StoryView Video, LLC

Attn: Paul Russell

622 Laura Drive

Falls Church, VA 22046

Email: paul@storyviewvideo.com

Phone: (703) 618­0207

April 2, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room Wl2­140

1200 New Jersey Avenue, SE

Washington, DC 20590 VIA ELECTRONICALLY

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 45.29; 14 CFR

61.113(a) and (b); 14 CFR 61.133; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14

CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b);

14 C.F.R. 91.205 (b); 14 C.F.R. 91.215; 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR

91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b); and 8900.227 Paragraph 16(c)(4) and

Paragraph 16(e)(1)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform

Act") and 14 C.F.R. Part 11, StoryView Video, LLC, operator of a Small Unmanned Aircraft

System (sUAS), which includes the Unmanned Aircraft (UA) and ground station­based

equipment and crew described below, seeks an exemption from Federal Aviation Regulations

("FARs") detailed below, to allow commercial operation of its sUAS, 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.

Commercial operation of the sUAS, as described herein, which is equipped with camera(s)

and sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but

not limited to electrical power lines, wind turbines and cell towers.
5. 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 authorities or

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to

increase awareness and improve safety for current and future UAS operations within the

NAS.

As described fully below, the requested exemption would permit the operation of the

designated small sUAS as set forth in this document under controlled conditions in the NAS

that would be a) limited b) controlled c) predetermined and d) safe. Approval of this

exemption would increase public awareness of sUAS operations and enhance safety to aid in

fulfilling the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to

“....establish requirements for the safe operation of such aircraft systems in the national

airspace system.”

The name and contact information of the applicant are:

StoryView Video, LLC

Attn: Paul Russell

622 Laura Drive

Falls Church, VA 22046

Email: paul@storyviewvideo.com

Phone: (703) 618­0207

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 45.29

14 CFR 61.113 (a) & (b)

14 CFR 61.133

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2)
14 CFR 91.417(a) and (b)

8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

StoryView Video, LLC, will operate the following model Small Unmanned Aircraft System

(sUAS), which includes the Unmanned Aircraft (UA) and ground station­based equipment and

crew.

THE UNMANNED AIRCRAFT (UA):

• The DJI Phantom 2, with a total weight of 1000g, or 2.205 lbs., including battery and

propellers is a lightweight, battery operated, 4 motor rotorcraft in the form of a quadcopter that

takes off and lands vertically, manufactured by DJI, PHANTOM 2 model, modified by the

applicant to carry the following equipment in flight:

• A Zenmuse H3­3D GoPro Gimbal 3­axis camera stabilization system;

• A GoPro 3+ on­board camera capable of capturing imagery in the form of full color, high

definition still photos and video;

• An on­board flight computer with GPS navigation and location ability that receives signals for

flight controls from a ground­based transmitter/controller;

• Capability for an on­board telemetry system that delivers flight data from the on­board flight

computer to the on­board radio transmitter including altitude AGL, horizontal and vertical

speed, compass direction of flight and direction back to its launch site;

• Capability for a 600mW 5.8GHz on­board radio transmitter that transmits live video from the

on­board camera plus all the flight data from the telemetry system described above.

• The diagonal length is 350mm.

• Under still air, the maximum speed is 15 m/s, or 33.55 mph, or 30 knots.

• The DJI Phantom 2 is powered by a 5200 mAh, 11.1V LiPo battery powering four E300

model motors.

THE GROUND STATION­BASED PART OF THE SYSTEM:

• A Pilot in Command (PIC) in operational control of a flight operation from beginning to end

and who controls the UA while in the air;

• A 100 mW, 2.4GHz ISM radio transmitter/controller ​operated by the PIC to control the UA

while in flight;

• A Visual Observer (VO) who provides a second pair of eyes to visually track the UA while in

flight;

• Capability for a radio receiver that receives live video and flight data from the on­board

camera and computer, and projects it all together onto a screen for the PIC to view during

flight.

The sUAS will be equipped with a camera and camera stabilizing gimbal, and have the

capability to be equipped with an OSD (on screen display) which provides the PIC with

altitude, airspeed, battery life and direction.
Our sUAS flight controllers utilize GPS to limit the altitude above the ground, to limit the radius

of the distance it flies from the PIC, and to exclude it from operations within designated Class

B, C and D airspace including a no­fly zone feature.

