Christian N. Loran

400 Minnisink road To tow a, NJ 07512 (973)650

- 0513
c hristian@cinemaflight.com

Dear Sir or Madam: This petition is being submitted on my behalf without legal counsel or consulting services. Pur suant to Section 333 of the F AA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F .R. Part 11 , Christian N. Loran, a freelance multimedia producer , hereby applies for an exemption from the Federal Av iation Regulations (F

ARs) listed below

to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Av iation Ad ministration (F AA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the F AA as required by Section 333. The requested exemption would permit Christian N. Loran to pursue his commercial interests in providing services to clients using a small advanced sUA V in the following areas: Real Estate, Marketing, Land Management/Sur veying, and Special Events. Christian N. Loran states that all sUAS flights will occur over private or controlled access property and w ill do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agree d to be w ithin the UAS’radius during filming and photography applications. Christian N. Loran has demonstrated the ability to safely and ef fectively fly the sUAS DJI Inspire 1 w hich will be used for all commercial and private purposes. Christian N. Loran complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS. Christian N. Loran is a retail drone store business owner and has bee n safely flying, selling, and repairing sUAS and other hobby aircraft for the past 8 years. All flights will occur in ordinance with any state or local laws regarding privacy

. I, Christian N. Loran, am seeking the exemption because I am committed to comp lying with all of the rules, guidelines, limitations, and future legislation set forth by the F AA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have described. W ithout the exemptions request granted, I w ould be unable to safely and effectively run my ne w business, and it is my intention to comply with the F AA and obtain an exemption of the following regulations.

The follow ing contains my list of regulations from which I am seeking exemption, and a complete li st of responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit and safety features, and similar petitions requests granted. **Regulations from which exemption is r**  **equested:**

14 C.F .R. Part 21 14 C.F .R. 45.23 (b) 14 C.F .R. 61.1 13(a) & (b) 14 C.F .R. 91.7(a) 14 C.F .R. 91.9(b) (2) 14 C.F .R. 91.109 14 C.F .R. 91.1 1914 C.F .R. 91.121

14 C.F .R. 91.151(a) 14 C.F .R. 91.203(a) & (b) 14 C.F .R. 91.205(b) 14 C.F .R. 91.215 14 C.F .R. 91.401

– 91.417

**I, THE OPERA** 

**TO R,**  **ASSUME THE FOLLOWING**  **RESPONSIBILITIES** 1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to
am end this exemption. 2. Operations for the purpose of closed

- set motion picture and television filming are permitted w ith proper permissions from motion

- picture provider. SUAS must be insured or insurance provided by motion

- picture provi der prior to any on

set flights 3. The UA

may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer

. 4. The UA

must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL

. 5. The UA

must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’ s F AA

- issued airm an medical certificat e or U.S. driver ’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated w ithin the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC alw ays m aintains VLOS capability . T he VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation f or the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance w ith the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Ad ministrator upon request. If a discrepancy exists betw een the conditions and 4 limi tations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator ’s responsibility to track such revisions and present updated and revised documents to the Ad ministrator or any law enforcement of ficial upon request. The operator must also present upda ted and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the F AA granted this exemption, then the operator must petition for an am endm ent to its grant of exemption. The F AA ’s UAS Integration Office (AFS −80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS oper ation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must rem ain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property

. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for

safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inop erable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11

. The operator must follow the UAS manufacturer ’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manu facturer safety bulletins. 13. Under this grant of exemption, a PIC must have a minimum of 1 years worth of advancd sUAS flying experience and training using the DJI Inspire 1. PIC must hold a valid U.S. driver ’s license issued by a state, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal government. The PIC and sUAS must be fully insured through the current sUAS insurer AerialPak, if there should be a change in insurance providers this exemption must be resubmitted. 14. The o perator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and
em ergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator ’s PICs and VOs (training, proficiency , an d experience

- building) and determining the PIC’ s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However , training operations may only be condu cted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA w ith appropriate distance from nonpartic ipants in accordance with 14 CFR § 91.1 19. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA

m ay not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FA A A irport/Facility Directory (AFD) or for airports not denoted w ith an ARP , the center of the airport symbol as denoted on the current F

AA

- published aeronautical chart, unless a letter of agreement with that airport’ s management is obtained or otherwise permitted by a COA issued to the exemption holder. T he letter of agreement with the airport management must be made available to the Ad ministrator or any law enforcement official upon request. 17. The UA

m ay not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or w hen visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property

. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available pow er for the UA to conduct the intended operation and to operate after that for at least five minutes or w ith the reserve power recommended by the manu facturer if greater

. 21. All aircraft operated in accordance w ith this exemption must be identified by serial number , registered in accordance w ith 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Ma rkings must be as large as practicable. 22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control S tation of the UAS any timethe aircraft is operating. These documents must be made available to the Ad mi nistrator or any law enforcement

of ficial upon request. 23. The UAS must remain clear and give way to all manned aviation operations and activities at all t imes. 24. The UAS may not be operated by the PIC from any moving device or vehicle. 25. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are pre sent that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave s uch protection and are w ithin 500 feet of the UAS, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipat ing persons under this exemption. 26. All operations shall be conducted over private or controlled

- access property with permission from the property
owner/controller or authorized representative. Permission from property owner/controller or authorized repr esentative will be obtained for each flight to be conducted. 27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the F AA's UAS Int egration Office (AFS −80) w ithin 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB W

eb site: www

.ntsb.gov

.

**SIMILAR EXEMPTIONS** They are sim ilar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 1 1062, 1110 9, 1 111 2, and 1 1213,

**14 CFR 21 H: Airworthiness Certificates**  Certification Procedures for Products and Parts **Reason for**

**Exception** It has been det erm ined that similar UAS's do not require an airw orthiness certificate as granted in Exemption No. 11 623, 1 1650, 1 1664, 12701 and 1 1734. **14 CFR 45.23 (b): Marking of the Aircraft**  These regulations provide that each aircraft must display "N" and the airc raft's registration number in letters at least 3 inches high. Additionally , the aircraft must display the w ord "EXPERIMENT AL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. **Reason for**

**Exception** Even though th e UAS will have no airw orthiness certificate, an exemption may be needed as the UAS will have not entrance to the cabin, cockpit or pilot station on which the work "EXPERIMENT AL" can be placed. Given the size of the UAS, two

- inch lettering will be impossib le. The w ord "EXPERIMENT AL" w ill be placed on the fuselage in compliance with 45.29 (f). The F AA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

**14 CFR 61.1 13 (A) 7 {b): Private Pilot Privileges an**  **d Limitations** The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United St ates, unless that person: (1) has a pilot certificate or special purpose authorization issued under this part in that person's physical possession or readily accessible. (2) The flight is only incidental to that business or employment. (3) The aircraft does not carry passengers or property for compensation or hire. **Reason for**

**Exception** The Petitioner will follow all man ufacturers' current training programs and safety manuals. Current F AA proposals have omitted this as a requirement for small UAS's. these requirements are unnecessary for small

- sized groundstation pilot controlled sUAS flights. Additionally , PIC (Christia n N. Loran) has a proven history in model aviation retail sales, repair , education and safety in accordance w ith the AMA (Academy of Model Aeronautics). PIC w ill ensure every aspect of this petition is followed, maintained, and documented in depth across a ll sUAS operations if granted exemption.**Public Benefit and Safety**

Unmanned Aircraft System sUA Vs are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduc ed noise and as such, a much smaller environmental impact which promotes public safety

. Christian N. Loran is petitioning for an exemption to operate a DJI Inspire 1 w ith a built

- in stabilized HD camera and GPS safety features which limit its ability to l im it the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no

- fly zone feature. The DJI Inspire 1 also has a f ailsafe function that is triggered in the event communication is lost between the sUAS and the main controller transmitter

. At that time, the sUAS will return to its point of takeof f and land safety

. If the connection is restored, the PIC can regain contro l of flight and land manually

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

 The petitioner w ill only operate its sUAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are `sufficient dis tance' from populated areas w ithin the sterile area described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to users of the national airspace system or the public."

 When flying the sUAS within three (3) miles of an airp ort, airport operators w ill be notified and the operator w ill give the right

- of

- wa y to avoid flying in the proximity of full

- scale aircraft. Maximum flight time for each operation will be 30 minutes.

 Flights will be terminated when battery levels reach 2 5%, allow ing suf ficient reserve flight time to safely land the sUAS.

 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned.

 Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer , and the camera operator

.  The sUAS PIC w ill be an

 The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover , and can simultaneously move vertically and horizontally

.  Given the small size of the sUAS and the restricted sterile environment within which it will operate, Cinemaf light's operations adhere to the Reform Act's safety requirements.