July

27, 2015

Kenji Croman Tie The Knot Images, LLC Owner: Kenji Croman 2555 Pacific Heights Place Honolulu, HI96813
Re: Exemption Request Pursuant to 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 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 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)

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Kenji Croman , operator of an Unmanned Aircraft Sy stem (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required b y S ec tion 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photograph y and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photograph y for public and/or private use including television, public events, cinematograph y and newsgathering

.

 Aerial inspection/photograph y of residential/commerci al structures under contract with the owners or local government authority

.

 Aerial inspection/photograph y of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. Aerial video/photography or providing live video feed to assist with search and rescue operations in

cases of an emergency

or natural disaster onl y when the local authorities or government has requested it b y contract or donation.

 The ability

to offer tr aining to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace Sy stem (NAS) as we ll as for the protection of the persons and propert y.
As described fully

below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereb y enhance safet y and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “ ....establish requirements for the safe operation of such aircraft sy stems in the national airspace s ys tem.”
**The name and address of the applicant is:** Tie The Knot Images, LLC Attn: Kenji Croman , Owner/Chief Pilot Email: kenjic@mac.com A ddress: 2555 Pacific Heights Place, Honolulu HI 96813
**Regulations from which the exemption is requested:** 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) s14 C FR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)
We are petitioning for exemption to enable Tie The Knot Images, LLC to operate a DJ I Inspire 1 equipped with a three

- axis gimbals and using High

- Def cameras. This sUAV has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class 8, C and D airspace including a n o - fl y zone feature. The Inspire 1 also has the fail

- safe function of the Naza

- M autopilot sy stem, which means when the communication between the Main Controller and the transmitter is disconnected, the outputs of all command sticks from controller will go to the center position. If the GPS signal is good enough, the s ys tem will automatically trigger Return to Home and will land safel y. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJ I Inspire 1 UAs are equipped with four main rotors; driven b y Li thium Poly mer battery

powered electric motors. Given the small size of the UAS and the controlled environment provided the proposed operations would adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surro unding 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. Accordingl y the applicant requests that the FAA grant the requested exemption with minimum delay

.
**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safet y of the persons and/or proper ty using conventional aircraft. These limitations 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:

 The	UAS	will	wei gh	less	than	55	lbs

.

 The	UAS	will	have	a	maximum	operating	speed	of	no	more	than 40 mph.

 Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual Observer	(VO). Maximum	flight	time	for	each	operational	flight	will	be 20	minutes.	Flights	will	be	terminated

at	25% battery	power	reserve	or	20	minutes	of	flight	time	whichever	occurs	first.

 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	eleva ted	platform	from	which	filming	is	planned.

 Minimum	crew	for	each	operation	will	consist	of	the	UAS	Pilot,	the	Visual	Observer	(VO)	and may	include	but	not	limited	to	a	Camera	Operator.

 The	UAS	pilot	will	be	a	designated	Pilot	in	Command	(PIC)	and	wi ll	take	and	pass	all	necessary certifications	currently	being	approved	by	the	FAA	administration	for	commercial	use.

 A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	day’s	flight consisting	of	all	the	days’	production	activities.

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

 The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	center/Airport	Reference Point (ARP)	of	a	tower	controlled	or	uncontrolled	airport.

 The	DJI Inspire	1 has	built	in	software	for	all	FAA	regulated	‘No	Fly	Zones’	and	was	uploaded by	D JI	(February	2015)	for	all	DJI	drones	to	download	and	prevent	any	possible	flights occurring	within	no

- fly	zones.	DJI Inspire	1 has	installed	software	(code)	that	denies	flights within	the	FAA	no

- fly	zones.		If	operations	will	be	within	a	5	mile	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.

 The	operator	will	file	FAA	Form	7711

- 1,	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.

 The	o perator	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	required	under	the	FOM.	With	the	advanced	permission	of	the	FSDO, operations	at	closer	range	may	be	approved.

 The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up

- to
- date	information for	the	particu lar	UAS	to	be	operated.

 The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	times. Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	county

or	city	jurisdictions,	including	law	enforceme nt,	fire	or	other	appropriate	governmental agencies.

 If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS	will have	the	capability	to	return	to	a	pre

- determined	location	within	a	designated	location	and land	autonomous ly.

 The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles,	weather,	or emergencies.


### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, estab lishes the procedural requirements for the issuance of airworthiness certificates as required b y FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an anal ys is 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 airworthiness certificate without the restrictions and conditions proposed.
The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated 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 safet y requirements. The FAA will have advance notice of all operations. These safety enh ancements provide a greater degree of safet y to the public and propert y owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastl y, application of these same criteria demonstrates that th ere 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.


### 14 C.F.R. § 45.23 (b). **Mark ing 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

- sport 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 letters not less 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 will be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safet y will be provided b y having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, ob server and others working with the UAS will see the identification of the UAS as “Experimental.”


### 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in **Command.** Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or propert y for compensation or hire. An equivalent level of safet y can be achieved by current Regulations because the applicant’s UAS do not carry an y pilots or passengers nor property . The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will equate to the safe operation of the UAS.


### 14 C.F.R. §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 will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory

standard will exist for dete rmining airworthiness. Given the size of the aircraft for maintenance and use of safet y check lists prior to each flight an equivalent level of safety will be provided.


### 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraf t Flight Manual, approved manual material, markings, and placards, or an y combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacit y to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot fl yi ng the UAS will have immediate access to it.

### 14 **C.F.R. § 91.103: Preflight Action.**

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be ne eded. The PI C will take all actions as stated in the manufacturer FOM in the pre

- flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before init iation of flight.


### 14 C.F.R. §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 control s. UAS and remotely piloted aircraft, by

their design do not have full y functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. 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 of the aircraft.


### 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescrib ed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may b e needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equival ent level of safet y will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the propert y owner or local officials. Because of the advance notice to the proper ty owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presentl y presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS ope rations and the operations of conventional aircraft that must comply with Section 91.119.

### 14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may

be needed. An equivalent level of safe ty will be achieved by

the operator, pursuant to the safet y check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.



### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in **VFR Conditions Section 91.151** (a) Prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assum ing normal cruising speed

– (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 18 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS 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 twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where onl y people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the ty pe of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally , li miting UAS flights to 10 minutes would greatl y reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved b y limiting flights to 20 minutes or 25% of battery power

— whichever happens fi rst. This restriction would be more than adequate to return the UAS to its planned landing zone from an ywh ere in its limited operating area.


### 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may

operate a civil a ircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded we ighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry

certification and registration documents or to display

them on the UAS. An equivalent level of safet y will be achieved b y keeping these docum ents at the ground control point where the pilot flying the UAS will have immediate access to them; to the extent they

are applicable to the UAS.

### 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed i n part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished b y the operator pursuant to the flight manual and operating handbook. An equivalent level of safet y will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas fo r a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL . The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety . An equivalent level of safet y wi ll be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.



### Public Interest Manned aircraft conducting aerial photograph y/videography can weigh 6,000 pounds or more and contain one or more individuals on board. Tie The Knot Images, LLC’s UAV will weigh less than 7 pounds and contain no living cr ew (the PIC and VO being remotel y located from the UAV). The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or propert y in the event of an incident or accident. There is no risk to an onboard c rew while using a UAV. Traditional manned aircraft contain highly flammable fuel and are at risk of fuel spillage and fire in the event of an incident or accident. The battery

- powered Inspire 1 carries no fuel, eliminating this fire and environmental risk. Traditional aerial photograph y/videography operations using conventional aircraft can operate in very close proximity to persons and propert y on the ground. While the FAA mitigates these risks in a variet y of way s, the proposed UAS operations would reduc e risks even further due to the limited size, weight, speed, operating conditions, and safet y features of the Inspire 1. Furthermore, as Congress outlined in the FAA Modernization and Reform Act, integration of UAS into the NAS is inherently

in the public interest, as long as it can be accomplished safel y. As described above, not only will the proposed UAS operations provide an equivalent level of safety to current operations

– they

will actually

provide a greatl y improved level of safet y t o construction managers and the general public.

### Conclusion Tie The Knot Images, LLC seeks exemption from the FARS outlined above in order to commercially operate a small UAV that weighs less than seven pounds for the purposes described above. The operation of the UAS described herein, under the strict conditions outlined above and in the operating documents, will provide an equivalent level of safety to support the grant of the requested exemptions. Please do not hesitate to contact me if you have any questions or con cerns.

Sincerel y,
Kenji Croman Owner, Tie The Knot Images, LLC