November 12,2015 U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., SE Washington, DC 20590 Re: Petition ofStellar Visioning, LLC for an Exemption Pursuant to Section 333 oftheFAA Modernization and Reform Act of2012 Director: Flight Standards Service: Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, Stellar Visioning, LLC (Stellar Visioning) hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified belowto allow commercial operation ofsmall unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting aerial closed setphotography, videography, Cinematography, inspection and mapping for the motionpicture, television, real estate, construction and web industries. This petition for exemption is made based oninformation outlined inthis Petition for Exemption, as well as the accompanying Stellar Visioning documents; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. FlightManual 1 (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") Stellar Visioning submits these supporting materials as confidential documents pursuantto 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/orproprietary informationthat Stellar Visioning has not and will not share with otherrequesting parties. Additionally, these documents contain operating conditions andprocedures that are not generally available to the public and are protected from release under the Freedom oflnformationAct, 5 U.S.C. § 552 et. seq. 

### NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITIONARE CONFIDENTIAL AND SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER.

1

. The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilottraining manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation November 12,2015 Page2
Foryour convenience, this Petition is organized as follows: 

### I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Closed Set Videography, Photography, Cinematography, inspection andMapping 

### III. Relevant Statutory Authority IV. Stellar Visioning's Proposed UAS Operations Meet the Requirements of Section 333 ofthe Reform Act A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions SetForthinthe Operations Manuals 

### V. Regulations From Which Exemption is Requested A. 14 C.F.R. Part 21, Subpart H

- Airworthiness Certificates and 14 C.F.R. § 91.203(a)(l) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. 

### § 91.7(a): Civil Aircraft Airworthiness G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual inthe Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration H. 14 C.F.R. § 91.103: Preflight Action I. 14 C.F.R. § 91.109(a): FlightInstruction J. 14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes K. 14 C.F.R. § 91.121: Altimeter Settings L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight inVFR Conditions 

### Vl. Drug and Alcohol Program VII. Public Interest VIII. Privacy IX. Federal Register Summary X. Conclusion I. DESCRIPTION OF PETITIONERU.S Department ofTransportation November 12, 2015 Page 3 Stellar Visioning is based in Los Angeles, CA and provides aerial closed setvideography, photography, cinematography, inspection and mapping to their client base. The Company's Principal and ChiefPilot David M. Dulanhas been flying UAV Quadcopters as a hobby for more than one year without incident, spending hundreds ofhours flying. Uponthe grant ofthe 333 Exemptionthe Company'sbusiness will continue to specialize in closed setphotography, videography, cinematography, inspection and mapping. Stellar Visioning's staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot in command ("PIC") in addition to any otherneeded on site assistance. All ofthe equipment ownedby Stellar Visioning is ofthe highest quality gear andhas been able to provide these services safely and without any claims or incident. StellarVisioning's goal is to advise the perspective clientthat Stellar Visioning is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. Stellar Visioning seeks an exemptionto allow for photography, videography and other related mediaproducts. The contact information for Petitioner is as follows: David M. Dulan Stellar Visioning, LLC 1

715 Westridge Road Los Angeles, California 90049 Phone: 310.713.8085 Email: JaviJJulan@gmail.com 

### II. DESCRIPTION OF PROPOSED OPERATION Stellar Visioning seeks an exemptionpursuantto Section 333 ofthe Reform Act to operate the DJI Phantom 2; DJI Phantom 3; DJI Inspire; DJI s900 Spreading Wings; and, Freefly Systems Alta(referred to SV-UAS) (under 55lbs) for the proposed operations discussed hereinbelow. All UAS operations will occur undertightly controlled conditions onprivate property or approved location where StellarVisioning has received verifiable permissionto operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance with the conditions and limitations ofthis Petition for Exemption and Stellar Visioning's Operations Manuals. As detailed in Stellar Visioning's Operations Manuals, all UAS operations will be limitedto daytime VFRconditions, within visual line-of-sight ("VLOS") ofthe operator, in uncontrolled airspace, and will occur at least 5 nm away from an airport reference point. Moreover, Stellar Visioning's Operations Manuals incorporate redundant safeguards to assure the aircraft does nottravel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. 

