U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 1

Anthony Oyedeji Full Fledge Entertainment, LLC
3603 Chenevert St. #401 Houston, Texas 77004

p : ( 832) 303

- 0396

e : fullfledgeent @gmail .com

May 2 8 , 2015

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

Re: Petition of Full Fledge Entertainment, LLC for Grant of Exemption Pursuant

to Section 333 of the FAA Modernization and Reform Act of 2012

.

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, R egulatory Docket No. FAA

- 2014

- 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA 2014 0355 in the matter of the petition of FLYING CAM INC

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), Full Fledge Entertainment , LLC , herein referred to as "FFE," hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA)

, so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 33 3.

The requested exemption would permit FFE to pursue its commercial interests in providing services to clients using small advanced UAS in the following areas:

• Video /Film Production

• Marketing

• Surveying

• Industrial Inspection

• Special EventsU.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 2

The petitione r has provided the following information to support its request for an exemption:

• Attachment1_AeriCam X6

-- Flight Check List.pdf

• Attachment2_WooKong

- M_Quick_Start_Guide_v1.14_en.pdf

• Attachment3_7c

- manual .pdf

• Attachment4_Inspire_1_Safet y_Guidelines_en .pdf

• Attachment5_Inspire_1_Maintenance_ManualV1.0_en.pdf

• Attachment6_Inspire 1 Checklist

Title 14, Code of Regulations sections from	which	exemption	is	requested : Part 21 ; 45.23 ; 6 1.113(a) & (b) ; 61.133 ; 91.7(a) ; 91.9(b) ; 91.109 ; 91.119 ; 91.121 ; 91.151(a) ; 91.203(a) & (b) ; 91.407

– 91.417

.

Unmanned Aircraft System

UAS are often more practical than helicopters as aerial video and photography gathering platform due to the size, purchase cost, operating cost, reduced noise and as such, has a much smaller environmental impact which promotes environmental and public safety.

FFE is petitioning for an exemption to operate an Aericam X6 and a DJI Inspire 1. The Aericam X6 and DJI Inspire 1 offer an advanced built

- in gimbal syste m, can carry

an Ultra High Defenition (UHD) camera, has GPS, live point of view camera feed, flight telemetry, monitors and controls for power levels, height and distance limits, a No

- Fly Zone feature to exclude it from operations within designated Class B , C and D airspace,
and a return to home function. Both UAS platforms have failsafe functions that are triggered in the event that communication is lost between the UAS and the main controller transmitter. At that time, the UAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set
below:

• The petitioner will only operate its UAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are ‘sufficient distance’ from populated areas within the sterile area described in the FOPM. Such operations will ensure that the UAS will “not create a hazard to users of the national airspace syste m or the public.”

• When flying the UAS within three (3) miles of an airport, airport operators will be

notified and the operator will give the right

- of

- way to avoid flying in the proximity of
full

- scale aircraft.U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 3

• Maximum flight time for each operation will be 30 minutes.

• Minimum crew for each operation shall consist of: UAS pilot, a visual UAS observer,

and/or the camera operator.

• The UAS operated by the petitioner weighs less than 55 pounds, including all payload

(i.e. camera, lens, and stabilized gimbal).

• The UAS will operate at speeds of no mor e than 50 knots, can hover, and

can simultaneously move vertically and horizontally

. Given the small size of the UAS
and the restricted sterile environment in which it will operate, FFE's operations adhere to the Reform Act’s safety requirements. The fact that FFE's more than two years of successful UAS piloting experience demonstrates ou r high regard for safe operations with an understanding of FARs, pre

- flight inspections, knowledge of operations and differences in airspace classifications, maintenance and repair, as well as being trained to high safety standards.

Under the requested ex emption, FFE ensures all operators have completed UAS education and training programs including applicable regulations

, guidance documents

, and s afe o perations p rocedures.

We respectively request exemption under Section 333 to enable FFE to operate
efficie nt, limited, low

- risk commercial UAS operations for the activities stated respecting at all times the space and privacy of citizens and property while keeping airspace safe.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

FFE requests an exemption from the following FARs as well as any additional regulations that may technically apply to the operation of our UAS:

Part 21. Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness
certificate. While the FAA cont inues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the Aericam X6 and DJI Inspire 1 under either, or both, of the following provisions:

21.191 Experimental certificates. Experi mental 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.U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 4

(b) Showing com pliance 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, property, or fuel, and will only fly under strict operational requirements. Combined with the UAS lightweight , being constructed primarily of carbon fiber, fiberglass, and plastic, we propose that the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate fo r 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.

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.

Our UAS do 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.

61.113 (a) and (b). Private pilot privileges and limitations: Pilot in Command ; and 61.133 Commercial pilot privileges and limitations.

The regulation provides that no person who holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allow s 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 h ire. 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.

The petitioner requests relief in order to facilitate the utilization of an experienced
UAS operator with the addition of a trained observer. All pre

- flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integratin g civil UAS operation in the National Airspace System.U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 5

91.7(a). 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.

91.9 (b). 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 ens ure 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, the documentation would not be available to the crew
d

uring flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

9 1.109

. Flight Instruction; Simulated instrument flight and certain flight tests.

The regulation states, "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The UAS Sy stem ground

- based control station consists of a hand

- held 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 inst ructor having
"hands

- on" the controls during flight, this technique meets the intent of 91.109 and provides an equivalent level of safety.

91.119

. Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cann ot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAS would be videography, photography or survey of persons, vessels, vehicles or structures, it would be necessary to operate closer than 500 feet to the items
listed.

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations
conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible with out additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”.U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 6

FFE requests a waiver for this condition to allow for reas onable and responsible flights

. O perations will only be flown over property or persons where permission has
been obtained and careful pre

- planning has been performed.

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.

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) CFR 91.121 is inapplicable since the UAS do not have an altimeter and instead utilize electronic GPS
with a barometric sensor for altitude informa tion.

An Above Ground Level (AGL) measurement is transmitted via radio from the
UAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

91.151 (a). Fuel requirements for flight in VFR conditions.

The regula tion provides that no person may begin a flight in an airplane under day

- VFR 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.

As discussed in Exemption 11136 (ADVANCED AV IATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808 , and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding

rem aining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed
operat ions, The FAA found that a reduced minimum power reserve for flight in daytime
VFR conditions was reasonable.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAS is battery operated and the maximum duration of flight from a single battery charge is 22 minutes with a 20% reserve. A full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph.U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 7

91.203(a) & (b)

. Civil aircraft: Certifications requ ired.

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 its maximum gross weight, the UAS 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 located with the crew at the ground control station and available for inspection upon request.

91.40 7

- 91.417. M aintenance, 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 t he aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) FFE propose to inspect and ensure that the UAS is in a condition for safe flight in accor dance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure th at safety would not be adversely affected.

It is our intention that the PIC performs maintenance and inspection of the aircraft
and be " authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy cond ition 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 an d firmware for the on

- board computer. The manufacturer or their designated repair facility will perform all other maintenance . 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.U.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 8

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1

- 3, C onditions and
Limitations section

, and believes that the procedures specified therein are reasonable and
will be uti lized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspect ions before each flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safety standards and regulations. The petitioner wi ll only operate the UAS over designated properties with the owner’s consent. Flight plans will be predetermined to limit the UAS flight time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacl es prior to operating the UAS

.
FFE requests that in a manner similar to reference 3, may be allowed to operate within 5 miles of an airport provided that.

“The UA may not operate in Class B, C, or D airspace without written approval
from the FAA. The UA may not operate within 5 nautical miles of the geographic center
of a non

- towered airport as denoted on a current FAA published 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 made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but FFE is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in l ieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS
in order to facilita te commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cann ot be displayed through ground level videography/photography. Aerial videography is a valuable marketing tool that can lead to increased commerce. Aerial surveying and inspections can increase work site efficiency, improve volumetric
estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control Unit operation time, incident , accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part ofU.S. Department of Transportation Full Fledge Entertainment, LLC

– Petition for Exemption

- FAA Section 333 Page 9

this application. This data may be submitted to FAA via traditional means or other means

as req uired.

Conclusion

FFE is requesting this exemption for the purposes of aerial photography, cinematography, videography, inspections and other data collection operations. The reason for such a general and broad based request is that the petitioner wishes t o utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner's busines s hopes to offer UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business. The primary purpose of seeking this exemption is to obtain the capability to offer the aforementio ned services while remaining in compliance with the FAA.

We thank you for your prompt consideration of our requested exemptions. Should you have any questions, or need additional information to support the requested exemptions, please feel free to contac t the undersigned.

Yours truly,

Anthony Oyedeji, Owner

Full Fledge Entertainment, LLC