US Department ofTransportation Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation July 20, 2015 Drone Aerial Productions, LLC Diane B. Rowden, Vice President 10350 Fulton Avenue Weeki Wachee, Florida 34613

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590 **~.)** ··. ····"'"\ :.,...

**~··**
Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe 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); 14CFR 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 ofthe FAA Modernization and Reform Act of 2012 (the "ReformAct") and 14 CFR Part 11, DroneAerial Productions, LLC, operator of Unmanned Aircraft Systems (UAS), herebyapplies for an exemption from the listed Federal Aviation Regulations r'FARs") to allow commercial operation of designated UAS, provided such operations are conducted within and underthe

Page 

### 11conditions outlined herein or as may be established by the FAA as required by Section 333. Thank you in advance foryour consideration. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 

### 1. Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photographyfor public and/or private use including television, public events, cinematography and newsgathering. 3. Aerial inspection/photographyof residential/commercial structures under contract with the owners or local government authority. 4. Aerial video/photographyor providing live videofeed to assist with farmers, golfcourses, Chamber of Commerce 

### &associated businesses for marketing campaigns and wildlife conservation organizations. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster onlywhen the local authorities orgovernment has requested it by contract or donation. 6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safetyfor current and future UAS operations within the NAS. As described fully below, the requested exemption would permitthe operation ofdesignated UAS as setforth in this document under controlled conditions in the NAS thatwould be limited, controlled, predetermined and safe. Approval ofthis exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfillingthe Secretary ofTransportation's (the FAA Administrator's) responsibilities to

**~~**....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."

Page 

### I2The name and address ofthe applicant is: Drone Aerial Productions, LLC., Diane B. Rowden, Vice President Phone: 352-573-4178 Email: diane.rowden@gmail.com Address: 10350 Fulton Avenue, Weeki Wachee, Fl 34613

Regulations from which the exemption is requested: 14CFR 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) 14CFR 91.103 14CFR 91.109 14 CFR 91.119 (c) 14CFR 91.121 14CFR 91.151 (a) 14CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b) Drone Aerial Productions, LLC, Diane B. Rowden, Vice President, will operate two ofthe following model UAS: Yuneec Model Q500 Typhoon, S/Ns YU15030598B01101 and YU 15160315B02B01 Specifications to follow below: Page 

### I 3

# PRODUCT SPECIFICATIONS

• Q500 TYPHOON Aircraft
o FlightTime

Up to 25 Minutes
o Height

240mm {9.45 in)
o Width

420mm {16.54 in)
o Diagonal Length Without Rotor Blades 565mm {22.2 in)
o Propeller/Main Rotor Diameter 330mm {13.0 in)
o Weight Without Battery and Payload

1130g (40.0 oz)
o Battery 5400mAh 35 11.1V LiPo (included)
o Charger
Page 

### I 43S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)
o Transmitter

10channel 2.4GHz with 5.8GHz video downlink (included) o 3 Flight Modes

Smart, Angle and Home Modes
o Maximum Flying Height

Default 400 Feet Above Ground Level (Adjustable via the QSOO GUI)
o Maximum Rotational Velocity 65°/s
o Maximum Bank Angle 35°
o Maximum Climb Rate in Smart and Angle mode 3m/s
o Maximum Descent Rate in Smart and Angle mode

2m/s
o Takeoff Weight With Battery and CG02GB

1700g (60.0 oz)
o Radio Control Frequency Band 2.4GHz • CG02GB Camera Gimbal System
o Focusing System Aerial Optimized Fixed Focus
o Video Resolution FULL HD 1080p Adjustable 60, 50 or48 FPS
o Photo Resolution Page 

### I 512 Megapixels
o Video Field ofView

o Control Angle Accuracy

o White Balance Automatic Smart White Balance Feature

o Transmission Band 5.8GHz
o Input/OperatingVoltage 7.0V to 14.0V DC
o VideoTransmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 

### ft) CE Compliance: Up to 300m (984.252 ft) with STlO Warning: You Must Follow Local Laws and Maintain Visual Line of Sight ofAircraft atAll Times.
o Current Consumption/Operating Current

500mA (average) to 600mA (peak)@ 12.0V (7.2W max)
o Storage Temperature

o WorkingTemperature

o Storage (memory) microSD Class 10 "'4to 128GB
Page 

### I 6o Height 115mm (4.5 in)


### o Weight 185g (6.5 oz)


### o Depth 135mm (1.4 in) Width 74mm (2.9 in)



# • ST10 Personal Ground Station

o Operating System

AndroidTM


### o NumberofChannels 10
o Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Upto 400m (1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual Line ofSight of Aircraft atAll Times.
o Robust Radio Control Modulation

Yuneec Protocol Video link Frequency Band 5.8GHz
o Video Transmission Distance/Range (Optimum Conditions)

Page 

### I 7o FCC Compliance: Up to 600m {1968.5 

### ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual Line ofSight of Aircraft atAll Times.
o Flight Systems Telemetry Data On Screen Display (OSD)

Yes
o LED Backlit LCD Screen

Capacitive MultiTouch 4.5"
o Tactile (Vibrating) and Audible Feedback

Yes
o Built In LipP BatteryVoltage 

## I Capacity

3.6V /5200mAh 18.72Wh
o Charger Auto Charge Modevia MicroB USB Cable with ACto 5V DC USB Power Supply {Included) Given the small size ofthe UAS in scope and the controlled environment provided, the proposed operations will adhere tothe Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grant the requested exemption. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Page 

### I 8The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property 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: 

### 1. The UAS will weigh significantly less than 55 lbs. Itweighs less than 4 pounds with battery and camera. 2. The UAS, depending on the model in operation, will have a maximum operating speed of no morethan 50mph. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flighttime for each operational flightwill be depending on the UAS model in operation, butwill not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlighttime whichever occurs first. 5. Flights will be operated at an altitude of no morethan 400 feetAbove Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crewfor each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include athird, but separate, Camera Operator (CO). 7. The UAS pilotwill be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours on the designated UAS. 8. A safety briefing will be performed priorto each day's flights consisting ofall the days' production activities. 9. All flight activities will be logged. 10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only.