### A. Aerial Closed Set Videography, Photography, Cinematography, inspection and MappingU.S Department ofTransportation November 12,2015 Page4 Stellar Visioning seeks to use small SV-UAS for the purpose ofconducting close set aerial photography, videography, cinematography, inspection and mapping for the film, television, real estate, construction and web industries. Stellar Visioning has purposefully tailored its operations to meetthe requirements established by the FAA in prior grants ofexemption authorizing commercial use ofUAS in the relevant industries, including:



### • • • • 

### • • 

### • • • • • 

### • Astraeus Aerial (ExemptionNo. 11062) Aerial MOB, LLC (ExemptionNo. 11066) Pictorvision, Inc. (ExemptionNo. 11067) HeliVideo Productions, LLC (ExemptionNo. 11065) Snaproll Media, LLC (ExemptionNo. 11063) RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064) Flying-Cam, LLC (ExemptionNo. 11080) Aerocine, LLC (ExemptionNo. 11150) Team 5, LLC (ExemptionNo. 11158) Alan D. Purwin (ExemptionNo. 11161) Helinet Aviation Services, LLC (ExemptionNo. 11160) Picture Factory, Inc. (ExemptionNo. 11178) All UAS photography, videography, cinematography, inspection and mapping operations will occur onprivate property or approved location in a controlled area away from spectators and persons not involved in the recording process. In addition, the filming will be conducted between dawn and dusk to ensure maximum safety for the public and those involved inthe manipulation and operation ofthe UAS; VFRconditions, at altitudes below400' above ground level ("AGL"). As set forth below, Stellar Visioning's operations provide an equivalent level ofsafety which is superior to performing the same work using conventional fixed-wing aircraft or helicopters. Small UAS recording operations is also safer thantraditional manned aircraft performing the same function. Videographer-inspectors also frequently need to climb rooftops, trees, or otherwise perform elevated work, which exposes them to the risk ofdangerous falls, electrocution or other work related injuries. In addition, depending onthe nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk ofexposure to hazardous conditions. The use ofSV-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most other types ofrecording operations. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations presentrisks associated with vehicles weighing tens ofthousands ofpounds (including payload) and carrying large amounts offuel which inherently presents significant fire hazards as well as exposure to other chemical contaminates. Itis importantto note the use of small UAS inthis areawill not only be safer andmore cost effective to the perspective user or purchaser ofthe service, butthe quality and expanse ofacquired information will be far more robust giventhe low cost associated with its acquisition and other potential consumers an inexpensive product.U.S Depmiment ofTransportation November 12,2015 Page 5 UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greaterprecision and duration at a very low cost. Small UAS will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible orhighly dangerous using conventional aircraft or other inspection methods. 

### III. RELEVANT STATUTORYAUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) ofthe FAA Modemization and Reform Act of2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuant to Section 33 3 ofthe ReformAct, the FAAAdministrator is to permit unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximity to airports andpopulated areas; and • Operation ofthe UAS withinthe visual line ofsight ofthe operator. Additionally, the FAAAdministrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority ofthe Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and §§ 44702-44716, et seq.). A party requesting an exemptionmust explainthe reasons why the exemption: (1) would benefitthe public as a whole, and (2) would not adversely affect safety (or howit would provide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. STELLARVISIONING'S PROPOSED SV-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT The small SV-UAS operations proposedby StellarVisioning as noted above in this Petition for Exemption qualify for expedited approval pursuantto Section 333 ofthe Reform Act as each of the statutory criteria and relevant factors are satisfied. 

### A. Approval is WarrantedBased on the UAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The SV-UAS utilized by Stellar Visioning has been approved for use inprior Section 333 Grants ofExemptionfrom the FAA. 2

2See e.g., Grant ofExemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant ofExemption to VDOS Global, LLC (Exemption No. 11112); Grant ofExemption to LowCountryRC, Corp. (Exemption No. 11184); Grant ofExemption to Alan Purwin (Exemption No. 11161); Grant ofExemption to Helinet Aviation Services (Exemption No. 11160); Grant ofExemption to Total Safety U.S., Inc. (Exemption No. 11156)

..U.S Department ofTransportation November 12, 2015 Page6

• The SV-UAS weighs less than 55 pounds, including payload

• The SV-UAS will not be flown at a ground speed in excess of50 knots. The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 50 knot speed restriction

• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combinationthereof. This information will be transmittedto the pilot viatelemetric data feed.

