**Private and Confidential**

**AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** , **Shepherdsville, KY**

- Section 333 Exemption Petition
**October 21, 2015** U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE W ashington, DC 20590

**Re** : Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) Dear Sir or Madam, **AE RIA**  **L MEDIA CONCEPTS, LLC**  , is writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** , an owner an d operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** may operate small ultralight weight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal Aviation Administration (“FAA”). Following exemption and approval by the FAA, **AE RIA**  **L MEDIA CONCEPTS, LLC**  , will primarily use professionally built aUAS , including, but not limited to; **DJI Inspire 1, DJI Phantom and other professionally** 

**built UA S**  we ighing less than 55 pounds, e quipped with cameras for the following applications: Closed

- Set Film Operations on Film and Television Productions, aerial videography/cinematography to safely enhance films and commercials; augmentation of real estate listin g s ; obtaining visual aids for disaster and insurance assessment, topography aid fo r Search and Rescue (SAR) missions ; UAS education; agricultural inspections ; building, construction and utility surveys and inspections. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** exemption request would permit the operation of ultralight we ight, unmanned (i.e. piloted by remote control) UAS’s for the development of community and government use videos, permissible within property boundaries for individual homeowners and within in tightly con trolled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. Furthermore, it is the intent to assist future FAA safety protocols and regulatio ns exclusive to lightweight UAS's for specific video and photography usage by sharing information with the FAA as **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** record flight data and other pertinent information gained through permitted flight operations.2

2 In addition, grant ing our exemption request will comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural assessment , film/video productions, closed

- set motion picture film operations and television, and structure inspections, to aid state and local agency’s. Further **AE RIA**  **L MEDIA CONCEPTS, LLC**  will conduct aerial operations in compliance with the protocols described herein or as otherwise est ablished by the FAA. For the reasons stated below, **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** respectfully requests the grant of an exemption permitting me to operate ultralight weight, remote controlled UAS’s to aid academic community awareness, to benefit/stimulate attraction to the Commonwealth of Kentucky and to enhance personal and public video feeds. A grant that will ultimately allow UAS’s to play a more positive role in the aviation sector.

I. Contact Information: **Joshua E. Grimes Ae**  **rial Media Concepts, LLC Shepherdsville, KY 40165**  Phone: **502 -** **376 -**  **1525** Email: **josh@code3video.net**
II. The Specific Sections of Title 14 of the Code of Federal Regulations From Wh ich **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.11 3 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief **AE RIA**  **L MEDIA CONCEPTS, LLC**  Seeks and the Reason He Seeks Such Relief: **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any current applicable FARs that would prevent **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** fro m operating aUAS within the national airspace system for the prescribed co mmercial flight operations stated in this petition. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace3

3 system as it is in the public’s interest to do so. **AE RIA**  **L MEDIA CONCEPTS, LLC**  ’s ul tralight we ight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultralight weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultralight weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. There by, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Wh ether the UAS will be opera ted near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** . M y UAS’s utilize eight (8) or less rotating propellers for balance, control and stability. My UAS’s are equipped with the following via video and data telemetry: 1) Altimeter 2) Attitude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7 ) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery remaining with approximate time. 11) Loiter and circle mode. 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology. Each UAS weighing less than thirty **(35)** pounds (far below the maximum 55 pound limit); Including camera(s) with or without gimbal (a camera stabilizer). **AE RIA**  **L MEDIA CONCEPTS,**  **LLC** , considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, circle in a specific place or loiter via GPS and can be operated in winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released. Wi th three (3) modes to c hoose from, I will fly in the safest mode to gather photo and video for and we have the ability to choose the safes t, most reliable and stable mode to prevent accident and hazard. Wh en pilot communication from the radio control is lost, UAS is designed slowly descend to point of takeoff and or to land at point of launch after ascending to a pre

- set altitude to ensure t he UAS will clear any obstacles that may be between the takeoff point and the4

4 current position of the UAS. This failsafe altitude will not be set more than 200ft and is determined before each flight. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** , will not operate a UAS near airports, hospitals nor police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. Pilots will be constantly on alert for any manned aircraft (poli ce/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. The a UAS’s are capable of vertical and hor izontal operations, and is flown only within my line of sight, as the remote control pilot. The a UAS's are also flown with a second operator who aids in watching for any obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights generally last between ten (10) to twenty
-five (25) minutes, with an altitude under one hundred fifty (150) feet. Smart Mode includes, position hold, self