Our sUASs have GPS guided failsafe functions allowing the autopilot system to fly back to the

launch site autonomously. If the transmitter is disconnected the system will automatically

trigger the return to home function and will land safely. If the connection is restored, the PIC

can regain control of flight and land manually.

Our sUASs will manually operate only in VLOS and will operate only within a sterile area such

as is described in the Flight Operations Manual (FOM) attached as Appendix A ​(hereinafter

“the Manual”). Adherence to the Manual will ensure that the sUAS will “not create a hazard to

the national airspace system or the public.”

Given the small size and weight of the sUAS involved and the restricted sterile environment

within which it will operate, the applicant falls squarely within that zone of safety (an

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption,

allow commercial operations of sUASs to commence immediately. Also due to the size of the

sUAS and the restricted areas in which the relevant sUAS will operate, approval of the

application presents no national security issue. Given the clear direction in Section 333 of the

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong

equivalent level of safety surrounding the proposed operations, and significant public benefit,

including enhanced safety, reduction in environmental impacts, including reduced emissions

associated with allowing sUASs for movie and television operations, the grant of the

requested exemption is in the public interest. Accordingly, the applicant respectfully requests

that the FAA grant the requested exemption without delay.

PILOT IN COMMAND AND OBSERVER QUALIFICATIONS AND DUTIES

The PIC will maintain at least a Private Pilot Certificate ​and a current Class III medical

certificate, or pass a knowledge test in order to obtain an FAA­approved drone operator

license and be vetted by the TSA. The PIC will take a recurrent test every 24 months and be

at least 17 years old.

The PIC will be allowed to fly during daytime hours only and must be able to see the drone at

all times (though a second operator can be used as an observer). The PIC will have a

minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten

hours logged as a UA pilot with a similar UA type, plus have at least 2 hours flying time and 3

takeoffs and landings within 30 days in the type of sUAS utilized in operations.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties

include all preflight preparation, in flight operation and post flight requirements. Procedures

include but are not limited to:

Safe flight operations
Risk assessment and mitigation to persons and property

Site suitability

The Visual Observer (VO) must have the visual acuity to observe the sUAS and be able to

communicate clearly with the PIC utilizing hand signals, verbal communications, or 2 way

radios.

The Visual Observer’s duties are:

Notifying the PIC of any impending obstacles in the flight path of the sUAS.

Notifying the PIC of any deviations in the planned flight path of the sUAS.

Notifying the PIC if unauthorized persons enter the area of the planned flight.

HOW THIS REQUEST IS TO THE BENEFIT OF THE COMMUNITY AND/OR PUBLIC

The requested exemption would support an application for a commercial Certificate of

Authorization to use the above described sUAS to conduct aerial videography and

photography to enhance academic community awareness for those individuals and

companies unfamiliar with the geographical layout of the Washington D.C. metropolitan and

surrounding area, including Northern Virginia, Maryland, and Delaware, as well as to augment

real estate listing videos.

Aerial videography for geographical awareness and for real estate marketing has been

around for a long time through manned fixed wing aircraft and helicopters. For small budget

real estate companies and average homeowners 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 non­luxury homeowners and lower budget Realtors

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.

The sUAS, powered by batteries, is smaller, lighter, and more maneuverable than larger

aircraft running on combustible fuel, it operates at lower altitudes with no people on board,

and will thereby reduce current risk levels and enhance safety and diminish the likelihood of

death or serious bodily injury. With a small payload and maximum flight time of only 25

minutes with maximum air speed of 30 knots, there is little or no risk to national security.

Granting StoryView Video, LLC’s exemption request furthers the public interest through

academic/visual awareness of the geographical benefits in and around the greater

Washington D.C. metropolitan area. Our ultra lightweight sUAS is battery powered and

creates no emissions that can harm the environment. The consequence of our ultra

lightweight sUAS crashing is far less than that of a full size helicopter or fixed wing aircraft

which are heavy, contain combustible fuel and can cause catastrophic devastation to the

public.
Low­level oblique photos and video from several angles are far more effective than ground

based imagery for displaying the characteristics of large, complex properties with several

buildings and large trees. In the past, 2­seat full­sized helicopters have been chartered for this

purpose, which has proven more costly than many potential clients of this service have been

able to afford. The benefits of reduced cost and improved quality of presentation from the

sUAS will be valuable to and benefit many buyers and sellers of real property, as well as other

potential users and applications.