• The SV-UAS will have system redundancies and independent functionality to ensure the overall safety andpredictability ofthe system. Ifconnection to the remote control or ground control station is lost, failsafe systems will permit the UAS to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control ofthe SV-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the SV-UAS is 2.4 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending onpayload. The difference in weightbetween the SVUAS and a helicopter significantly reduces the potential harmto the participating and nonparticipating individuals and/or sunoundingproperty inthe event ofanunintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated. B. Approval is Warranted Based on the Operational Restrictions Set Forth in Stellar Visioning's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected SV-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment ofStellar Visioning's proposed operations, belowis a summary ofoperational limitations and conditions that Stellar Visioning will adhere to, and which will ensure an equivalent or higher level of safety to operations conducted under cunentregulatory guidelines: 1. The SV-UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted overprivate or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UAS operated under the Grant ofExemption will be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number)U.S Department ofTransportation November 12, 2015 Page 7 markings in accordance with 14 CFRpart45, Subpart C. Markings will be as large as practicable. 4. Minimum crewfor each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe GUN-UAS, and one or more Visual Observers ("Observer") as necessary to safely conductthe mission. 5. PICs shall possess either a private, recreational, or sportpilot certificate. The PIC must also hold a cunentFAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC will also meetthe flight review requirements specified in 14 C.F.R 61.56 in an aircraft inwhich the PIC is rated on his or herpilot certificate. 6. The SV-UAS shall be operated within VLOS ofthe PIC and Observer at all times. The PIC must use human vision unaided by any device otherthan cotTective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operationwill be able to communicate verbally at all times. 8. Electronic messaging ortexting will notbe permitted during flight operations. 9. The additional requirements identified in the Grant ofExemption shall be added to the Stellar Visioning's Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator uponrequest. Ifa discrepancy exists between the conditions and limitations inthe Grant ofExemption and Stellar Visioning's Operations Manuals, the conditions and limitations inthe Grant of Exemption shall take precedence and must be followed. Otherwise, Stellar Visioning shall follow the procedures outlined intheir Operations Manuals. 10. Stellar Visioning may update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to the Administrator upon request. StellarVisioning will also present anupdated and revised Operations Manuals ifitpetitions for extension or amendment to its Grant ofExemption. Ifan update orrevision would affect the basis uponwhich the FAA grants the exemption, Stellar Visioning will seek an amendmentto its Grant ofExemption. Stellar Visioning will contactthe FAA's UAS Integration Office (AFS-80) ifquestions arise regarding updates orrevisions to the operating documents. 11. Stellar Visioning Operations Manuals and its Grant ofExemption will be available to the PIC atthe ground control station anytime the SV-UAS is operating. 12. The PIC is prohibited from beginning a SV-UAS flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes.U.S Department ofTransportation November 12, 2015 Page 8 13. Maximumtotal flight time for each operational flight using the SV-UAS will be limited to 40 minutes orthe amount oftime the UAS can be flown and still maintain a reserve battery power ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enter navigable controlled airspace withouttimely prior written authorization and approval from the FAA. In the eventthe structure being inspected exceeds 400 feet AGL, the UAS will notbe operated more than 100 feet above the highestpoint on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations mustbe conducted at least 500 feet from all nonparticipating persons. (persons otherthanthe PIC, VO, operatortrainees oressential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris inthe event ofan accident. The operator must ensure thatnonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does notpresent anundue hazard, and;

