May 30, 2015

Remote Control Video Productions, LLC Dave Bradlaw Director of Videography PO Box 93592 Southlake, TX 76092 214

-945

-3776 Cell 817

-681

- 3996 Email: nadar1@charter.net

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act of 2012 References: Exemption N umbers : 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352) 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507) 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382) 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642)

Dear Sir or Madam, In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, Remote Control Video Productions, LLC, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§ 61.113(a) ; 61.113(b ) ; 91.119(c ) ; 91.121 ; 91.151(a ) ; 91.405(a ) ; 91.407(a ) ( 1 ) ; 91.409 (a ) ( 1 ) ; 91.409(a ) ( 2 ) ; 91.417(a) & (b ) ; i n order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are con ducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references listed above

. The FARsThe petitioner seeks exemption from the above mentioned FARs for the following reasons;

61.113(a) & (b ) The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with the addition of a trained observer. All pre

-flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civil UAS operation in the National Airspace System. 91.119(c) As discussed in Exemption Nos. 11062, 11109, 11112, and 11213 , operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. The petitioner will operate the UAS between ground level and 400 feet. The UAS will be operated over designated properties with the owner’s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. T his data may assist the FAA in development of regulations for commercial operations in low

risk, controlled environments.
91.121 As discussed in Exemption Nos. 11062, 11109, 11112, and 11213 , 91.121 i s not applicable since the UAS does not have an altimete r and instead utilizes electronic GPS with a sensor for altitude information. 91.151(a) As discussed in Exemption Nos. 11062, 11109, 11112, and 11213 prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, In addi tion, similar UAS specific relief has been granted for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating docum ents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations an d the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a ) ; 91.407(a ) ( 1 ) ; 91.409 (a ) ( 1) & (2 ) ; 91.417(a) & (b) As discussed in Exemption Nos. 11062, 11109, 11112, and 11213 , the petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and limitat ions specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected. The UASThe DJI In spire 1 and DJI S1000+ are highly successful professional grade small rotorcraft

. The DJI In spire

1 is a quadcopter design a nd the DJI 1000+ is an o ctocopter design. Both models have a weight of less than 55 pounds including payload and are d esigned primarily to carry aloft a high definition camera. Both models have an advertised maximum speed of less than 87 knots ( 100 mph ) . Both models are equipped with the DJI A2 flight controller and utilize an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain it s geospatial orientation and position. Each UAS is controlled through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC,
camera imagery, and control camera angle. Both models have failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum al titude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. More information is available in attachment 1 and 2

. Risk mitigation The petitioner has reviewed the Conditions and Limitations section of the FAA exemptions referen ce d above and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will b e verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA to as sist in future implementation of safety standards and regulations. The petitioner will only operate the UAS over designated properties with the owner’s consent. Flight plans will be predetermined to limit the UAS flight time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating the UAS. UAS operation will always be within VLOS of the PIC and the observer. Public interest Use of the UAS in lieu of a manned aircraft would enhan ce safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground leve l videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA and SoT for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means or other means as required.Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, videography, inspections, and other flight operations”. The reason for such a general and broad based request is that the petitione r wishes to utilize a business strategy to maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the turnaround time associated with additional exemptions. The petitioner's business model is based on th e idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has refrained from engaging in commercial use of the UAS. T he primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. The petitioner’s Director of Videography is a member of the Academy of Model Aeronautics (AMA) and has experience in the radio
control model aircraft hobby. Respectfully submitted , Remote Control Video Productions, LLC

Dave Bradlaw Director of Videography