- leveling, altitude command, GPS, return home featu re, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** , will utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. Wewill not operate a UAS at or below manufacturer recommend minimum battery power levels for operation; preferring to remain well within a safe operating range to insure adequate communicatio n between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. We do not believe in tak ing risk that may cause a crash that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. The pilot(s) have lo gg ed numerous practi ce f lights in remote areas as hobbyists simulating flights for future commercial use to gain familiarizat ion with the characteristics of this specific UAS's performance under different temperature and weather conditions. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** , pilots are extremely cautious when operating UAS/ultralight we ight unmanned aircraft and will not “create a ha zard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to in tegrate UAS's into the national airspace system. **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** ’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security. IV. How **AE RI**  **AL MEDIA CONCEPTS, LLC**  Request Wi ll Benefit the Public As A W hole: Aerial photography/videography for Closed

- Set Film Operations on Film and Television Productions, aerial videography/cinematography to safely enhance films and commercials; augmentation of real estate listings; obtaini ng visual aids for disaster assessment, topography aids for Search and Rescue (SAR) missions; UAS education; agricultural inspections; building, construction and utility surveys and inspections ha ve been around for a long time through5

5 manned fixed wing aircraft and helicopters. I specifically have operated aerial videography services using fixed mounted gyro

- stab i lized camera platforms with fixed wing aircraft. Since the development of UAS, demands for this method of gathering aerial services has practica lly died off. For small budget companies, average homeowners and property owners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense; depriving non

- l uxury owners and lower budget companies from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that communities across the USA has experienced in the past with various forms of manned aircraft, med ical helicopters and small general aviation aircraft crashes within the state. Many of which have included post

- c rash fires from combustible fuel that exploded and burned up on impact. Police helicopters have made emergency hard landings and there continues to be many documented medical helicopter crashes across the nation

. **AE RI**  **AL MEDIA**  **CONCEPTS, LLC**  's, a UAS poses no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed tha t it is in the public’s interest to integrate commercially flown a UAS's into the national airspace system, hence the passing of the Reform Act. Granting **AE RIA**  **L MEDIA CONCEPTS, LLC**  ’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the Continental United States of America and its territories

. Our ultralight we ight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultralight weight UAS crashing is far less than a full 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 furthered by minimizing ecological and crash threat by permi tting aerial video/photo capture through my battery operated ultralight weight UAS's. Permitting **AE RIA**  **L MEDIA CONCEPTS, LLC**  , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially fu rthers the e conomic impact for communit ies. V. Reasons W hy **JOSHUA GRIMES (A** **ERI AL** **MEDIA CONCEPTS, LLC)**  ’s Exemption Wi ll Not Adversely Affect Safety Or How The Exemption Wi ll Provide a Level of Safety At Least Equal To Existing Rule: **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovat ion and implementation of new and novel, as of yet undiscovered safety protocols for Realtors, land and structured owners. In addition **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** , submit the following representations of enhancements to current aerial videography and photo graphy: The a UAS’s weigh less than ten ( 10 ) pounds including an integrated ultralight weight camera ; I only operate my a UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); Our a UAS only ope rate for 10

- 30 minutes per flight; We land a UAS prior to manufacturer recommended minimum level of battery power; I pilot6

6 our a UAS through remote control only by visual line of sight; and have a live video feed for a secondary pil ot to monitor video recording; the Pilot receive s a live telemetry feed from the a UAS during all flights which include remaining battery voltage, distance, altitude, and any anomalies that may occur during flight;
The a UAS’s Command and Control utilizes spread spectrum 2.4Gh z- 2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use. The a UAS’s camera system utilizes 5.725Ghz

- 5.875Ghz frequencies in accordance with CFR 47, Part 15. The a UAS’s have a GPS controlled flight controller

- a f light safety feat ure whereby it hovers or circles and then lands at the GPS takeoff point if communication with the remote control pilot is lost; The aUAS actively record s and analyze flight data through the DJI Inspire and DJI phantom flight controller app to constantly update and enhance safety protocols; We only operate in reasonably safe environment that are strictly controlled, away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary importance; The Pilots always obtain all necessary permissions prior to operation; and, have procedures in place to abort flights in the event of safety breaches or potential danger. **AE RIA**  **L MEDIA CONCEPTS, LLC**  ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awa reness real estate, structured inspections, land management and search and rescue. W hile the safety record of such helicopters is remarkably a stounding, there has been incidents involving loss of life as well as extensive property damage; it is far safer t o operate a battery powered ultralight weight UAS. First, the potential loss of life is diminished because UAS's carry no human life on board and I only operate my UAS in specific areas away from mass population. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of our a UAS allow for us to remotely pilot away from and avoid hazards quickly and safely. Final ly, given its small size and weight, even wh en close enough to capture amazing images, our a UAS do not have to be close to the objects they are focused on thanks to the technology and use of post editing software allowing for pan and zoom s . Accordingly, our a UAS has been experimentally operated for fa miliarization/competency and will continue to operate at and above current safety levels. VI. A Summary The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of **AE RIA**  **L MEDIA CONCEPTS, LLC**  ’s, UAS permits exempt ion from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the7

7 airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense popul ations. **AE RI**  **AL MEDIA**  **CONCEPTS, LLC**  ’s, current and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form con templated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certification s and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC**

. B. 14 C.F.R. § 45.23: Markin g of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS can be marked with the appropriate “N” number once this “N” number has been given. C. 14 C.F.R. § 61.113: Private Pilot Pri vileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. **AERI AL** **MEDIA CONCEPTS, LLC**  , The UAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. T he PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** presently has staff that possess a private pilot rating. D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Our a UAS will never operate at an altitude greater t han 2 00f t AGL; safely below the standard of 400 AGL. **AE RIA**  **L MEDIA CONCEPTS, LLC**  , will however operate a UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of the a UAS, an equivalent or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2, Manual8

8 The above

- cited Regulations requ ire, amongst other things, aircraft owners and operators to “have [the] 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. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to **AE RI**  **AL MEDIA CONCEPTS, LLC**  's, UAS. However, as a safety precaution we inspect a UAS before and after each flight. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because **AE RI**  **AL MEDIA**  **CONCEPTS, LLC** ’s UAS meets an equivalent level of safety pursuant to S ection 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the we ight, size, speed, maneuverability and proximity to areas such as airport s and dense populations. Our a UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operati on of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there a re no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** seeks an exe mption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91 .151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate **AE RIA**  **L MEDIA CONCEPTS, LLC**  's, small ultralight we ight UAS to gather Aerial photography/videography for closed

- set film operations on film and television productions, aerial videography/cinematography to safely enhance films and commercials; augmentation of real estate listings; obtaining visual aids fo r disaster assessment, topography aids for Search and Rescue (SAR) missions; UAS education; agricultural inspections; building, construction and utility surveys and inspections , and to develop economic platforms for the aforementioned to enhance the experi ence of thos e seeking to promote, relocate, rebuild, ree valuate and to find with in the Continental United States of America.9

9 **F. A dditional FAA** 

**Required Operating Conditions and Limitations** Wh en not covered elsewhere in this Operations Manual, the following conditions and limitations apply: 1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and equipment 2. The UA may not be flown at a speed exceeding a ground speed of 85 knots. 3. Flights must be operated at an alti tude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL. 4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's state driver’s license. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VL OS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. If a discrepancy exists between these limitations and any procedure outlined elsewhere in this operations manual, the conditions and limitations herein take precedence and must be followed. 7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenanc e and alterations must be properly documented in the aircraft records. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. 9. The operator must follow the manufacturer's UAS aircraft/component, maintena nce, overhaul, replacement, inspection, and life limit requirements. W hen unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. At a minimum, the following must be included in the operator's manual:10

10 a. Actuators / Servos b. Transmission (single rotor) c. Powerplant (motors) d. Propellers e. Electronic speed controller f. Batteries g. Mechanical dynamic components (single rotor) h . Remote command and control i. Ground control station (if used) j. Any other components as determined by the operator 10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a current state driver’s license. Th e PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 11. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under this grant of exemption to accompli sh the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered non - participants, and the PIC must operate the UAS with appropriate distance from n on participants in accordance with 14 CFR § 91.119. 12. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency fli ghts can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off and landing currency flights, all persons not essential for flight operations are considered non

participants, and the PIC must operate the UAS with appropriate distance from non

- participants in accordance with 14 CFR § 91.119.11

11 13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be docume nted and made available to the Administrator upon request. 14. Prior to operations conducted for the purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator

- approved and

- qualified pilot must be succe ssfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test s tandards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual. 15. The UAS may not be operated directly over any person, except aut horized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.
16. Regarding the distance from participating persons, the operator’s manual has safety miti gations for authorized and consenting production personnel. At all times, those persons must be essential to the closed

- set film operations. Because these procedures are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television Fi lming

. 17. Regarding distance from non

- participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced t o no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers,12

12 etc. Such barriers may protect non

- participating persons (observers, the public, news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre
- determined location within the security perimeter and land or be recovered in accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the security perimeter and land or be recovered in accordance with the operator’s manual.
19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in acco rdance with the operator’s manual. 20. Each UAS operation must be completed within 30 minutes flight time or with 25% b attery power remaining, whichever occurs first. 21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation

. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
23. The operator must develop procedures to document and mainta in a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator’s manual. 24. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 25. The operator must develop UAS technician qualification c riteria. These criteria must be added to the operator’s manual.13

13 26. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropr iate government oversight agency requirements. 28. At least three days before scheduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed film ing. 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 person responsible for the UAS filming production under this grant of exemption c. Name and phone number of the person responsible for the on

- scene operation of the UAS. d. Make, model and serial or N

- number of the UAS to be used e. Name and certificate number of the UAS PIC's involved in the filming production event 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 must be made available to the inspector upon request. g. Signature of exemption

- holder or representative h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filmin g will be conducted and the altitudes essential to accomplish the operation 29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC at the ground control station of the UAS any time the aircraft is operating. These documen ts must be made available to the Administrator or any law enforcement official upon request.
30. The UAS must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight veh icles, parachute activities, parasailing activities, hang gliders, etc.).14

14 31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 32. The UAS cannot be operated by the PIC from any moving device or vehicle. 33. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 34. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 miles of the geographic center of a non

-towered airport as denoted on a current FAA

- pu blished aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be mad e available to the Administrator upon request.
35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided. Currently, the aforementioned aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel which p os e a potential risk to the public. Granting **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** ’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fue l, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, we operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. **AE RIA**  **L MEDIA CONCEPTS, LLC**  , have been informally analyzing and recording flight information and will compile safety protocols and the implementation of a flight operations manual for usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board **AE RIA**  **L MEDIA CONCEPTS, LLC**  ’s,15

15 UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** ’s, operation of my UAS, weighing less than forty (40) pounds and traveling at lower speeds within limited areas low to the ground will provide an equivalent level of safety as that achieved under current FARs. Accordingly , **AE RIA**  **L MEDIA CONCEPTS, LLC**  , respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted, **JOSHUA**

**GRIMES AE**  **RI AL** **MEDIA**

**CONCEPTS, LLC 384 Spring Farm Trail**  Shepherdsville, KY 4016516

16 10 Appendix A 

### List of Aircraft

No. Make and Model Description Registration No. 1 DJIInspire Electric powered, 8 rotor, small unmanned multirotor helicopter Pending 2 DJIPhantom Electric powered, 4 rotor small unmanned multirotor helicopter Pending

DJI INSPIRE The operation of the DJI INSPIRE system is as follows. 1. Build Materials I. Plastic II. Aluminum 2. Motor Configuration I. The DJI INSPIRE flight in a 4 motor quadcopter setup. , 3. Payload I. The DJI INSPIRE flies it’s own light

-weight integrated camera. II. Ma ximum All

- up weight

- 6lbs 4. Maintaining the DJI INSPIRE I. Before each flight: 1. Check all hardware to ensure it is securely tightened. 2. Check that the motor is level and locked in place. 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, st ress, 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 5. Check all navigational lighting to ensure it is properly working. II. After 45 hours of flight 1. Remove and check all motors and motor mounts for s ig ns of wear and tear. Replace as necessary. 2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.17

17 Appendix B 2. DJI Phantom The operation of the DJI Phantom system is as follows. 1. Build Materials I. Plastic II. Aluminum 2. Motor Configuration I. The Phantom flight in a 4 motor quadcopter setup. , 3. Payload I. The Phantom it’s own integrated camera. II. Maximum All