c. Operations nearerto the PIC, VO, operatortrainees oressential persons do not present anundue hazard to those personsper§ 91.119(a). 16. The SV-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 17. The SV-UAS may not operate within 5 nm ofan airportreference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the Stellar Visioning COA. The letter ofagreement with the airport management will be made available to the Administrator uponrequest. 18. Prior to eachflight the PIC shall inspectthe SV-UAS to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents as well as equipmentupdates. The PIC shall not operate any SV-UAS ifthe inspection reveals a condition that affects the safe operation ofthe SV-UAS until the necessary maintenance has beenperformed and the SV-UAS is found to be in a condition for safe flight. The ground control station shall be included inthe preflight inspection. All maintenance and alternations mustbe properly documented inthe UAS's records as required by Stellar Visioning's Operations Manuals.U.S Department ofTransportation November 12,2015 Page 9 19. Stellar Visioning will timely carry out its maintenance, inspections, and record keeping requirements in accordance withthe Operations Manuals. Maintenance, inspection, and alterations will be fully noted in the SV-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized person returning the SV-UAS to service. 20. Any SV-UAS thathas undergone maintenance or alterations that affect the UAS operation orflight characteristics (e.g., replacement ofa flight critical component) must timely undergo a functional test flight in accordance with Stellar Visioning's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and SV-UAS record entry shall be included inthe Stellar Visioning's Operations Manuals. 21. The SV-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins andproductupdates. 22. Prior to the operation, a Mission Packetwill be created in accordance withthe requirements on Stellar Visioning's Operations Manuals.
23. Stellar Visioning will obtain anAir Traffic Organization ("ATO") issued Certificate ofWaiver orAuthorization, otherwise known as a COA, priorto conducting any operations underthis Grant ofExemption. A NOT AMwill be issued as required by the COA. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level andpotential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. Ifthe SV-UAS loses communication with the PIC, it will have the capability to safely return to a pre-determined location withinthe operational area and land safely. 26. Contingency plans will be inplace to safely terminate flight ifthere is a loss of communicationbetween the PIC and the Observer. 27. The SV-UAS will have the capability to safely abort flight in the case ofunpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued within the United States. 29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraftpilot and atleast 10 hours logged as a UAS pilot with a similar SV-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist.U.S Department ofTransportation November 12,2015 Page 10 30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR § 61.51(b), a minimum ofhours pursuantto 54 CFR § 61.51(b) as UAS pilot operating the make and model ofSV-UAS to be utilized for operations underthe exemption and three take-offs andthree landing inthe preceding 90 days. 31. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules ("SVFR") shall notbe conducted. 32. The SV-UAS shall remain clear and yield the right ofwayto all other manned operations and activities at all times (including, butnot limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. SV-UAS Operations under Instrument FlightRules, at night, orbeyond VLOS are prohibited. 34. The UAS will notbe operated from an elevatedplatform unless designed and engineered specifically for suchpurposes and be in compliance with the general restrictions imposedby the applicable regulations. Additionally no PIC will provide any film-flight operations while inmotion from atop any elevated platform vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe SV-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 401 01 ofthe Act, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemptionis inthe public interest.3
Stellar Visioning seeks an exemption from several interrelated provisions ofTitle 14 ofthe Code ofFederal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconducting the requested operations using SV-UAS platforms noted above. Listedbelow are: (1) the specific sections of 14 C.F.Rfor which exemption is sought, and (2) the operating procedures and safeguards that Petitionerhas established which will ensure a level ofsafety betterthan or equal to the rules from which exemption is sought. 4

349 U.S.C. §44701 (f) (authorizing the grant ofexemptions from requirements ofregulations prescribed pursuantto Sections 44701(a) and (b) and Sections 44702- 44716).

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level ofsafety at least equal to that provided by the rule from which you seek exemption.U.S Department ofTransportation November 12, 2015 Page 11 UNMANNEDAIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart H

- Airworthiness Certificates and 14 C.F.R. §91.203(a)(l) The FAA has stated that no exemption is needed from this section ifa finding is made under the Reform Actthatthe UAS selected provides anequivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met and in point offact exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines thatthere are some characteristics ofthe chosen UAS that fail to meetthe requirements ofthe RefmmAct, anexemptionis requested. EquivalentLevelof Safety Stellar Visioning's use ofthe SV-UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth inthe description ofproposed operations in Section IV(A), the SV-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed inexcess of50 knots. The SV-UAS is also equipped with safety features which will allow Petitionerto operate the SV-UAS safely after experiencing certain in-flight contingencies or failures as noted below. 6 7 Additionally, the SV-UAS carries neitherpilots norpassengers, carries no explosive materials or flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in StellarVisioning's Operations Manuals.

5See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6See e.g., Grant ofExemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI S1000] has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) or a lost-link eventwith a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation."

