# lllt DSHEAR MEDIA llldoo Producl•on LLC ltloiiOn Graphics Visual Effects
April I 7, 2015
U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Petition ofWindshear Media LLC. for Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012
. To Whom It May Concern: Windshear Media LLC. (WM), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial systems (i.e., sUAS) pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 

### 11. This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed WM ' s Operations Manual, the UAS manufacturer's operations and/or instructions manual, UAS User's Manuals, sUAS Quick Start Guides, and any other requirements established by the FAA pursuant to Section 333 ofthe Reform Act. Windshear Media LLC respectfully requests a waiver on the 45

- day comment period, as this application is identical in description to other Section 333 Exem ptions that have already been granted
. This exemption would permit commercial operations by Windshear Media LLC , to use the Dn Phantom 1, on Phantom 2, DJI Inspire 1, and the DJI SlOOO, to conduct aerial photography and videography, agricultural assessment of crops and data collection, news gathering, training and education, support services for public entities , inspections and assessments of structures , real estate photography and videography, and closed set film and movie production
. WM ' s operation under the exemption w111 be subject to specific operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333. Windshear Media LLC submits the Operations Manual as a confidential document under 14 CFR § 11.35(b), the entire content of this manual contains confidential information that WM has not and will not make available to others. This manual contains operating procedures and additional information that is not available to the public and are protected from release under the Freedon of Information Act, 5 USC§ 552 (b) (4).WM has assembled a team ofUAS personnel, including pilots with Commercial and Instructor Ratings, and will be operate sUAS within the National Airspace(NAS) under controlled VFR conditions at or below 400' AGL. They will operate the sUAS with pilots who are current and qualified with a FAA Pilot Certificate and have completed WM's training program. Windshear Media LLC respectfully submits this request for an exemption because it operates sUAS. Currently, the operations ofWM will be conducting will be in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft. The FAA can have confidence that the operations will be conducted at an equivalent level or greater level of safety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under Section 333(c) ofthe Reform Act to "es tablish requirements for the safe operation of such aircraft systems in the national airspace system." For your convenience, WM has organized this Exemption request as follows:


### I. Petitioner's Description II
. Relevant Statutory Authority 

### HI. Qualifications for Approval Under Section 333 ofthe Reform Act IV
. Details ofProposed sUAS Operations

V. Regulations From Which Exemption is Requested Vl. Public Interest Vll. Privacy VIII. Federal Registry Summary

IX. Conclusion


### I. Petitioner's Description: Windshear Media LLC , headquartered in Stevensville, Maryland, is a Production Company that also provides film and movie production services, support to news services, real estate photography , services to first responders , photographic assessment of agriculture, education , and sUAS demonstration flights in a compliant and safe environment. WM plans on providing a wide range of sUAS services as the market expands. The management at WM has over 45 years combined experience in aviation with both helicopter and fixedwing aircraft (including Search and Rescue, Medevac , Law Enforcement, disaster assessment, and Homeland Security.), and over 4 years experience operating sUAS. The Chief Pilot has over 8500 hours in both rotorcraft and fixed wing aircraft, has been a commercial pilot for 29 years, is a Certified Flight Instructor and Instrument Instructor in both Helicopter and Single Engine Land and has been an IP for 20 years. The Chief Pilot is intimately familiar with operational control procedures and overseeing the safe operations of an aviation event. The President has over 24 years working in an aviation and first responder environment as well as over seventeen years in video production and understands the requirements to integrate the sUAS into 2open and closed set television and movie locations. WM's goal is to operate in an accident-free environment by:
• Demonstrating a commitment by management and all employees' to operator in a compliant manner. • Identify hazard and risk while eliminating or controlling all these risk
. They will use steps to intervene and report when unsafe work practices appear to exist. • Train all employees involved in flight operations to operate at the highest standard level. The contact information for Petitioner is as follows: Windshear Media LLC. Attn: Jonathan Cook 305 Chari Court Stevensville, MD 21666 Ph: 443-497-0539 Email: Info@WindshearMedia
.com
ll. 