Additionally, we request that we be allowed to use our system to benefit first responders

nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while

remaining subject to all limitations cited in this application as we do so.

GENERAL OPERATING STANDARDS

The operation restrictions proposed provide for an equivalent or higher level of safety

because operations will further enhance the safety of the persons and/or property using

conventional aircraft. The restrictions and conditions to which the applicant agrees to adhere

to when conducting commercial operations under the FAA issued exemption as set forth in

the Flight Operations Manual (FOM) include:

1. No flight will be made with a sUAS Gross weight exceeding 55 pounds.

2. The sUAS will operate at a maximum speed of no more than 30 ​knots and no further than

3/4 NM from the PIC.

3. Flights will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC)

and/or Visual Observer (VO).

4. Maximum total flight time for each operational flight will be 25 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 25 minute limit.

5. 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.

6. Minimum crew for each operation will consist of the sUAS Pilot and at least one Visual

Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The sUAS pilot will be a designated Pilot in Command (PIC) and meet the requirements of

one of the following:

a. Hold a Private Pilot Certificate with a Third Class Medical Certificate and at least 20

hours of logged sUAS flight time, or be a separate but equivalently sUAS­trained

operator under the direct supervision of a Private Pilot. Or,

b. Pass a knowledge test in order to obtain an FAA­approved drone operator license, and

be vetted by the TSA. The PIC will take a recurrent test every 24 months and be at

least 17 years old. The PIC will be allowed to fly during daytime hours only and must

be able to see the drone at all times (though a second operator can be used as an

observer).

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft

pilot and at least ten hours logged as a UA pilot with a similar UA type.
8. A safety briefing will be performed prior to each day’s flights consisting of all the days’

production activities. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace, unless otherwise approved by the FAA,

and no closer than in a 5­mile radius of the geographic center/Airport Reference Point (ARP)

of a tower controlled or uncontrolled airport.

12. If operations will be within a 5­mile 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 information.

13. The operator will file FAA Form 7711­1, 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.

14. The 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 equivalent level of safety

determination, as U.S. Department of Transportation required under the FOM. With the

advanced permission of the FSDO, operations at closer range may be approved.

15. Operations will be restricted to flights over private property with the permission of the

property owner.

16. The PIC will brief the VO and property owner about the operation and risk before the

first flight at each new location.

17. Written and/or verbal permission from the relevant property holders will be obtained.

18. The sUAS will not be operated over densely populated areas.

19. The sUAS will not be operated at air shows.

20. The sUAS will not be operated over any open­air assembly of people.

21. The sUAS will not be operated over heavily trafficked roads.

22. The PIC and VO will have been trained in operation of sUAS and receive up­to­date

information for the particular sUAS to be operated.

23. The PIC and VO will be able to communicate by voice and/or radio at all times during a

flight operation.

24. 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 as appropriate to flight operations.

25. If the sUAS loses communications with the remote controller or loses GPS signal, the

sUAS will have the capability to return to a pre­determined location within a designated

location and land autonomously.

26. The sUAS will have the capability to abort a flight in case of unpredicted obstacles,

weather, or emergencies such as low battery, safety breaches, or potential danger.

27. Operations will be restricted to day only and weather conditions equivalent to VFR.

28. No flight may be made without a Pre­Flight Inspection by the PIC before each operation
to ascertain that the UA is in a condition safe for flight.

29. The operator will develop procedures to document and maintain a record of the sUAS

maintenance, preventative maintenance, alterations, status of replacement/overhaul

component parts, and the total time in service of the sUAS.

30. Each sUAS operated under this exemption will comply with all manufacturer safety

bulletins, firmware, and software updates.

31. The operator will comply with the manufacturer's recommendations pertaining to

maintenance, inspection and replacement of sUAS components.

32. Before conducting operations, the radio frequency spectrum used for operation and

control of the sUAS will comply with the Federal Communications Commission (FCC).

33. The sUAS will remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, hang gliders, etc.).

34. The sUAS will not operate in Class B, C, or D airspace without written approval from the

FAA.

35. The sUAS will not be operated by the PIC from any moving device or vehicle.

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16

personnel Qualifications. Additionally, the PIC will perform maintenance on the system and

will complete a course of maintenance instruction as part of the PIC’s initial training.

