Operations Manual and Operator's Handbook both contain confidential, trade secret and proprietaryinformationthat i Drone has not and will not share with others. Petitioner submits the Flight Operations Manual and Operator's Handbook and all information contained therein as proprietaryand confidential information pursuantto 14 C.F.R. § 11.35(b). The Flight Operations Manual and Operator's Handbook contain operating conditions and procedures that are not available to the public and are protected from release under the Freedom of InformationAct, 5 U.S.C. § 552 etseq.

ALG ATTORNEYS. PLLC C080206 M:Jh (720) 5364600 Fox: (720) 53!l 4e0·1 ALGA TTORNEYS.COM(2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraftsystems identified under paragraph (1). §333(b) (1)-(2). Finally, §333 provides that "[i]fthe Secretary determines underthis section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." §333{c). The FAA has promulgated guidance for UAS users thatwish toobtain aSection 333 exemption. The FAA has recommended thatan applicant discuss the following items: 1. The safe operation of a UAS to minimize risk to the National Airspace ("NAS"), including the operational characteristic for the type of UAS intended for use, operating procedures, and aircraft loading information; 2. Operational procedures, including pre-flight inspections, maintenance, and repair; 3. Radio Frequency ("RF") spectrum used for control ofthe UAS and associated equipment that is part ofthe UAS and whether it complies with Federal Communications Commission 

### ("FCC") or otherappropriate governmentoversight requirements; 4. A description ofthe Pilot in Command 

### ("PIC") directly responsible forthe operation ofthe UAS, including the level of airman certificate held, any applicable training related to the operation, and any minimum hours offlight experience required by the PIC, both total flight time and the time with the particular UAS, as well as medical standards and certification ofthe PIC directly responsible forthe operation ofthe UAS; 5. The intended UAS operations, including howthe operation would notadversely affect safety, or how they would provide a level ofsafety at least equivalent to that provided by the rule from which exemption is sought; 6. The proposed maximum operatingspeed and altitude, and describethe minimum flightvisibility and distance from clouds for their intended operations, including any potential hazards and safety mitigations associated withthese proposed conditions; 7. The characteristics ofthe area of intended operation and the associated potential hazards and proximityto populated areas; 8. The proximitytoairports; 9. A description of how the application intends to operate the UAS within visual line-of-sight ("VLOS"); 10. Any procedures to conduct a preflight safety risk assessment to determine thatthe UAS is in a conditionforsafe flight and thatthe planned operation can be completed safely; 11. To the extent the activity involves operations that have existing requirements, such as motion picture and television filming, or pipeline and powerline control, howthe application intends to complywith such regulations; and 12. The applicant's intent to obtain a Certificate ofWaiver ofAuthorization ("COA") from the FAA AirTrafficOrganization. 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. See 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701{a), (b) and §§ 44702

- 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) would benefitthe public as awhole, and (2) would notadversely affectsafety (or how itwould provide alevel ofsafetyat least equal totheexisting rules). See 14C.F.R. § 11.81 (petitionsforexemption). 2. i Drone Meetsand Exceeds the Legal and Regulatory Requirements As will be shown herein, i Drone meets and exceeds the stated §333 requirements as well as the guidance promulgated by the FAA. The proposed operations in this petition for exemption qualify for expedited approval under §333 ofthe FMRA. Each ofthe statutory criteria and other relevant factors are satisfied. The proposed operations permit the use of small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access; and that (4) provides an increased level ofsafety beyond that existing when fixed or rotorwing aircraft are used to accomplish the same purpose. I Drone's sUAS are rotorcraft, weighing 50 or fewer pounds, including payload. They operate, under normal conditions, at lowspeed and have the capabilityto hover and move in thevertical and horizontal plane. I Drone's UASs will operate in line of sight, or pursuant to the prevailing FAA regulations and guidance, and will onlyoperatewithinthose areas described in the enclosed Flight Operations Manual. Given the small size of the sUASs involved and the restricted environment within which they will operate, the comprehensive safety and operational parameters used by i Drone, and i Drone's commitmentto compliance with the FAA's regulations now and intothe future, this petition exemption falls within the equivalent level of safety that Congress desired the FAA to permit commercial UAS operations by exemption pending completion offormal rulemaking. Also, due to the size ofthe sUASs and the restricted area in which the sUASs will operate, approval ofthe application presents no national security issue. Considering the clear direction in §333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, the grant of the requested exemptions is also in the public interest. Accordingly, i Drone respectfully requests the FAAgrantthe requested exemptionwithoutdelay. 