7See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The SV-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The SV-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further thatthe UAS has built-in intelligent fault handling which allows the SV-UAS to detect a system fault while in the air and automatically fly back to its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set wind thresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight termination link- to prevent a 'fly away' or other potentially dangerous situation- is available to the operator."U.S Department ofTransportation November 12,2015 Page 12 Operations conducted underthis exemption will be closely controlled and monitored by the PIC operator and will be conducted incompliance with local public safety requirements, to provide security for the area ofoperation. Stellar Visioning will also provide the FAA with advance notice ofall operations viaNOTAMs as required by the applicable COA. In all cases, operation ofthe SV-UAS underthe proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operating with an airworthiness certificate. Lastly, the SV-UAS do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the SV-UAS. 8 In addition, no sense-and-avoid technology is necessary for the SV-UAS because they will be operated at all times in VFRconditions and withinVLOS ofthe PIC and Operator. 9 B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Stellar Visioning's small SV-UAS would otherwise require certificationunder Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. R. Part 21, Subpart H, 

### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Stellar Visioning seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraftunless that aircraft is identified in accordance with Part45 ofthis chapter.

• 14 C.F.R. § 45.23(b), Markings ofthe Aircraft, states: Whenmarks include only the Roman capital letter "N" and the registration number is displayed onlimited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," "light-spmi, "experimental," or "provisional," as applicable.

• 14 C.F.R. § 45.27(a), Rotorcraft, states:

8See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).U.S Depruiment ofTransportation November 12,2015 Page 13 Each operator ofa rotorcraft must display onthatrotorcrafthorizontally onboth surfaces ofthe cabin, fuselage, boom, or tail the marks required by §45.23. In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted providedthatthe aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part45, Subpati C ifthe markings are as large as practicable." 10 EquivalentLevelof Safety All SV-UAS flown by Stellar Visioning will bearN-number markings that are as large as practicable in accordance with 14 C.P.R. Part 45, Subpart C.u D. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections Stellar Visioning seeks an exemption from the maintenance inspection requirements contained in 14 C.P.R. §91.405(a), 91.407(a) (1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.P.R. Part43. See, e.g., 14 C.P.R. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections

...have discrepancies repaired as prescribed in part 43 ofthis chapter"). An exemption from these regulations is neededbecause Part43 andthese sections only apply to aircraftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption will nothave. (Emphasis added) EquivalentLevelof Safety Anequivalent level ofsafety will be achieved or exceeded because maintenance and inspections will be timely performed in accordance withthe Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by StellarVisioning's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe SV-UAS and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe SVUAS and no flights will occur unless, and until, all flight critical components ofthe SV-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by Stellar Visioning's Operations Manuals, the PIC who conducts the functional test flight will make an entry in the SV-UAS aircraftrecords ofthe flight. Stellar Visioning's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe,

10. FAA DocketNo. FAA-2014-0352.

11. See, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Depmiment ofTransportation November 12,2015 Page 14

camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Stellar Visioning's Operations Manuals also include procedures to document and maintain a record ofthe SV-UAS's maintenance, preventative maintenance, alterations, status ofreplacement/overhaul componentparts, and the total time in service ofthe SV-UAS used under this Grant ofExemption. As a whole, the maintenance and inspectionprocedures required in StellarVisioning's Operations Manuals ensure that an equivalent or higher level ofsafety will be achieved. PILOT-IN-COMMAND OF THE UAS E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations Stellar Visioning seeks exemption from 14 CFR § 61.113, whichrestricts private pilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure thatthe skill and competency ofany PIC matches the airspace inwhichthe PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. In this case, while the SV-UAS will be operated as part ofa commercial operation, they carry neitherpassengers nor cargo. In the Grant ofExemptionto Astraeus Aerial, the FAA determined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class III Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilot would not leadto any additional safety benefits when UAS operations are involved. EquivalentLevelof Safety The restrictions Stellar Visioning has placed on its SV-UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial. Stellar Visioning will operate onprivate property or approved location away from persons and property not involved inthe operation. Stellar Visioning will also obtain an ATO issued COA prior to conducting any operations under this Grant ofExemption. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements. A NOT AMwill also be issued as required by the applicable COA. In additionto these flight restrictions, Stellar Visioning will further ensure safe operationby requiring that any PIC bethoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects ofSV-UAS flight. As set forth inthe Operations Manuals, pilots will have experience not only in SV-UAS operations generally buthave logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights onbehalfofStellarVisioning. The pilot qualification, training, and currency requirements inthe Operations Manuals ensure that Stellar Visioning pilots are competent and proficient inthe SV-UAS they are operating. Stellar Visioning's training and qualification requirements are consistentwiththose contained inprior FAA Section 33 3 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety to the public.