We submit that the combination of the UA's light weight, flight performance and ability, fully

qualified flight crew, and strict operation under the guidelines established in 8900.227, and

under all of the Restrictions (1) through (35) listed above, the FAA can have full confidence

that the operation will have an equivalent or greater level of safety than manned aircraft

performing the same mission.

Given the small size of the sUAS in scope and the controlled environment provided, the

proposed operations will adhere to the Reform Act’s safety requirements. The approval 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 of the requested exemption is in the

public interest. Accordingly, the applicant graciously requests that the FAA grant the

requested exemption.

We are prepared to modify or amend any part of this request to satisfy the need for an

equivalent level of safety. Please contact us at any time if you require additional information or

clarification. We look forward to working with your office.

Sincerely ,

Paul Russell

StoryView Video, LLC
Addendum ­ Exemption Requests and Equivalent Level of Safety

Appendix A ­ Flight Operations Manual

Appendix B ­ Phantom 2 User Manual

Appendix C ­ Phantom 2 Quick Start Guide

Appendix D ­ Smart Flight Battery Safety Guidelines
ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

StoryView Video, LLC, requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of the sUAS:

14 CFR Part 21, Subpart H: Airworthiness Certificates.

This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we

request an experimental certificate be issued for the sUAS under either or both of the

following provisions:

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) ​Research and development. ​Testing new aircraft design concepts, new aircraft

equipment, new aircraft installations, new aircraft operating techniques, or new uses for

aircraft.

(b) ​Showing compliance with regulations. ​Conducting flight tests and other operations to

show compliance with the airworthiness regulations including flights to show compliance for

issuance of type and supplemental type certificates, flights to substantiate major design

changes, and flights to show compliance with the function and reliability requirements of the

regulations.

Since the experimental certificate can be used for commercial purposes such as market

surveys, sales demonstrations, and customer crew training, we would expect that an

experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict

operational requirements. Combined with the UA’s light weight, being constructed primarily of

carbon fiber and plastic, we propose that the UA will be at least as safe as, if not safer than, a

conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we

request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness

certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration

number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or

pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be

placed, and may not have a registration number assigned to it by the FAA.
We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL"

in the placard on the top of the aircraft, as indicated above, where the PIC, VO and others in

the vicinity of the aircraft while it is preparing for launch will be able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous paragraph will

provide the aircraft's registration information at the ground station. Finally, we will display at

the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft

Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4

NM of the ground station, the banner should be visible to anyone that observes the aircraft

and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command, and 61.133

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to

act as pilot in command of an aircraft in connection with any business or employment if: (1)

The flight is only incidental to that business or employment; and (2) The aircraft does not carry

passengers or property for compensation or hire.

Our proposed operations require that the PIC must adhere to one of the following:

1. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate"

in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the

FAA Private Pilot written examination." Since the aircraft cannot carry passengers or property,

we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this

application is to conduct a business. Or,

2. Pass a knowledge test in order to obtain an FAA­approved drone operator license, and be

vetted by the TSA. The PIC will take a recurrent test every 24 months and be at least 17

years old. The PIC will be allowed to fly during daytime hours only and must be able to see

the drone at all times (though a second operator can be used as an observer).

The petitioner asserts that under § 61.113 (a) and (b) private pilots are limited to

noncommercial operations, however he can achieve an equivalent level of safety as achieved

by current regulations because his sUAS does not carry any pilots or passengers. Further, he

states that, while helpful, a pilot license will not ensure remote control piloting skills. He further

indicates that the risks of operating a UAS are far less than the risk levels inherent in the

commercial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from

§ 61.113 Private Pilot Privileges and Limitations: Pilot in command.

Regarding sUAS operational training, the petitioner states he has flown practice flights in

remote areas as a hobbyist simulating flights for future commercial use to gain familiarization

with the characteristics of his sUAS’ performance under different temperature and weather

conditions.

14 CFR 91.7 Prohibits the Operation 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 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that

flight manual information is available to the aircrew while operating the aircraft. We request an

exemption to this requirement since the aircraft is not only too small to carry documentation,

but also since the documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current,

approved UA Flight Operations Manual (FOM) (Appendix A) must be available to the crew at

the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR Part 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to ensure

the safety of the flight. As FAA approved rotorcraft flight manuals will not be provided for the

aircraft, an exemption will be needed. The operating pilot will take all actions as stated in the

FOM under normal procedures including but not limited to reviewing the weather, flight battery

requirements, landing and takeoff distances, and aircraft performance data before initiation of

flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests.

The regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls."

The UA System ground­based control station consists of a small hand­held radio transmitter

and while it does not offer a second set of "controls", both the student and instructor can, and

will, operate the single set of controls simultaneously. With both student and instructor having

"hands­on" the controls during flight, we feel that this technique meets the intent 91.109 and

provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated

closer than 500 feet to any person, vessel, vehicle, or structure.

Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this

requirement.

In order to provide an equivalent level of safety we will only fly over private property with the

permission of the owner of the property flown over. The aircraft will not be operated over

congested areas or over any open air assembly of persons. The property owner will be

briefed on the expected route of flight and the associated risks to persons and property on the

ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an

emergency landing without undue hazard to persons or property on the surface. Therefore we
maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is

minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in

order to prevent conflict with other aircraft.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day­VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for

delays to landing. The UA is battery operated and the maximum duration of flight from a

single battery charge is 25 minutes with a 20% reserve. Since the aircraft will never fly more

than 3⁄4 NM from the point of intended landing, a full battery charge at launch will ensure that

we meet the reserve energy requirement of this paragraph. We request an exemption to the

word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number

assigned to the aircraft and a registration certificate, must be aboard the aircraft. Additionally,

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or

cockpit entrance so that it is legible to passengers or crew."

At a maximum gross weight of 2.205 ​pounds, the UA is too small to carry documentation,

does not have an entrance, and is not capable of carrying passengers or crew. To obtain an

equivalent level of safety and meet the intent of 91.203, we propose that documents deemed

appropriate for this aircraft by the FAA will be co­located with the crew at the ground control

station and available for inspection upon request. In order to identify the aircraft, we propose

that the information found on airworthiness and registration certificates be permanently affixed

to the aircraft via placard containing the following information plus the word

“EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately

after the proposed placard description below:

EXPERIMENTAL

Manufacturer: DJI Innovations, Inc.

950 E Baseline Ave. Ste. 210

Apache Junction, AZ 85119

Model: Phantom 2

Serial Number: PH645424765

14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use.
This regulation states all aircraft operating within 30 nautical miles of class A, B and C

airspace must be equipped with automatic pressure altitude reporting equipment having a

Mode C capability that automatically replies to Mode C interrogations. Due to the small size

and lifting capabilities of our sUAS we cannot carry a traditional transponder. All of our

operations will be under 250’ if we are operating within the 30mi reach of a mode c veil.

14 CFR Subpart E (91.401 ­ 91.417) ­ Maintenance, Preventive Maintenance, Alterations.

The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized

under 43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be

authorized to approve the aircraft for return to service." As provided in the Pre­Flight

Checklist, the PIC will ensure that the aircraft is in an airworthy condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance

performed by the PIC is limited to repairing small cracks, replacing a propeller, checking

electrical connections and updating software and firmware for the on­board computer. All

other maintenance will be performed by the manufacturer or their designated repair facility.

The PIC will document work performed in accordance with 91.417. We feel that due to the

size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of

safety.

8900.227 Paragraph 16(c)(4) PIC Medical, and Paragraph 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second­class medical

certificate issued under part 67 in order to perform as a pilot or observer.

The UA maximum gross weight is 2.205 pounds, it is constructed of carbon fiber and plastic,

and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the

unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in

flight, the UA will return autonomously to the site of launching and land without crew

intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as

a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected

to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure

that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to

operate a much larger vehicle.

SUMMARY OF SECTION 333 EXEMPTION REQUEST

For publication in the Federal Register, StoryView Video, LLC hereby provides, pursuant to 14

C.F.R. Part 11, the following summary of its exemption application.
To allow commercial operation of an sUAS for aerial photography and video work including

applications and fields such as real estate marketing, architecture, land surveying,

engineering, television, public events, cinematography and newsgathering, an exemption is

requested from the following regulations:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 45.29

14 CFR 61.113 (a) & (b)

14 CFR 61.133

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2)

14 CFR 91.417(a) and (b)

8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

Safety and Benefits of the UAS

StoryView Video, LLC will be using the sUAS in a variety of applications that generally require

expensive full­size manned aircraft to complete. Small, light, unmanned aerial vehicles offer

myriad benefits over the use of full­sized manned aircraft for applications including but not

limited to electric power line inspection, oil/gas pipeline inspection, advanced agriculture,

videography, and photography.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with a small

UAS carrying no passengers or crew creates a much greater margin of safety for the pilots

and crew.

Conclusion

Concluding, the sUAS will not carry persons or property, will not carry fuel, and will only fly

under strict operational requirements. Combined with the UA's light weight and it’s primarily

carbon fiber and plastic construction, we propose that the UA will be at least as safe, if not

safer, than a conventionally certificated aircraft performing the same mission.
By granting StoryView Video, LLC‘s requested exemptions, the FAA will help drive

development of safe and successful commercial UAS operations and will advance the public

knowledge base for such operations. StoryView Video, LLC is committed to promoting the

UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing

data from its commercial UAS operations and serving as a resource for future UAS research

operations. Thus, the FAA has good cause to grant this Petition.

As pointed out in this application, all the sUASs which our company would use, under

authorization by the US DOT­FAA, are small, light­weight devices operated within the line of

sight of the Pilot­in­Command (PIC), less than 400 feet above the ground and outside 5 miles

from any airport, heliport, seaplane base, spaceport, or other location with aviation activities,

unless the air traffic control authorities (ATC) have been notified and have authorized each

flight within a radius of this distance.

All of our sUASs have proven capability for controlled flight. They are devices offered for

general sale on the market around the world and have often been used as Model Aircraft in

the USA. We are certain that the studies conducted until now by the FAA, about Section 332,

Public Law 112­95, 2014, have already provided you with the assurances on the

airworthiness of sUASs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and StoryView

Video, LLC should be permitted to conduct small UAS operations in accordance with its

manuals and all other operating parameters deemed necessary and appropriate by the FAA.

The submission of this application and its contents is the best demonstration that indeed it is

possible to pursue the authorization process so that some sUASs may be used for legitimate

commercial activities and under reasonably safe conditions.

StoryView Video, LLC seeks an exemption pursuant to 14 C.F.R. and Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of its sUAS

commercially, without an airworthiness Certificate. By granting this Petition, the FAA

Administrator 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 StoryView

Video, LLC to safely, efficiently, and economically operate sUASs commercially within the

NAS. Wherefore, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, StoryView Video, LLC respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of

14 C.F.R Sections.

APPENDIX A ­ FLIGHT OPERATIONS MANUAL (FOM)

GENERAL OPERATING STANDARDS

1. No flight will be made with a sUAS Gross weight exceeding 55 pounds.

2. The sUAS will operate at a maximum speed of no more than 30 ​knots and no further than

3/4 NM from the PIC.

3. Flights will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC)

and/or Visual Observer (VO).

4. Maximum total flight time for each operational flight will be 25 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 25 minute limit.

5. 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.

6. Minimum crew for each operation will consist of the sUAS Pilot and at least one Visual

Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The sUAS pilot will be a designated Pilot in Command (PIC) and meet the requirements of

one of the following:

c. Hold a Private Pilot Certificate with a Third Class Medical Certificate and at least 20

hours of logged sUAS flight time, or be a separate but equivalently sUAS­trained

operator under the direct supervision of a Private Pilot. Or,

d. Pass a knowledge test in order to obtain an FAA­approved drone operator license, and

be vetted by the TSA. The PIC will take a recurrent test every 24 months and be at

least 17 years old. The PIC will be allowed to fly during daytime hours only and must

be able to see the drone at all times (though a second operator can be used as an

observer).

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft

pilot and at least ten hours logged as a UA pilot with a similar UA type.

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’

production activities. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace, unless otherwise approved by the FAA,

and no closer than in a 5­mile radius of the geographic center/Airport Reference Point (ARP)

of a tower controlled or uncontrolled airport.

12. If operations will be within a 5­mile 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 information.

13. The operator will file FAA Form 7711­1, 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.
14. The 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 equivalent level of safety

determination, as U.S. Department of Transportation required under the FOM. With the

advanced permission of the FSDO, operations at closer range may be approved.

15. Operations will be restricted to flights over private property with the permission of the

property owner.