### Relevant Statutory Authority: This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion ofthe formal UAS rulemaking , based on the following considerations:

• The UAS's size, weight, speed , and operational

**capability~** • Operation ofthe UAS in close proximity to airports and populated

**areas~** and • Operation ofthe UAS within the visual line of sight ofthe operator. If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System". Additional ly, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the pub1ic interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority , by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airvvorthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: 

### The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any ofsections.

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# m. Qualifications for Approval Under Section 333 of the Reform Act The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each ofthe statutory criteria and other relevant factors are satisfied. The proposed operations would permit WM the use of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access ; and that (3) provides an Increased level of s afety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose . WM uses UASs that are multi-rotor, weighing less than 55 pounds including payload
. They operate, under normal conditions, at speeds not to exceed 50 mph
. The multi-rotor has the capability to hover and move in the vertical and horizontal plane
. WM 's UAS will operate in line of sight, during daylight hours , and will only operate within a sterile area described in the enclosed Operations Manual. WM will operate at or below 400 feet AGL and will file a NOT AM for each flight operated in controlled airspace that is required. All required permissions and permits would be obtained from territorial , state, county or city jurisdictions, Including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS. 

### IV. Details ofProposed slJAS Operations The enclosed Operations Manual describes, in detail, the policies and procedures for WM's proposed sUAS operations
. To assist the FAA in its safety assessment ofWM's proposed sUAS operations, below is a summary ofoperational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:



### 1. The sUAS w111 weigh less than 55 pounds. 2. Flights vvill be operated within line of sight of the PIC and visual observer. 3
. Maximum total flight time for each operational flight will be limited to 20 minutes or the amount of time the sUAS can be flown and still maintain a reserve battery power or fuel quantity of no less than 25%. 4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned
. 5
. Flights will be operated at a lateral distance ofleast 100 feet from any inhabited structures, buildings, vehic1es, vessels, people not associated with the operation or who have not signed a waiver in advance of the operation. 6. Minimum crew for each operation will consist ofthe sUAS Pilot in Command and a Visual Observer. Additional crewmembers may consist ofadditional observers and a Camera Operator. 7. The sUAS Pilot in Command will be an FAA licensed airman with a minimum of a private pilot's certificate and a third class medical.

48. WM will designate a Pilot in Command ("PIC") for each mission
. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day 's flight activities. It will be mandatory for all personnel performing duties within the boundaries ofthe safety perimeter be present for this briefing. 10. Prior to the operations at a particular location, a site inspection and mission briefing will have been conducted. On the day ofthe mission, the management person with operational control and the PIC will concur on dispatching of the mission
. 11. The PIC and Observer will remain in close enough proximity so as to be able to communicate by voice. 12. All sUAS will be maintained in accordance with the manufacturer 's guidelines
. 13. In the event of an accident involving a WM sUAS, they will cease operations and report the accident to the NTSB and AFS-80. 14. Pilot in Command and Visual Observer will at all times be able to communicate by voice 15
. All PICs, VOs , and Camera Operators will be training and tested on their proficiency to operate with the UAS environment. 16. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions , including local law enforcement, fire or other appropriate governmental agencies. 17. In compliance with approved Waiver, WM management will submit a written " Plan ofActivities" to the local Flight Standards District Office (FS DO) havingjurisdiction over the area ofproposed filming three days in advanced of operations during film or movie productions. 18. Ifthe sUAS loses communications signal, the sUAS will have the capability to return to a predetermined location within the closed set and land
. 19. Contingency plans will be in place to safely terminate flight ifthere is a loss of communication between the pilot and the observer. 20. The sUAS has the capability to abort a flight in case ofunpredicted obstacles or emergencies.

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### V. Regulations From Which Exemption is Requested
• 14 CFR Pa rt 21 • 14 CFR 45.23(b ) • 14 CFR 61. 1 13 ( a) & (b ) • 14 CFR 91.7 (a) • 14 CFR 91.9 (b) (2) • 14 CFR 9 1. 103 • 14 CFR 91. 109 • 14 CFR 9 1.11 9 • 14 CFR 91.12 1 • 14 CFR 9 1. 151 (a) • 14 CFR 9 1. 203 (a) & (b) • 14 CFR 9 1. 405 (a); 407 (a) (1);409 (a) (2); 4 1 7 (a) 

### (b)


### A. 14 CFR Part 21 , Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H , entttled Airworthmess Certificates , establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by The Aerial Filming Company, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part II and Section 333 of the Reform Act. The Federal Aviation Act (49 U
. S
.C
. §44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed , operational capability , and proximity to atrports and populated areas ofthe particular UAS
. In all cases, an analysts of these criteria demonstrates that the UAS operated without an airworthiness certificate , in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthines s certificate without the restriction s and conditions proposed
. The sUAS to be operated is less than 55 lbs
. full } loaded, carnes neither a pilot nor passenger, carries no explosive materials or flammable fuels , and operates exclusively v.ithin a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, and under the requirements and in compliance with local public safety requirements
. The FAA will have advance notice of all operations. These safety enhancements , which already apply to civil aircrail, provide a greater degree of safety to the public and property owners than conventional operations conducted with amvorthiness certificates issued under 14 C
. P
.R Part 21 , Subpart t I. ApplicatiOn ofthese same cnteria demonstrates that there is no credible threat to national security posed by the UAS , due to its size, speed of operation , location of operation , lack of explosive materials or flammable liquid fuels , and inability to carry a substantial external load. 