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## ~~ON_E__

## ---------------~----------~------------------ I Drone Corporation is aColorado corporationthatoperates Small Unmanned Aircraft Systems equipped to conduct aerial videography, cinematography, photography and otheraerial data collection services. I Drone works with clients across many industries, including oil and gas companies, real estate, construction, and agriculture,to providethe client images, videos and data needed to support and grow their business. The i Drone team has extensive experience in both safely piloting sUASs and providing aerial photography. Contactfori Drone: i Drone Corp. Marc Mackie 37050 Soaring Eagle Circle WindsorCO 80550 team@idronecorp.com 303-523-0413

---------------·---------------------------- ---------- ·-·-------------PROPOSED OPERATIONS The enclosed Manuals describe, in detail, the policies and procedures for i Drone's proposed sUAS operations. To assist the FAA in its safety assessment ofi Drone's proposed sUAS operations, below is a summary of operational limitations and conditions, which will ensure an equivalent or higher level of safetyto operations conducted undercurrent regulatoryguidelines: 1. The sUAS will weigh lessthan 50 pounds. 2. Flights will be operated within line ofsight ofthe Operator. 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 500 feet Above Ground Level 

### ("AGL"). 5. Flights will be operated at a safe lateral and vertical distance from and above any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation orwho have notsigned awaiver in advance oftheoperation. 6. The sUAS Pilot with Pilot in Command responsibilities for the flight will be the designated Operator ("Operator"). 7. The sUAS will operate only within a confined area as described in the Flight Operations Manual. 8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties withinthe boundaries ofthesafety perimeter be presentforthis briefing. 9. The Operatorwill have been trained in operations ofsUAS generallyand received up-todate information on the particular sUAS to be operated as required in the Flight Operation Manual. 10. Written and/ororal permission fromthe relevant property holderswill be obtained. 11. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 12. Ifthe sUAS losestransmission signal, thesUAS will have the capabilityto return to apredetermined location and land. 13. Contingency plans will be in place to safely terminate flight if there is a loss of transmittercommunications ora loss ofGPS signal. 14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.REQUESTED EXEMPTIONS The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by itsterms, includes exempting civil aircraft, as theterm is defined under§40101 ofthe Act, including sUASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 for purposes of conducting aerial photography and videography, and other aerial data collection services. Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level ofsafety betterthan orequal tothe rules from which exemption is sought. A. 14C.F.R. Part 21, Subpart H-Airworthiness Certificates and 14C.F.R. § 91.203(a) and (b) Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural requirements for the issuance of airworthiness and registration certificates as required by 14 C.F.R. Given the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an exemption from Part 21, Subpart H, meets the requirements ofan equivalent level ofsafety under Part 11 and §333 ofthe FMRA. The Federal Aviation Act and §333 of the FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness or registration certificate, in the restricted environment and underthe conditions proposed, will be at least as safe as, or safer than, a conventional rotorcraft operating with an airworthiness certificate without restrictions and conditions ofthe proposed sUAS operations. Equivalent Level ofSafety The sUAS to be operated hereunder, DJI Innovations Inspire 1 multi-rotor rotorcraft, weighs less than 55 pounds with payload, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and sterile area. Unlike other civil aircraft, the proposed operations will be controlled and monitored by the Operator pursuant to the Flight Operations Manual's requirements, as attached. These safety enhancements, which already apply to civil aircraft operated in connection with existing aerial videography operations, provide a greater degree ofsafety to i Drone's employees, members of the public, and propertyownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, lackofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load. B. 14C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent i Drone would otherwise require certification under Part 27, i Drone seeks an exemption from Part 27's airworthiness standards for the same reasons Identified in the

·---------·-··· ··- -·-·--------·-··exemption requestfrom 14 C.F.R. Part 21, Subpart H. C. 14CFR § 61.113: Private Pilot Privileges And limitations Petitioner seeks an additional exemption from 14 CFR § 61.113, which restricts private pilot certificate holdersfromflying aircraftfor compensation or hire, and which would also have the effectofrequiring a second-class medical certificate.This provision limits private pilotsto non-commercial operations. Equivalent Level ofSafety Because the sUASs will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety of current operations by requiring a ground crew memberto have a private pilot's license rather than a commercials pilot's license to operation this sUAS. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation ofthe sUASs are so diminished from the level of risk associated with commercial operations contemplated by part 61 when drafted,thatallowing operations as requested with a private pilot in the ground crew exceeds the present level ofsafety achieved by 14 C.F.R. Sec. 61.113{a) and (b). In addition, in Grant of Exemption No. 11062 to Astraeus Aerial ("Astraeus"}, the FAA determined that an Operator with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Additionally, as previouslydetermined bythe SecretaryofTransportation,the requirementto have an airman certificate ameliorates security concerns overcivil UAS operations conducted in accordance with §333. The aerial data collection conducted by i Drone will be conducted in areas where access to the public is limited and controlled. As such, the operations will have no substantial impacton anythird persons not involved in the production. I Drone also has a policy to conduct its operations, when possible, during times when third persons not involved in the production are expected to be limited and to the extent possible, to provide noticeto affectedthird persons when production and operationswill occur. Because i Drone will operate in controlled areas and under controlled parameters, the sUAS will be flown based on visual line-of-sight at altitudes below 500' AGL. Accordingly, i Drone request that this exemption be granted. D. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Petitionerseeks an exemptionfromthe aircraft markingand identification requirements contained in 14 C.F.R. §§ 91.9{c}, 45.23{b) and 45.27{a). 14 C.F.R. § 91.9{c}, Civil Aircraft Flight Manual, Marking and Placard requirements, provides that "[n]o person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordancewith Part45 ofthis chapter." Equivalent Level ofSafety The equivalent level ofsafety for exemptions to the aircraft marking and identification requirements of §§ 91.9{c}, 45.23{b) and 45.27{a) will be provided by havingthe sUAS marked on its fuselage as required by§45.29(f). In addition, i Drone is aware of Exemption No. 11333,which required the sUAS's markings to be lias large as practicable." The FAA has previously issued the following related exemptions to theaircraft marking requirements of§45.23(b): Exemption Nos. 10700, 10167 and 10167A. E. 14C.F.R. § 91.9(b)(2}: Civil Aircraft Flight Manual in theAircraft I Drone seeks an exemption fromtheflight manual requirements of14C.F.R. §91.9(b)(2), which states: (b) No person mayoperate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 ofthis chapter, unless there is available in the aircraft acurrent approved airplane or Rotorcraft Flight Manual, approved manual material, markings and placards, orany combinationthereof. Given the physical dimensions ofthe sUAS, configuration and load capacity, the sUASs have no abilityto carry such a manual on the aircraft, not only because there is no pilot on board, but because there is simply no room orcapacitytocarry such an item on the aircraft. Equivalent Level ofSafety The safety related purpose ofthis manual requirement can be equally satisfied by maintainingthe sUAS flight manual at the ground control point where the Operator will have immediate access to it. Accordingly, i Drone requests an exemption from 91.9(b)(2)'s flight manual requirements, on the conditionthatthe sUAS flight manual be available atthe control pointduringeach operation. The FAA has issued thefollowing exemptionstothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700, and 11333 ("documents required under 14 CFR §§ 91.9 and 91.203 must be available tothe PIC at the Ground Control Station ofthe UAS any time the aircraft is operating.") F. 14C.F.R. § 91.7(a): Civil AircraftAirworthiness I Drone seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy conditionto be operated. Inasmuch therewill be no airworthiness certificate issued forthe sUAS, should this exemption be granted, no FAA regulatorystandard will existfordeterminingairworthiness. Equivalent Level ofSafety The DJI Innovations INSPIRE 1 has a stellar safety record, demonstrating that the sUAS is airworthy. Further, given the size ofthe sUAS and the requirements contained in the Flight Operation Manual for maintenance and pre-flightsafetycheck lists, an equivalent level ofsafetywill be provided. The FAA has issued thefollowingexemptionstothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A,9565,9565B, 10167, 10167A,10602,32827, 10700,and 11333. G. 14C.F.R. § 91.103: PreflightAction Drone seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved flight manual on board the aircraft. Whilethe Operatorwill be familiarwith all information necessarytosafely conduct the flight, an exemption is requested to the extent that an FAA-approved flight manual is required on board the aircraft.

U.S.Equivalent Level ofSafety An equivalent level ofsafety will be provided by following the Operator's Handbook. The Operator will take all required preflightactions- including reviewingweather,flight battery requirements, landingand takeoff distance, and aircraft performance data

- before initiation of flight. The Operator's Handbook will be kept at the ground station with the operator at all times. Further, i Drone will utilize all safety and manufacturer's manualstoensure itadherestothe higheststandards forsafetywithinthe industry. H. 14C.F.R. § 91.109(a): Flight Instruction I Drone seeks an exemption from 14 C.F.R. § 91.109{a), which provides that "[n]o 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." sUASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a box that communicateswiththe aircraftvia radio communications. Equivalent Level ofSafety Given the size and speed ofthe sUAS, an equivalent level ofsafe training can still be performed without dual controls because no pilotor passengers are aboard the sUAS, and all persons will be asafe distance away in the event that the sUAS experiences any difficulties during flight instruction. 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 for a numberofaircraft and forflight instruction in experimental aircraft. See, Exemption Nos. 5778K 

### & 9862A. The equivalent level ofsafety is provided bythe factthat neithera pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls utilizing digital communications thatare paired tothe sUAS, making it nearly impossible to unintentionally or intentionally have the control communications interrupted. The FAA has approved exemptions forflighttrainingwithoutfully functional dual controls for a number ofaircraftand forflight instruction in experimental aircraft. Exemptions include: Nos. 5778K and 9862A. I. 14C.F.R. § 91.119: Minimum Safe Altitudes Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119{c). Section 91.119{d) allows for a helicopterto 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 bythe FAA." To provide the intended aerial video operations, the sUAS is normally operated below 500 feet AGL. Additionally, due the nature of the proposed operations, the sUAS will maintain a safe lateral and vertical distance from inhabited structures, buildings, vehicles, and vessels, and from people not associated withthe operation.Equivalent Level ofSafety Compared to flight operations with rotorcraft weighing far more than the maximum 55 pounds proposed herein, and given the lack offlammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed ofthe UAS, as well as the location where it is operated. As set forth in the Flight Operation Manual, the sUAS will be operated in a confined area, where buildings and people will not be exposed to operations without their pre-obtained consent. Because of the advance noticetothe propertyowners and participants, all affected individualswill be well aware ofthe planned flight operations as setforth in the Flight Operation Manual. Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI INSPIRE 1 demonstrates thatthe sUAS can be safely used at these lower altitudes and closer operating environments. 

### J. 14C.F.R. § 91.121:AltimeterSettings This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude orflight level by reference to an altimeterthat is settothe elevation ofthe departure airport or barometric pressure. An exemption is required because the sUAS does not have a barometricaltimeter, but ratheraGPS altitude read out. Equivalent Level ofSafety An equivalent level of safety will be achieved by following the procedures set forth in the Flight Operation Manual. As prescribed in the Flight Operation Manual, the operatorwill confirm the altitude ofthe launch site shown on the GPS altitude indicator beforeflight. Moreover,the Operatorwill use the GPS altitude indicatortoconstantly monitorthesUAS's height,thus ensuringoperation atsafe altitudes. K. 14C.F.R. § 91.151(a): Fuel Requirementsfor Flight in VFR Conditions Drone requests an exemption from 14 C.F.R. § 91.151{a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No 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- (1) Duringthe day, toflyafterthatforat least30 minutes; or (2) At night,tofly afterthatforat least45 minutes. Here, the battery powering the DJI Innovations INSPIRE 1 provides approximately 15 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 C.F.R. § 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. Petitionerwill not be conductinganysUAS flights at night.Equivalent Level ofSafety An equivalent level ofsafety will be achieved because the operations will be conducted on-site without significant transit time by the sUAS. All flights will be planned to be terminated with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to the ground and its planned landing zone from anywhere in its limited operating area even in the eventofan unexpected occurrence. Operation ofthe 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 ofthe small UAS, and the proximityoftheflightoperationtothe landingzone. This request for exemption falls within the scope of prior exemptions, including Exemption Nos. 10673, 2689F, 5745, 10673, 10808and 11333. L. 14C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration I Drone seeks an exemption from civil aircraft certification and registration requirements of 14 C.F.R. § 91.203(a) and (b). The regulation states in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it thefollowing: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed atthecabin orcockpit entrance so that itis legible to passengers orcrew. An exemption to this regulation is necessary because: (1) the sUAS's configuration, load capacity and size does not allow it to carry certification and registration documents; (2) the sUAS does not have a cabin or cockpit entrance at which documents could be displayed; and (3) there are no passengers or crewforwhomthe certificates need to be displayed. Equivalent Level ofSafety To the extentthese regulations are applicable to the proposed sUAS operations, an equivalent level of safetywill be achieved by keepingthese documents atthe ground control pointwherethe Operatorwill have immediate access tothem. The FAA has issued numerous exemptionstothis regulation, including: Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. M. 14C.F.R. § 91.405(a), 91.407(a}(1}, 91.409(a)(1}, 91.409(a)(2}; 91.417(a) and (b): Maintenance Inspections I Drone also seeks an exemptionfromthe maintenance inspection requirements contained in 14C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart Eof this part and shall between required ions

