APPLICATION/PETITION FO R EXEMPTION (Drone “UAV” Use)

Manager of Risk and Crowd Services
SFX Entertainment 430 Park Ave New York, NY sdennison@sfxii.com Tel; 480

- 707

- 3798 

# STATED SECTION(S) FOR RELIEF SOUGHT
COMES NOW, SFX Entertainment, Inc. herein after referred to as SFX, and does hereby submit and request exemptions to FAA Rules for drone (UAV) usage, and seeks an exemption Filed under Section 333 to grant relief from and an airworthiness Certificate unde r the FAA Modernization and Reform Act of 2012, Public Law 112

- 95 FEB 14,2012, Section 333. SFX is a domestic public company that specializes in the production of large Music Festivals around the United States. At all times, SFX carries insurance, is fully legal in all Stats and has NEVER operated a UAV at any time, prior to this application being filed. Our use of the DJI 900 is less than 3.3kg and does not fly over 35 mph and does not operate in proximity to airports and populated areas, and operation i s within a visual line of sight does not create a hazard to users in the national airspace system or the public or pose a threat to national security. 

## Exemption **under the Requirements of 14CFR 11.81** SFX will conduct UAV operations safely to minimize risk t o the NAS or to persons and property on the ground. SFX will use its UAV to conduct monitoring of traffic flow and parking lots in order to assist State and Local Law Enforcement agencies in traffic management at our outdoor music festivals. The cost inc urred by obtaining a helicopter is excessive and the monitoring of traffic using a UAV is an economic advantage to all parties concerned. In fact many local law enforcement agencies do not have access to helicopter for this purpose. We have included in th is submission a copy of the DJI 900 a commercially available UAV that has been used extensively in the United States with an excellent safety record. SFX has an ongoing relationship with FAA headquarter (Mr. Brian Thoorp brian.thoorp@faa.gov ) for limiting overflights at our concert venue and also DHS ( **JONATHAN D. RICHESON** , Security Specialist Commercial and Government Facilities Section, Sector Outreach and Programs Division Department of Homeland Security.
Prior to any flight a complete pre

-flight is conducted, weekly operational inspections and an annual inspection by an authorized DJI service center to insure that all operational components are in proper factory specifications. (See Attached manual) The Radio F requency spectrum that is used for control and its associated equipment is in the 2.4 giga hertz range and complies with the Federal Communications Commission requirements.

## Pilot in Command

The UAV for SFX will only be operated by Mr. Scott Dennison t he Manager of Risk and Crowd Services. Mr. Dennison is a licensed commercial pilot with instrument and multi

- engine rating with over 7000 hours of flight time in a variety of aircraft (Certificate number 579623050). Mr. Dennison also has a BS degree in Aviation Technology from Purdue University. In addition Mr. Dennison is also a former Special Agent for FAA and Federal Air Marshall. Mr. Dennison also is actively involved with many Federal Agencies to include DHS. Mr. Dennison has taken a variety of significant courses offered by DJI the manufacturer of the UAV on its operation and safety requirements. Mr. Dennison knows the safety threat these vehicles can pose to air traffic, the general public and others, and as such, since he has a working, and re al world knowledge, his operation of a UAV is far superior than that of an operator that merely buys a UAV and then operates it outside the confines and guidelines/regulations of the FAA. 

## Proposed Operations: SFX has 5 major outdoor festivals a year loc ated in remote communities. The Manager of Risk works closely with Federal, State and Local Law Enforcement to insure a safe environment for our employees, patrons and the local community. In this effort the proper management of traffic into and out of t he event is of major concern to law enforcement and the local community. In order to properly manage traffic operations information must be passed to State and Local law enforcement on the flow of traffic into and out of the event along with the current status of parking lot capacities. Due to the limited number of police officers available to monitor traffic operations and the excessive cost of renting a helicopter the UAV offers immediate information to all involved at an economical cost. The UAV will be operated at altitudes not to exceed 300 feet and a forward speed of less than 25 mph. Minimum flight visibly will be set at 3 miles. The UAV is not intended to be flow over persons but only to monitor traffic operations. If winds exceed 25 mph the UAV will not be used. Safety measures in place for the UAV are contained in the operations manual of the DJI900. In addition the DJI900 used by SFX is equipped with a deployable parachute that can be remotely operated. All flights by the SFX UAV will be l ine of sight with an observer and the pilot, during daylight conditions, inside Class G (uncontrolled) airspace and more than five miles from any airport or other location with aviation activities.

## Operational Area

The UAV use is intended solely for the footprint of the venue for each music event on a conditional use permit granted by the county or city of the event. Prior to any operational use a complete risk assessment is done to determine any obstructions to the proposed flight paths that would be involved. The UAV will not be operated within 5 miles of any airport. Visual line of site will be accomplished by the Pilot and his observer watching the aircraft at all times. Information is relayed to local law e nforcement officials via 2 way radio. In addition SFX operates with the cooperation of Federal, State and Local Law Enforcement officials and Incident Command Post (ICP). All flight operations are cleared with the ICP prior to departure and prior to land ing. This is in accordance with Section 333 (b)(1) 

## Pre Flight Safety Risk Assessment:
A pre

-flight a safety risk assessment is done in accordance with 14CFR 91.7(b). This information is contained in the DJ900 operations manual. In addition to this SF Ris k Department conducts a total assessment of all flight paths, take off locations and landing zones. The SFX risk Department has meteorologist on site at all times to insure the weather conditions are proper for the safe UAV flight operations. No operatio n of the UAV can occur till such time as the on

- site meteorologist has approved the flight based on local conditions. , shall at all times, and as a minimum, observe all applicable regulations of 14 CFR parts 61 and 91. This document is intended to identify alternate methods of compliance with the regulations when evaluating proposed UAS operations. In this case, the applicant himself, that was in fact, is an accomplished pilot and former FAA Official, the applicant understands and has working knowledge of the rules of flight, air traffic patterns, safety standards, aeronautics, which SFX would argue is way beyond that of the typical and relevant average operator now existing and making use of an UAV. 

## SUMMARY WHEREFORE, the applicant, SFX (Scott Denniso n), respectfully requests a (24) month exemption to lawfully, within the stated regulations of the FAA and others, and as stated, operate a UAV for the sole purpose of traffic management for music festivals in support of State and Local Law Enforcement. FU RTHER, it is stated and affirmed here, that SFX (Sean Murphy) has made application for the required COA.