### B. 14 CFR § 

### 45.23 (b). Marking of the Aircraft The regulation requires : When marks include only the Roman capital letter "N" and the registration number is displayed on limited , restricted or light- s port category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station. in

6letters not Jess than 2 inches nor more than 6 inches high, the words "limited, " "restricted," "light-sport, " "experimental," or "provisional , " as applicable
. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS wtll have no entrance to the cabin, cockpit or pi lot station on which the word " Experimental" can be placed. Given the size ofthe sUA V , two-inch lettering will be impossible
. The word "Experimental" will be placed on the fuselage 

### in compliance wtth §45
.29 (f)
. The equivalent level of s afety will be provided by having the sUAV marked on its fuselage as required by §45 29 (f) where the pi lot, observer and others workmg with the sUA V will see the identrfication ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos
. 10700, 8738 , 10167 and 10167A.



### C. 14 CFR §Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in Command Sections 61 113 (a) & (b) limit private pilots to non- commercial operations Because the UAS 

### will not carry a pilot or pas sengers ; the proposed operations can achieve the equivalent level of safet} ofcurrent operations by requiring the PIC operating the aircraft to have a private pilot's license to operate this sUAS
. U nlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled. The area of operation is controlled and restricted, and all fl1ghts are planned and coordinated in advance. The level of safety provided by our requirements exceeds that provided by a single individual holding a commercial pilofs certificate operating a conventional aircraft
. The risks associated with the operation of the sUAS are s o dimini shed from the level ofrisk associated wtth comrnerctal operations contemplated b} Part 61 when drafted, that allowmg operat10ns ofthe sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C. F
. R. §61. 113 (a) & (b)
. 

### D. 14 CFR §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition
. As there wi11 be no airv,;orthiness certificate is sued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness
. Given the size of the aircraft and the requirements contained in our operations manual for maintenance and use of safety check lists prior to each flight , as set forth in Sections 

### J , L , and Q , an equivalent level of safety ""ill be pro" ided
. 

### E. 14 CFR § 91.9 (b) (2) : Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate aU $
. -registered civil aircraft
.. . (2 ) For \\hich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material , markings , and placards, or any combination thereof.

7The sUAS, given its size and configura tion has no ability or place to carry such a flight manual on the aircraft, not on ly because there is no pilot on board, but beca use there is no room or capactty to carry such an item on the at rcraft. The equivalent level of safety will be maintained by keepi ng the fl ight manual at the ground control point wher e the pilot flying the sUAS wi ll have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607 , 8737, 873 8 ,9299, 9299A, 9565, 95658, 10167, 10167A, 10602,32827,and 10700. F. 14 CFR § 91.103: Preflight action This regulation requires each PIC to take certain actions before flight to ins ure the safety offlight. A s FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in our confidential operating manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
G. 14 CFR §91.109: Flight instruction Section 91
. 103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls
. sUASs/ remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communication s .The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft
. See Exemption Nos .5778K 

### & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.
H. 14 CFR §91.119: Minimum safe altitudes Sect ion 91. 1 19 establi shes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) all ows heli copters to be operated at less than the mimmums pr escnbed, provided the person operating the helicopter com plies with any route or altitudes prescri bed for helicopters by the FAA. As this exemption is for a sUAS that is a hehcopter and the exem ption requests authorit) to operate at altitudes up to 400 AGL, an exemption rna} be needed to allow such operat ions. As set forth herein, the sUAS will never operate at hi gher than 400 AGL. It 

### will however be operated in an area wher e buildings and people will not be exposed to operations without thei r pre-obtained consent. The equivalent level of safety will be achieved given the s i ze, weight, and speed ofthe UAS as well as the location where 1t is operated. No flight will be taken without the permission ofthe property owner or loca l officials. Because ofthe advance notice to the propert) ow ner and participa nts in the filming activtty, all affected mdividuals will be aware ofthe planned flight operations. Compared to fli ght operations with aircraft or rotorcraft \veighing f ar more than the maximum 55 1 bs. proposed herein and the lack offlammable fuel, any ri sk associated with these opera tions is far less than those presently pr esented with conventional aircraft operati ng at or below 500 AGL. In addition, the low-altitude operations ofthe sUAS wil1 ensure

8

### separation between these small- UAS operations and the operations ofconventional aircraft that must comply wit h Section 91.119. 

### I. 14 CFR §91.121 Altimeter Settings 

### This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure. " As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed
. Our sUAS has a barometric, telemetric data feed
. This altitude information will be generated by equipment installed on the aircraft, GPS triangulation or any combination thereof Before each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PIC
. J. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

### Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing , and, assuming normal cruising speed

- ( 1) During the day, to fly after that for at least 30 minutes ; or (2) At night, to fly after that for at least 45 minutes
. " The battery powering the sUASs provides a maximum of approximately 40 minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length
. Given the limitations on the UAS 's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. We believe that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not incur the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sUAS. Additionally , limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. We believe that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area . Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745 , 10673 , and 10808. K. 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

### The regulation provides in pertinent part : (a) Except as pro\lided 

### in§ 91.715, no person may operate a civil atrcraft unless it has within it the following: 9

### (l) An appropriate and current airworthiness certifieate •... (b) No person may operate a civil ai rcraft unless the ainvorthiness certificate required by paragraph (a) ofthis section or a special flight aut hori zation issued under §9 1.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew . The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As s uch, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them , to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative s ample of other exceptions includes Exemption Nos. 9565 , 9665 , 9789 , 9789A, 9797 , 9797A, 9816A, and 10700
. L. 

### 14 CFR §91.405 (a); 407 

### (a) (1); 409 

### (a) (2); 417(a) & 

### (b): Maintenance Inspections These regulations require that an atrcraft operator or owner "shall have that aircraft inspected as prescnbed in subpart E of this part and shalJ between required inspections , except as provided in paragraph (c) ofthts section , have discrepancies repaired as prescnbed in part 43 ofthis chapter
.. , " and others shall inspect or maintain the aircraft in compliance with Part 

### 43
. Given that these sections and Part 43 apply only to aircraft with an ainvorthiness certificate, these sections will not apply to our operations
. Maintenance 

### will be accomplished by the operator pursuant to the manuals and operating handbooks for each respecttve sUAS (included with the submiss10n ofthis petition)
. An equivalent level of safety will be achieved because these sUAS are very limited in size and will carry a small payload and operate only in restricted areas for limited penods oftime
. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual , the operator will ensure that the sUAS is in working order prior to initiating flight, perform reqUired mamtenance, and keep a log of any mamtenance performed
. Moreover, the operator is the person most fami liar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety 

### VI. PUBLIC INTEREST Granting Windshear Media LLC. an exemption furthers the public interest. National policy set by Congress favors early integration ofUAS into the national airspace in controlled, safe working environments such as those propose in thi s petition
. Windshear Media's goal is to help facilitate safe integration of sUASs into mainstr eam USA in the following areas :
• Videography and Photography • Agricultural Assessment of Crops and Data Collection • News Gathering • Training and Education • Support Services for Public Entities • Inspections and Assessments of Structures • Real Estate • Closed Set Film and Movie Production
lD

### Vll. PRIVACY A ll flights will be conducted in accordance with any federal , state or local la ws regarding priv acy. VITI. FEDERAL REGISTER 

### SUMMARY Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the foliO\\tng rules· 14 C.F
.R. §21, subpart 

### It 14 C.F.R 45.23(b), 14 C.F.R. §§ 61.113( a) & (b),91.7 (a); 91.9 (b) (2);91.103(b);9l.l09; 91119; 91.121; 91.l5l(a);91.203(a) and(b); 91.405 (a); 91.407 (a)(l); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & 

### (b) to operate commercially a small unmanned vehicle (55lbs or less). IX
. 

### CONCLUSION 

### Approval of exemptions allowing commercial operatiOns of sUASs as requested will enhance safety by reducing risk. Conventional operations, using Jet or piston power aircraft, operate at extremely low altitudes and in extreme proximity to people and structures; and present the nsks associated with vehicles that weigh approximately 5 

### ,OOOlbs carrying large amounts offuel. Such aircraft must fly to and from the film location. ln contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry 

### no passengers or crew and, therefore, will not expose them to the risks associated wtth manned aircraft flights. The operation of small UASs, weighting less than 55 lbs., conducted m the strict conditions outlined above, will provide an equtvalent level of safety supporting the grant of the exemptions requested herem, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a secure environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.



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# s ubm 2tat

onathan Cook Winds hear Media LLC
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