Page 

### I 911. The flights will occur in Class Gairspace no closer than a Smile radius ofthe geographic center/ Airport Reference Point (ARP) ofatower controlled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius ofthe geographic center/ Airport. 13. The operatorwill file FAA Form 77111, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no morethan 72 hours but no less than 48 hours from planned operation. 14. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that onlyconsenting persons will be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department of Transportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 15. The PIC and VO will have been trained in operation of UAS and receive up to date information forthe particular UAS to be operated.

16. The PIC and VO will be able to communicate byvoice and/or radio at all times. 17. Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 18. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to a predetermined location within a designated location and land autonomously. 19. The UAS will have the capability to abort aflight in case ofemergencies with an automated "Return Home and Land" function. 20. The UAS will have the capabilityto abort aflight in case of unpredicted obstacles, weather, or emergencies such as low battery.

Page 11014 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act {49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorizethe FAA to exemptaircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated withoutan airworthiness certificate in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree ofsafetytothe public and propertyowners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. §45.23 (b). Marking ofthe AircraftThe regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance tothe 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 Page Ill14 C.F.R. §45.23 (b). Marking ofthe AircraftThe regulation requires: When marks include onlythe 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 mustalso display on that aircraft near each entrance tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, thewords "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance tothe cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). US DepartmentofTransportation February 20, 2015 The equivalent level ofsafety will be provided by havingthe UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuantto 14 CFR 61.113 (a) 

### & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation or hire. The proposed UAS operations may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendanttothe operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC ofthe UAS will be, or be underthe directsupervision of, a FAA Certificated Private Pilot with currentThird Class or higher medical certificate. It is believed thatthe operation and limitations set forth in the FOM will equate tothe safe operation ofthe UAS. 14 C.F.R. §91.7(a): Civil AircraftAirworthiness. 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 forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety checklists priorto each flight, an equivalent level ofsafety will be provided.

Page 11214 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 ofthis chapter, unless there is available in the aircraft acurrent approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 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 orcapacityto carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping theflight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it. 14 C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command totake certain actions beforeflightto insure the safety offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraftan exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight 14 C.F.R. §91.109: Flight Instruction. Section 91.103 providesthat no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fullyfunctioning dual controls. UAS and remotely piloted aircraft, bytheir design do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions forflighttraining withoutfullyfunctional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudesfor operation ofcivil 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 prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption Page 

### 113requests authorityto operate ataltitudes up to400 AGL, or not morethan 200 above an elevated platformfrom which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higherthan 400AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feetAGL, the UAS will not be operated morethan 200 feet above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir preobtained consent. The equivalent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice tothe property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraftweightingfar more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the lowaltitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe 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 U.S. exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuanttothe safety check list and live flight data monitoring, confirmingthe altitude ofthe 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 flytothe first point of intended landing, and, assuming normal cruising speed- (1) Duringthe day, tofly afterthatfor at least 30 minutes; or (2} Page 114At night, to fly afterthatfor at least45 minutes."The applicant believes that an exemption from 14 CFR §91.151{a) falls within the scope of prior exemptions. Operatingthe UAS in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or 25% ofbattery power- whichever happens first. This restriction would be morethan adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 6 the regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate acivil aircraft unlessthe airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs well underthe proposed 551b limitand is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level of safety will be achieved by keeping these documents atthe ground control point where the pilotflying the UAS will have immediate access tothem, tothe extent they are applicable tothe 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 operatororowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will notapplytothe applicant. Maintenancewill be accomplished by the operator pursuanttothe flight manual and operating handbook. An equivalent level ofsafetywill be achieved because the UAS is very limited in size and will Page 115carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediatelyand will be operating from no higherthan 400feetAGL. The operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthycondition to providethe equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight and perform required maintenance needed. Additional Information. The applicant, Drone Aerial Productions, LLC, Diane B. Rowden, Vice President, believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of2012, providing sufficientjustificationforthe granting ofcommercial operations ofthe applicant's UAS. The applicant, Diane B. Rowden, requests your respective approval ofthis Section 333 exemption petition request. Thankyou foryour interest and attention in this matter. Please notify Diane B. Rowden ofyour actions, and or approvals. ThankYou foryour interest in this request

Sincere)y,

# D~~~r~:~~**j)ri'n~ B~**  Rowden, Vice President diane.rowden@gmail.com 10350 Fulton Avenue VVeekiVVachee, Fl34613 352-573-4178 Page j16

## Please do not display mydrive(s license on the website Thankyou, Diane Rowden



# ~