12Exemption No. 11062 (FAA DocketNo. FAA-2014-0352).U.S Department ofTransportation November 12, 2015 Page 15

OPERATING PARAMETERS OF THE UAS**-~·····--·-·~--** F. 14 C.F.R. 

### § 91.7(a): Civil AircraftAirworthiness Inasmuch as there will be no airworthiness certificate issued for the UAS, Stellar Visioning seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy conditionto be operated. The FAAhas stated thatno exemption is required for 14 C.F.R. § 91.7(a) to the extentthatthe requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitionerrequests thatthe requirements for§ 91.7(a) be treated in accordance with Section V(A), supra. G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraftFlightManualin the Aircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.F.R. § 91.9(b) (2) and§ 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraftmanuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft- (2) Forwhich anAirplane orRotorcraft FlightManual is required by § 21.5 ofthis chapter, unless there is available in the aircraft a current approved Airplane orRotorcraft FlightManual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no personmay operate a civil aircraftunless it has within itthe following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis 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. Given the small size and configuration ofthe SV-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals onboard the SV-UAS because there is simply no room and the SV-UAS has no cabin or cockpit. As a way to comply with the code Stellar Visioning will maintain the documents with the PIC and make them available for inspection. 

### EquivalentLevelof Safety

13See Id. at 13-14, 22.U.S Department ofTransportation November 12,2015 Page 16 In an FAA Office ofChiefCounsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledged thatthe intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircrafthas access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilothas access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring thatthe pilothas access to the documents at the ground control station from which he or she is piloting the UAS. H. 14 C.F.R. § 91.103: Preflight Action Stellar Visioning seeks an exemption from 14 C.F.R. 

### § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on boardthe aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extentthat an FAA-approved FlightManual is required. EquivalentLevelof Safety Anequivalent level ofsafety will be provided by following the StellarVisioning's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects orinoperable components in accordance withthe Stellar Visioning's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoffdistance, UA performance data, and contingency landing areas-before initiation offlight. Stellar Visioning's Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS. I. 14 C.F.R. § 91.109(a): Flight Instruction Stellar Visioning seeks an exemption from 14 C.F.R. § 91.109(a), whichprovides inpertinent part that "[n]o 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." UASs and remotely piloted aircraft, by their design, do nothave functional dual controls. Instead, flight control is accomplishedthroughthe use ofa device that communicates with the aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a). EquivalentLevelof Safety Giventhe size and speed oftheUASs that Stellar Visioning intends to use, an equivalent level of safe training can still beperformed without dual controls because no pilot orpassengers are

14Memorandum from Mark Bury, FAA Assistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAAFlight Standards Service (Aug. 8, 2014); see also DocketNo. FAA-2014-0352 at 16-18.U.S Department ofTransportation November 12, 2015 Page 17 aboard the UAS, and as required by the StellarVisioning's Operations Manuals, all persons will be a safe distance away inthe eventthatthe UAS experiences any difficulties during flight instruction. Moreover, as required by the StellarVisioning's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures provided for in Stellar Visioning's Operations Manuals ensure thatthe proposed UAS operations provide an equivalent orhigher level ofsafety thanthatprovidedby the flight instruction regulations. J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes Stellar Visioning requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure innon-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopterto operate atless than thGse minimum altitudes when it canbe operated "without hazard to persons or property onthe surface," provided that "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." An exemptionis required because the proposed SV-UAS operation will normally need to occur below400 feet AGL. In circumstances where the SV-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the SV-UAS will not be operated more than 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) may needto be less than 500 feet away from the SV-UAS. EquivalentLevelof Safety Comparedto ±light operations with rotorcraft weighing tarmore than the maximum weights proposedherein, and giventhe lack offlammable fuel with the above noted UASs, any risk associated withthese operations is far less thanthose whichpresently exist with conventional aircraft. An equivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe SV-UAS, as well as the controlled location where the operations will occur. In orderto avoid any riskto manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, orwhen inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highestpoint onthat structure and 50 feet horizontally ofthe structure. As set forth inthe Operations Manuals, the SV-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless thatperson is in a position where he or she is shielded from the SV-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated ifa nonparticipating personwithin 500 feet ofthe SV-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures

15Relieffrom § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event ofa failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from§ 91.119(b) will notbe necessary. See e.g., Grant ofExemption No. 11157 to Slugwear, Inc., dba Like on atree Aerial (FAA-2014-0534 at 15).U.S Department ofTransportation November 12, 2015 Page 18 unless the property owner/controllertimely has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and, operations nearthe PIC or Observer will notpresent an undue hazard per§ 91.119(a). Adherence to these restrictions in Stellar Visioning's Operations Manuals will ensure operations canbe conducted without compromising public safety. 16 K. 14 C.F.R. § 91.121: Altimeter Settings Stellar Visioning seeks an exemption from 14 C.F.R. §91.121, which requires a person operating an aircraftto maintain cruising altitude or flight level by reference to an altimeter that is setto the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extentthat the UASs do nothave a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety The FAA has stated that an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 canbe achieved in circumstances where: (1) the UASs will be operatedbelow400 feet AGL or below17

, (2) withinVLOS, (3) where GPS based altitude information is relayed inreal time to the operator at a ground-based on-screen display and, (4) where priorto eachflight, a zero altitude initiationpoint is established for the PIC to confirm accuracy ofthe onboard GPS. 18
The SV-UAS that Stellar Visioning intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Stellar Visioning's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compasspriorto each flight operation. Like priorFAA Section 333 Grants ofExemption, the SV-UAS Stellar Visioning intends to use, and the safety mitigation procedures contained inthe Operations Manuals, both ensure that an equivalent level ofsafety orgreater level will be achieved, and a Grant ofExemption to the requirements of § 191.121 is therefore appropriate. L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Stellar Visioning requests an exemptionfrom 14 C.F.R. 

### § 91.151(a)'s fuel requirements for flight inVFRconditions. Section 91.151 states:

16See e.g., Grant ofExemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are presentthat can sufficiently protect nonparticipating persons from the UA or debris in the event ofan accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determines that it does not present an undue hazard."

17Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure.

18See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation November 12, 2015 Page 19

(a) No person may begin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enoughfuel to fly to the first point of intended landing and, assuming normal cruising speed

- (1) During the day, to fly afterthat for at least 30 minutes; or (2) Atnight, to fly after that for at least 45 minutes. Here, the technological limitations onUAS battery powermeans thatno meaningful flight operations canbe conducted while still maintaining a 30-minute battery reserve. Anexemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, itis not Stellar Visioning's intentionto fly the SV-UAS atnight. EquivalentLevelof Safety
In the Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight inVFRconditions could be achieved by prohibiting the PIC from beginning a SV-UAS flight unless (considering wind and forecast weather conditions) there was enough powerto fly to the first intended point oflanding and, assuming normal cruising speed, to fly afterthat for at least 10 minutes. Inreaching this conclusion, the FAA considered thatthe UAS batteries for the SV-UAS provide approximately 50 minutes ofpowered flight (withpayload) and providedbattery level and battery time remaining in minutes and seconds to the PIC. 19 The FAA also considered the fact the SV-UAS operating manual states: "start every flight with a fully chargedbattery inthe aerial vehicle", and that inthe eventthatthe SV-UAS shouldrun low onpower, the PIC will be alerted and can safely land the- SV-UAS as soon as possible. Like the VDOS Grant ofExemption, Stellar Visioning's use ofthe SV-UAS, combined withthe requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety canbe achieved and infact exceeded. Similarly, inthe Grant ofExemptionto Alan Purwin (ExemptionNo. 11161), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions couldbe achieved by prohibiting the PIC from beginning a flight withthe UA unless (considering wind andforecast weather conditions), there was enough powerto safely fly at normal cruising speedto the intended landing point and landthe UA with 25% battery power remaining. Stellar Visioning will adhere to this limitation for its SV-UAS flights. The SV-UAS includes a lowbattery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the SV-UAS to a ground-based-on-screen display.Z0 As required by Stellar Visioning's Operations Manuals, the PIC will promptly fly the SV-UAS backto the home launch location or pre-determined abort location where it may safely land, while still maintaining a minimum of