16. The PIC will brief the VO and property owner about the operation and risk before the

first flight at each new location.

17. Written and/or verbal permission from the relevant property holders will be obtained.

18. The sUAS will not be operated over densely populated areas.

19. The sUAS will not be operated at air shows.

20. The sUAS will not be operated over any open­air assembly of people.

21. The sUAS will not be operated over heavily trafficked roads.

22. The PIC and VO will have been trained in operation of sUAS and receive up­to­date

information for the particular sUAS to be operated.

23. The PIC and VO will be able to communicate by voice and/or radio at all times during a

flight operation.

24. 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 as appropriate to flight operations.

25. If the sUAS loses communications with the remote controller or loses GPS signal, the

sUAS will have the capability to return to a pre­determined location within a designated

location and land autonomously.

26. The sUAS will have the capability to abort a flight in case of unpredicted obstacles,

weather, or emergencies such as low battery, safety breaches, or potential danger.

27. Operations will be restricted to day only and weather conditions equivalent to VFR.

28. No flight may be made without a Pre­Flight Inspection by the PIC before each operation

to ascertain that the UA is in a condition safe for flight.

29. The operator will develop procedures to document and maintain a record of the sUAS

maintenance, preventative maintenance, alterations, status of replacement/overhaul

component parts, and the total time in service of the sUAS.

30. Each sUAS operated under this exemption will comply with all manufacturer safety

bulletins, firmware, and software updates.

31. The operator will comply with the manufacturer's recommendations pertaining to

maintenance, inspection and replacement of sUAS components.

32. Before conducting operations, the radio frequency spectrum used for operation and

control of the sUAS will comply with the Federal Communications Commission (FCC).

33. The sUAS will remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, hang gliders, etc.).

34. The sUAS will not operate in Class B, C, or D airspace without written approval from the

FAA.
35. The UAS will not be operated by the PIC from any moving device or vehicle.

sUAS PRE­FLIGHT CHECKLIST & PROCEDURES

Inspect rotors for shape, cracks, and any signs of loss of integrity.

Inspect / Attach rotors – check rotation direction and nut tension.

Inspect overall vessel for signs of damage and loose connections.

Inspection of motors for smooth, balanced, quiet operation ­ free of debris.

Check UA main battery – at a minimum of 95% of charge.

Check battery – for clean connections & free of defects, swelling, etc

Define flight plan, take off & objectives.

Check flight plan against designated “No Fly Zone” i.e.,: proximity to Airports, Military, etc.

Check wind and weather – look for signs of unusual wind at higher elevations.

Confirm the designated flying area and confirm with all personnel.

Confirm flying area is clear of all restricted air space requirements.

Confirm your VO and VLOS range and verbal communications to be used.

Check for aerial obstructions – utility wires, etc.

Check all wiring connections for tightness.

Check all external devices are attached securely: gimbal, camera, etc., and each has a

safety, ziptie, etc., in case a device comes loose so it does not separate from the vessel.

Check camera lens is clean.

Check camera settings are correct.

Check all control switches are in proper start up position.

Clear and reset flight clock to zero.

Check take off area is clear of objects and persons for 10 ft radius.

Turn on remote controller, check for adequate voltage, set it to connect to the UA.

Turn on the UA main battery, and check for radio contact with UA's remote controller.

If at a location different from previous flight, re­set GPS and compass to current location.

Announce “Stand Clear – We're Powering Up Now!”

Allow the system to complete it's full start up procedure.

Confirm that the system status is flight­ready.

Confirm GPS status, and number of satellites.

Check that battery still indicates operational status at 95% or better

Spin up rotors – listen for any unusual sounds in the system.

Start flight­clock.

Lift off and hover at 4 feet.

Check all status lights on the UV and Controller.

Check that hover is stable (not drifting or erratic).

Check that camera is operational.

Check that all control commands are responsive.

Set current home location for Lost Link: “Return to Home”

Confirm VO readiness, and proceed with the flight plan.
TO REGAIN CONTROL AFTER LOST RADIO CONTACT

1. Failsafe = ON

2. Throttle = 50%

3. Mode = ATTl

4. Failsafe= OFF

Mode = G

*If radio contact is not restored, the UA will automatically continue at 60ft. above its last

elevation before losing contact toward its takeoff point, then descend and land there

autonomously.