...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these

U.S,sections onlyapplyto aircraftwith an airworthiness certificate, which thesUAS will nothave. Equivalent Level ofSafety An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the Operator's Handbook as referenced in the Flight Operation Manual. As provided in the Flight Operation Manual,the operatorwill ensurethatthe sUAS is in workingorder priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy conditionto providetheequivalent level ofsafety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will onlytake place in restricted areas for limited periods oftime duringdaylight hours, creates less riskthan thatassociated with conventional rotorcraft performingthe same operation. ! PUBLIC INTEREST

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**--~---~-------------------- --~**  --- ---------- Granting i Drone's exemption furthers the public interest on numerous levels. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such asthose propose in this petition. In addition, maintaining industrial safety has been a priorityofstate and local governmentsfordecades. I Drone also believe that the use of sUASs for aerial photography and videography serves a valuable public interest and addresses a common public concern: safety. The use ofsUAS's in a controlled and safe manner, as described herein. In addition, in the eventofan unforeseen incident, asUAS causes far less disruptionthantraditional aircraft. In addition, conducting aerial videography with the sUAS, instead of manned aircraft, meets another common public concern in the noise and pollution caused by traditional aircraft. The use of a sUAS significantly reduces the levels of air and noise pollution generated during traditional aerial video production flight operations. By using battery power and electric motors, the sUAS produces no air pollution, and is the most viable environmentally conscious alternative to piston or turbine powered rotorcraft. The sUAS, while reducing the carbon footprint of aerial video productions, also eliminates noise pollution as its battery powered electric motors are barely audible duringthe take-off phase, and cannot be heard when operating morethan 100feetabove ground level. By using the sUAS to perform aerial videography, 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 aircrew members located onboard the aircraft, the minimal size and weight ofasUAS creates less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial videography. Relatedly, the sUAS contains no reactive or combustible materials on board and thusthe potential forfire orexplosions is greatlydiminished. In addition, granting the exception will help advance the knowledge base for conducting commercial UAS operations. This additional data will help the FAA set future rules regarding UAS flight operations, maintenance, and crew qualifications. The public also has an interest in reducing the hazards and emissions associated with alternate use ofhelicoptersto conduct similar aerial videography operations. The UAS in question is very lightweight and does notcarryanyflammable fuel, further reducingthe riskfrom any potential accident. PRIVACY

All ofthe proposed flights and videographywill be only conducted afterobtainingany individual subject matter's permission. All flights will occur over public right-of-way or private propertywiththe property owner's prior consent and knowledge. The proposed operations will not impact privacy concerns beyond those already implicated by manned aircraft aerial videography operations. FEDERAL REGISTRY SUMMARY Pursuant to 14 C.F.R. Part 11,the following summary is provided for publication in the Federal Register, should it be determinedthat publication is needed: i Drone seeks an exemptionfrom thefollowing rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 45.27 (a); 14 C.F.R. 61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.9(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14CFR 91.151(a); 14CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14CFR 91.407(a)(1); 14 CFR 91.409(a)(1)and {2); 14CFR 91.417 (a) & (b). Approval of these exemptions allowing commercial operations of small and lightweight unmanned aircraft ("sUAS") to conduct aerial videography and cinematography operations will enhance safety by reducing risktoC5 Aerial, the general publicand propertyowners. The DJI Innovations sUAS, weighing less than 55 pounds, with payload, and powered by batteries, eliminatesvirtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is transportedtothe designated survey area set up. Itis notflownfrom an external locationto the work-site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraftflights. The operation ofthis small UAS will provide an equivalent level of safety, supporting the grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground, and in a controlled environment. As a result, they are far safer than conventional aerial photography, videography, and data collection operations are conducted withfixed wing aircraftor helicopters. 

## ! CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security-provides more than adequate justification for the grant of the requested exemptions to permit i Drone to operate sUASs in support of its aerial photography, videography, and aerial data collection operations in accordance with the Flight Operation and Operator's Handbook appended hereto.



### u.s.Grantingthe requested exemption will benefitthe public interestas awhole in manyways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger, (2} improving aerial videography operations and decreasing operating costs, and (3} providing an environmentally conscientiouswayofproducingaerial videographyand cinematographyoperations. Sincerely,

Encls:- Flight Operations Manual (CONFIDENTIAL- NOT FOR PUBLIC RELEASE)

- sUAS Operator's Handbook (CONFIDENTIAL- NOT FOR PUBLIC RELEASE}