- up W eight

- 4lbs 4. Maintaining the Phantom I. Before each flight: 1. Check all hardware to ensure it is securely tightened. 2. Check t hat the motor is level and locked in place. 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 5. Check all naviga tional lighting to ensure it is properly working. II. After 45 hours of flight 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary. 2. Remove motor controllers and visually inspect and check for damage. Replac e as necessary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying

. 5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work. **AE RI**  **AL MEDIA** 

**CONCEPTS, LLC** , **Shepherdsville, KY**

. Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre

-flight pre paration and during flight. Pre

- Fl ight Protocol: Check batteries with voltage meter to insure fully charged and ready for use. Inspect batteries for damage or leakage that may affect proper operation. Inspect propellers for cracks, chips or damage that may cause sudden loss of propul sion or18

18 unmanageable/uncontrolled flight. Check all GPS and Telemetry connections prior to flight. Check weather forecasts for wind advisory or other conditions that my impact flight. Consult FAA and AOPA resources for TFR, NOTAM and aeronautical c harts for airport vicinity and flight paths of possible air traffic or restricted flight information

. Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent informat ion. **Inspect flight area for** Vicinity of public safety helipads/heliports Vicinity of medical helipads/heliports Vicinity of light poles vicinity or utility wires Vicinity of trees flocks of birds that may cause interference and potential flight impact Vicinity of any elevated obstructions that may pose potential flight hazard Vicinity of roadways with moderate to heavy traffic that can be distracted public Gatherings that may attract viewers optional point of control for best visual site of UAS wh ile in flight Emergency landing areas **Takeoff and landing** Inspect area for best and safest point of takeoff and landing If in a subdivision or area that is within 150 feet of a residential street, post warning Sign(s)/stand(s) "Attention Aerial Photography In Progress Remain Back 150 Feet " **Flight Protocol:** takeoff and land from same location (have alternate landing areas in case of emergencies) remain alert to birds, sound or aircraft, curious public, and a pproaching vehicles do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to minimal elevation sufficient to acquire desired results remained prepared for emergency landing at all times pay attention to flight t ime

– warning meter for low voltage. Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut down propulsion immediately following landing

– priority of disconnecting batteries **Post flight:** 1. a) Disconnect battery to prevent accidental activation of propulsion system 2. b) Secure UAS in a safe location19

19 c) Remove all warning signs from public access areas Emergency or Suspected Hazard: Immediate land UAS at safest and closet ground location in the event Man ned aircraft is heard or seen in vicinity of flight There is a public gathering within established safety boundary wanting to observe flight Pilot is being distracted from focusing on flight and safety Sudden change in weather (wind bursts) Sudden increase in vehicular traffic in vicinity of flight Birds enter into proximity of flight Any sudden unsafe event that can cause collision, distraction or interruption of control Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. Ma intaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative

.20

20 Date:____________________ Location:___________________________________________________
pre f light Inspection: o Yes o No Comment: _________________________________________________ Elements Proximity to airport: _________________ (see attached map pinpointing approximate location of flight) Airport notified: No Yes Date:_______________ Time: ______________ Phone Number: _____________ Contact Name:________________________ Nearest major intersection:______________________________________________________ Proximity to medium traffic road: _________________________________________________ Proximity to heavily traveled roadway road: ________________________________________ Proximi ty to congested population: ________________________________________________ Approx. Takeoff Time : GMT: We ather Good Fair Poor Comment : Visibility Good Fair Poor Comment : Wi nd Speed ___mph ___Gusts/MPH ___avg/MPH Comment : Approx. Landing Time: GMT: Estimated Elevation Ground level: Safety Concerns: Additional Comments: sea level:21

21 **Ap pendix 'D'** 


### Aircraft Manuals This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and illustrated parts ca talogs. These manuals may be attached electronically to the docket when submitted. Information regarding design, aircraft performance, fail

- safe features, operating limitations, normal and emergency procedures, and maintenance and inspection procedures is contained within the manuals and supplemental information documents listed below:
1. DJI Inspire Manual V1.0 2. Inspire 1 Maintenance Manual v1.0 3. Intelligent Flight Battery Safety Guidelines v1.4 4. Inspire 1 Safety Guidelines 5. Phantom 3 Professional Manual V1.0 6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)

For more information or questions about this manual please contact: **Ae rial Media Concepts, LLC**  **384 Spring Farm Trail**  **Shepherdsville, KY 40165 502**  **- 376**  **- 1525**