19. Grant ofExemptionNo. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 20. The SV-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and orientation relative to the UAS.U.S Department ofTransportation November 12, 2015 Page 20 25% reserve battery power. Stellar Visioning submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined withthe requirementthat flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and within VLOS ofthe PIC and Observer(s), ensure thatthe proposed operationwill provide an equivalent orhigher level ofsafety to the public to thatprovidedby the regulations from which exemption is sought. 

### VI. DRUG AND ALCOHOL PROGRAM Stellar Visioning will have policies inplace to ensure that no person may participate in SV-UAS flight operations ifthey are underthe influence ofalcohol or any drug. 

### VII. PUBLIC INTEREST The public interest will be served by granting Stellar Visioning's Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed inthis Petition. Granting this Petition for Exemption helps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-the FAA Administrator's assessment ofwhethercertain UAS may operate safely in the NAS before completion ofthe statutorily required rulemaking. The proposed SV-UAS operations inthis Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whompermission was granted for use by Petitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be in the local vicinity. Traditional methods ofproviding surveillance and mapping services locationpersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for whichthe individual is neither trained nor equipped to perform, which exposes themto unnecessary risk ofserious physical injury from dangerous falls or otherphysical mishaps. Moreover, inspectors/surveyors are oftenunnecessarily exposedto hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifYing specific locations for potential recording sites to be used inthe end product. The use ofsmall UAS can eliminate these hazards and ultimately create a much safer method ofperforming these types ofinspections creating a safer environment for the public as well as Stellar Visioning employees. The use ofsmall UAS also enhances safety andreduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crewin addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, inthe unlikely event of an accident, StellarVisioning's small battery powered SV-UAS presents significantly less danger to persons onthe ground when compared to operations by conventional manned aircraft. 21

21See Grant ofExemptionNo. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event ofan incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation."U.S Depmiment ofTransportation November 12,2015 Page 21 As Petitioner's SV-UAS are battery powered, the public will also benefit from a reduction in harmful petroleumbased emissions associated with conventional aircraft performing inthe same functions proposed herein. Air quality will naturally be improved with the reduction offuel powered vehicles. Lastly, as recognized by the FAA in prior Section 333 Grants ofExemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the indust1y, adding a greater degree offlexibility, which supplements the current capabilities offered by manned aircraft.22 The quality ofthe finished product is enhanced andprovides a greater finished product demand which will aid the current UAS industry and provide additionaljobs as the cost of providing the needed product is greatly reduced while reducing the difficulty withwhichthe finished product is created. The demand for the current industrial product is increasing and will continue to increase giventhe enhanced flexibility ofproduction; therefore, giventhe lower cost, owner/operators and others inthe relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All SV-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication inthe FEDERAL REGISTER, should it be determinedthat publication is needed: Petitioner seeks an exemption from the following rules inTitle 14 ofthe Code ofFederal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video productionwith conventional fixed-wing aircraft, rotorcraft, or other methods. 

### X. CONCLUSION Stellar Visioning's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas; operation within VLOS and national security. The proposed SV-UAS

22See e.g., Grant ofExemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation November 12,2015 Page 22 operations will benefitthe public as a whole by improving safety and reducing riskby alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. In consideration ofthe foregoing, this Petition for Exemption provides the FAAwithmore than adequatejustificationfor granting the requested exemptions allowing Stellar Visioning to use small SV-UAS inthe recordedproduction ofits product.
We thankyou for your prompt consideration ofour requested exemptions. Respectfully Submitted,

David M. Dulan Stellar Visioning, LLC 1

715 Westridge Road Los Angeles, California 90049 Phone: 310.713.8085 Email: daviddulan@gmail.com (The following attached items containproprietary and commercial information exempt from disclosure under the Freedom oflnformationAct, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuantto 14 C.F.R. § 11.35(b)). Attachments: 0. MPTOM Motion Picture and Television Operations Manual 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. PostFlight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals