November 17, 2015 U.S. Department ofTranspmiation DocketManagement System 1200 New JerseyAve., SE Washington, DC 20590 Re: Petition ofAircam360 for an Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 Director: Flight Standards Service: Pursuant to Section 333 ofthe FAAModernization and RefmmAct of2012 ("ReformAct") and 14 C.P.R. Part 11, Aircam360 ("Aircam") 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 photography, videography and cinematography for residential and commercial real estate for related real estate and construction industries. Additionally, Aircam provides aerial photography and videography services for outdoor events. This petition for exemption is made based oninformation outlined inthis Petition for Exemption, as well as the accompanyingAit·cam 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. Flight ManuaP (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") Aircam submits these supporting materials as confidential documents pursuant to 14 C.P.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary informationthat Aircam has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures 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: ALLATTACHMENTS SET FORTH IN SUPPORT OFTHIS LETTER OF PETITIONARE CONFIDENTIALAND SHALLNOT BE RELEASED TO THE PUBLIC WITHOUT WRITTENAUTHORIZATION 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, componentmaintenance manuals, pilottraining manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation November 17, 2015 Page2 For your convenience, this Petition is organized as follows: I. 

### Description ofPetitioner II. Description ofProposed Operations A. Aerial Videography, Photography and Cinematography 

### III. Relevant StatutoryAuthority IV. Aircam's Proposed UAS Operations Meet the Requirements ofSection 333 of the ReformAct A. Approval is Wan-anted Based on the UAS's Size, Weight, Speed, and Operational Capability B. Approval is Wan-anted Based onthe Operational Restrictions Set Forth in the Operations Manuals 

### V. Regulations FromWhich Exemption is Requested A. 14 C.F.R. Part 21, SubpatiH- Airwmihiness Certificates and 14 C.F.R. § 91.203(a)(1) 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)(l), 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): CivilAircraftAirworthiness G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraft Flight Manual in theAircraft and 14 C.F.R. 

### § 91.203(a) and (b): Canying CivilAircraft Certification and Registration H. 14 C.F.R. 

### § 91.103: PreflightAction I. 14 C.F.R. 

### § 91.109(a): Flight Instruction J. 14 C.F.R. 

### § 91.119(c): Minimum SafeAltitudes 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 andAlcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. ConclusionU.S Department ofTransportation November 17, 2015 Page3 

### I. DESCRIPTION OF PETITIONER Aircam is based in Moorpark, CAworking inreal estate photography, videography and cinematography services. The Company specializes in, and will continue to focus onthe photography, videography and cinematography ofreal property for the industrial and commercial real estate industry as well services for outdoor events. The Company's Principal and Chief Pilot Thomas Gluckman has been flying UAV Quadcopters as a hobby for more than one year without incident, spending hundreds ofhours flying. Upon the grant ofthe 333 Exemption the Company's business will specialize inreal estate photography, videography and cinematograph industrial and commercial properties. As well as services for outdoor events. Aircam's staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot in command ("PIC") in addition to any other needed on site assistance. All ofthe equipment owned by Aircam is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. Aircam'ss goal is to advise the perspective client thatAit·cam 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. Aircam seeks an exemption to allow for photography, videography and other related media products. The contact information for Petitioner is as follows: Thomas Gluckman Aircam360 7259 University Drive Moorpark, CA93021 Phone: 805.338.3969 Email: thomas@aircam360.com 

### II. DESCRIPTION OF PROPOSED OPERATION Aircam seeks an exemption pursuant to Section 333 ofthe Reform Act to operate the DJI Inspire 1 (referred to AC-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions onprivate property or approved location whereAircam has received verifiable permissionto operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance withthe conditions and limitations ofthis Petition for Exemption andAircam's Operations Manuals. As detailed inAircam's Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") ofthe operator, in uncontrolled airspace, and will occur at least 5 nm away from an airpmt reference point. Moreover, Aircam's Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies.U.S Depatiment ofTransportation November 17,2015 Page4 A. Aerial Videography, Photography and Cinematography Aircam seeks to use smallAC-UAS for the purpose ofconducting aerial photography, videography and cinematography for the real estate industry and will provide aerial services for outdoor events. Aircam has purposefully tailored its operations to meet the requirements established bythe FAAinprior grants ofexemption authorizing commercial use ofUAS inthe real estate industry, including:

• Trudeau, Realtor® (ExemptionNo. 11138) • Alon Sicherman (ExemptionNo. 11728) • Sokoler Medly (Exemption No. 11341) • Raven Executive (Exemption No. 12639) • Christopher Mergenthaler (ExemptionNo. 13509) All UAS photography, videography and cinematography operations will occur onprivate property or approved location in a controlled area away from spectators andpersons not involved inthe 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 of the UAS; VFRconditions, at altitudes below 400' above ground level ("AGL"). As set forth below, Aircam's operations provide an equivalent level ofsafety which is superior to performingthe same workusing conventional fixed-wing aircraft or helicopters. Small UAS video production is also safer than traditional 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 workrelated 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 ofAC-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most other types ofinspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks associated withvehicles weighing tens ofthousands ofpounds (including payload) and can-ying 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 area will not only be safer and more 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 otherpotential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greater precision and duration at a very low cost. Small UASs will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible or highly dangerous using conventional aircraft or other inspection methods.U.S Department ofTransportation November 17, 2015 Page 5 

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

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

### IV. AIRCAM'SS PROPOSEDAC-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The smallAC-UAS operations proposedbyAircam as noted above inthis Petition for Exemption qualify for expedited approval pursuant to Section 333 ofthe ReformAct as each ofthe statutory criteria and relevant factors are satisfied. 

### A. Approval is Warranted Based 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.

• TheAC-UAS utilized byAil·cam has been approved for use inprior Section 333 Grants ofExemption from the FAA.2

• TheAC-UAS weighs less than 55 pounds, including payload

• TheAC-UAS will notbe flown at a ground speed in excess of50 knots. The exemptionholder may use either groundspeed or calibrated airspeed to determine compliance with the 50 knot speed restriction.

2 See e.g., Grant ofExemption to Trudeau, Realtor® (Exemption No. 11138); Grant ofExemption to A1on Sicherman (Exemption No. 11728); Grant ofExemption to Sokoler Medly (ExemptionNo. 11341).U.S Department ofTranspotiation November 17, 2015 Page 6

• Altitude information will be generated by equipment onboard the UAS as specifiedusing GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. This information will be transmitted to the pilot viatelemetric data feed.

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

• The radio frequencies used for operations and control oftheAC-UAS comply withthe Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for theAC-UAS is 2.4 GHz frequency bands. Ifthe same operations were conductedusing a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending on payload. The difference inweight betweentheACUAS and a helicopter significantly reduces the potential harm to the pmiicipating and nonparticipating individuals and/or surroundingproperty inthe event ofan unintended 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 Aircam's Operations Manuals Ait·cam's Operations Manuals and the Manufacturer's Manual for the selectedAC-UAS will contain all the procedures and limitations necessary to safely and successfully performthe operations specified inthis Petition for Exemption. To assist the FAAinmaking a safety assessment ofAircam's proposed operations, below is a summary ofoperational limitations and conditions thatAircam will adhere to, and which will ensure an equivalent orhigher level of safety to operations conducted under currentregulatory guidelines: 1. The AC-UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted overprivate or controlled-access property with verifiable petmission from the land owner/controller or authorizedrepresentative. Petmission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UASs operatedunder the Grant ofExemptionwill be identified by serial number, registered in accordance with 14 CFRpmi 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings will be as large as practicable. 4. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe AC-UAS, and one or more Visual Observers ("Observer") as necessary to safely conductthe mission.U.S Department ofTransportation November 17,2015 Page 7 5. PICs shall possess either a private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meetthe flight review requirements specified in 14 C.F.R 61.56 in an aircraft in whichthe PIC is rated on his or her pilot certificate. 6. TheAC-UAS shall be operated withinVLOS ofthe PIC and Observer at all times. The PIC must use human visionunaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging or texting will not be permitted during flight operations. 9. The additional requirements identified in the Grant ofExemption shall be added to theAircam's Operations Manuals. The Operations Manuals will be maintained and made available to theAdministrator upon request. Ifa discrepancy exists betweenthe conditions and limitations inthe Grant ofExemption and Aircam's Operations Manuals, the conditions and limitations inthe Grant ofExemption shall take precedence and must be followed. Otherwise, Ait·cam shall follow the procedures outlined in their Operations Manuals. 10. Ah·cam may update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to theAdministrator uponrequest. Aircam will also present anupdated and revised Operations Manuals ifitpetitions for extension or amendment to its Grant ofExemption. Ifan update or revision would affect the basis upon which the FAA grants the exemption, Aircam will seek an amendmentto its Grant ofExemption. Aircam will contactthe FAA's UAS Integration Office (AFS-80) ifquestions arise regarding updates or revisions to the operating documents. 11. Ait·cam Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime theAC-UAS is operating. 12. The PIC is prohibited from beginning aAC-UAS flight unless (considering wind and forecast weather conditions) there is enoughpower to fly to the first intendedpoint of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximumtotal flight time for each operational flight using the AC-UAS will be limited to 40 minutes or the 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 feetAGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. Inthe event the structure being inspected exceeds 400 feetU.S Department ofTransportation November 17,2015 Page 8 AGL, the UAS will not be operated more than 100 feet above the highest point onthe stmcture, and no more than 50 feet horizontally from the stmcture. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operatortrainees or essentialpersons), vessels, vehicles, and stmctures unless:

a. Barriers or stmctures are presentthat sufficiently protect nonparticipating persons from the UAand/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. 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 stmctures where the owner/controller ofsuch vessels, vehicles or stmctures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per 

### § 91.119(a). 16. The AC-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 AC-UAS may not operate within 5 nm ofan airport reference 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 NOT AM as required by theAircam360A. The letter ofagreement withthe airport management will be made available to theAdministrator upon request. 18. Prior to each flight the PIC shall inspect theAC-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 inthe relevant sections ofthe operating documents as well as equipmentupdates. The PIC shall not operate any AC-UAS ifthe inspectionreveals a conditionthat affects the safe operation oftheAC-UAS until the necessary maintenance has beenperformed and the AC-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 must be properly documented inthe UAS's records as required byAircam's Operations Manuals. 19. Aircam will timely cany out its maintenance, inspections, and record keeping requirements in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be fully noted inthe AC-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized personreturning theAC-UAS to service.U.S Department ofTransportation November 17, 2015 Page9 20. Any AC-UAS that has undergone maintenance or alterations that affect the UAS operation orflight characteristics (e.g., replacement ofa flight critical component) musttimely undergo a functional test flight in accordance withAircam's Operations Manuals. The PIC who conducts the functional test flight must make an entry inthe UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight andAC-UAS record entry shall be included inthe Aircam's Operations Manuals. 21. The AC-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and productupdates. 22. Priorto the operation, a Mission Packet will be created in accordance withthe requirements onAircam's Operations Manuals. 23. Aircam will obtain anAir Traffic Organization ("ATO") issued Certificate ofWaiver orAuthorization, otherwise known as a COA, priorto conducting any operations under this Grant ofExemption. A NOTAM will be issued as required bythe COA. All operations will be conducted in accordance with airspace requirements in the ATO issued COAincluding 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. IftheAC-UAS loses communicationwiththe PIC, it will have the capabilityto safely return to a pre-determined location within the operational area and land safely. 26. Contingencyplans will be inplace to safely terminate flight ifthere is a loss of communicationbetweenthe PIC and the Observer. 27. TheAC-UAS will have the capability to safely abort flight inthe 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. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilotwith a similarAC-UAS type platform. This requirement canbe achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51(b), a minimum ofhours pursuantto 54 CFR 

### § 61.51(b) as UAS pilot operating the make and model ofAC-UAS to be utilized for operations under the exemption and three take-offs and three landing in the preceding 90 days.U.S Department ofTransportation November 17, 2015 Page 10 31. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted. 32. TheAC-UAS shall remain clear and yieldthe right ofwayto all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. AC-UAS Operations under Instrument FlightRules, at night, or beyondVLOS are prohibited. 34. The UAS will not be operated from an elevatedplatformunless designed and engineered specifically for such purposes and be in compliance withthe general restrictions imposed by the applicable regulations. Additionally no PIC will provide any film-flight operations while inmotion from atop any elevatedplatfmm vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control oftheAC-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### V. REGULATIONS FROMWHICH EXEMPTION IS REQUESTED The FederalAviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 oftheAct, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest. 3 Aircam seeks an exemption from several intenelatedprovisions ofTitle 14 ofthe Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconducting the requested operations usingAC-UAS platforms noted above. Listedbelow are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards thatPetitioner has established which will ensure a level ofsafety better than or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.203(a)(l)

3 49 U.S.C. § 44701(f) (authorizingthe grant ofexemptions fi·om requirements ofregulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716).
4 14 C.F.R § 11.8l(e), which requires a petition for exemptionto 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 17, 2015 Page 11 The FAAhas stated that no exemption is needed from this section ifa finding is made under the ReformActthat the UAS selected provides an equivalent 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 that there are some characteristics ofthe chosen UAS that fail to meetthe requirements ofthe ReformAct, an exemption is requested. EquivalentLevelof Safety Aircam's use ofthe AC-UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth in the description ofproposed operations in Section IV(A), theAC-UAS weighs less than 55 pounds, including payload and will notbe flown at a ground speed in excess of50 knots. TheAC-UAS is also equipped with safety features which will allow Petitionerto operate the AC-UAS safely after experiencing certain in-flight contingencies or failures as noted below. 6 7 Additionally, theAC-UAS carries neither pilots nor passengers, 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 inAircam's Operations Manuals. Operations conducted under this exemption will be closely controlled and monitoredby the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. Ah·cam will also provide the FAAwith advance notice ofall operations viaNOTAMs as required by the applicable COA. In all cases, operation oftheACUAS under the proposed conditions will be at least as safe as, or safer than, conventional

5 See Grant ofExemption No. 11062 to AstraeusAerial (FAA-2014-0352 at pgs. 13-14, 22).

6 See 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 event with 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."

7 See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The AC-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to commandthe system where to go, and the system does all the flying for the operator. The AC-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 deemedunsafe orunnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the AC-UAS to detect a system fault while in the air and automatically fly backto its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set windthresholds; and low batte1y levels." All flight operations are global positioning system (GPS) controlled, making the system easyto navigate. At any point ifthe operator is not explicitly commandingthe 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 17, 2015 Page 12 rotorcraft operating with an airworthiness cetiificate. Lastly, the AC-UASs do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessedby the PIC and Observer, who are not onboardtheAC-UAS. 8 In addition, no sense-and-avoid technology is necessary for theAC-UASs because they will be operated at all times inVFR conditions and withinVLOS ofthePIC and Operator. 9 B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airwotihiness certification of normal category rotorcraft. To the extentthatAircam's small AC-UAS would otherwise require cetiificationunder Part 27, Petitioner seeks an exemption from Part 27's airwmihiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. 

### R. Pmi 21, Subpart H, 

### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Aircam seeks an exemptionfrom 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), CivilAircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.F.R. § 45.23(b), Markings oftheAircraft, states: Whenmarks include only the Roman capital letter "N" and the registration number is displayed onlimited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display onthat aircraft near each entrance to the cabin, cockpit, or pilot station, inletters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-spmi, "experimental," or "provisional," as applicable.

• 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display on that rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, or tail the marks required by § 45.23.

8 See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).U.S Depmiment ofTransportation November 17, 2015 Page 13 In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted providedthat the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10 EquivalentLevelof Safety AllAC-UAS flown byAircam will bearN-number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11 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 Aircam seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards inreference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. 

### § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis pmi and shall between required inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). An exemption from these regulations is needed because Part 43 andthese sections only apply to aircrqftwith an airworthiness certificate, which the UASplatforms to be operated under this grant of exemption will nothave. (Emphasis added) EquivalentLevelof Safety An equivalent 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 Aircam's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe AC-UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation oftheAC-UASs and no flights will occurunless, and until, all flight critical components oftheAC-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 byAircam's Operations Manuals, the PIC who conducts the functional test flight will make an entry in the AC-UAS aircraftrecords ofthe flight. Aircam'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: powetirain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Ait·cam's Operations Manuals also include procedures to document and maintain a record oftheAC-UAS's maintenance, preventative maintenance, alterations, status of replacement /overhaul componentparts, andthe total time in service ofthe AC-UAS used under this Grant ofExemption. As a whole, the maintenance and inspection procedures required in

1

# °FAA Docket No. FAA-2014-0352.
11 See, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Department ofTransportation November 17,2015 Page 14 Aircam'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 Aircam seeks exemption from 14 CFR 

### § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace inwhich the PIC will be operating, as well as requiring certifications ifthe private pilotis carrying passengers or cargo for hire. Inthis case, while the AC-UAS will be operated as part ofa commercial operation, they carry neither passengers nor cargo. Inthe Grant of Exemptionto Astraeus Aerial, the FAAdetermined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrantthe additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilot to become qualified as a commercial pilotwould not leadto any additional safety benefits whenUAS operations are involved. EquivalentLevelof Safety The restrictionsAircam has placed on its AC-UAS operations meet or exceedthe restrictions similarly imposed onAstraeus Aerial. Aircam will operate onprivate property away from persons and property not involved inthe operation. Ait·cam will also obtain anATO issued COA priorto conducting any operations underthis Grant ofExemption. All operations will be conducted in accordance with airspace requirements intheATO issued COAincluding class of airspace, altitude level andpotential transponder requirements. ANOT AM will also be issued as requiredby the applicable COA. In additionto these flight restrictions, Ait·cam will further ensure safe operationbyrequiringthat any PIC be thoroughly versed not onlyin airspace and communication issues pe1iaining to all aircraft operators but also inthe unique aspects ofAC-UAS flight. As set forth inthe Operations Manuals, pilots will have experience not only inAC-UAS operations generally buthave logged flight time inthe specific make and model used for the operations before they are permittedto participate incommercial flights onbehalfofAircam. The pilot qualification, training, and currency requirements inthe Operations Manuals ensure thatAircampilots are competent and proficient intheAC-UAS they are operating. Aircam's training and qualificationrequirements
are consistent withthose contained inpriorFAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency andproficiency for its pilots and will ensure at least an equivalent level ofsafety to the public.

12 Exemption No. 11062 (FAA DocketNo. FAA-2014-0352).U.S Department ofTranspmiation November 17,2015 Page 15 OPERATINGPARAMETERS OFTHE UAS F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness Inasmuch as there will be no airwmihiness ce1iificate issued for the UASs, Aircam seeks an exemptionfrom 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airwmihy condition to be operated. The FAAhas stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extentthatthe requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with SectionV(A), supra. G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraftFlightManual in theAircraft 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 airwmihiness documents and other aircraft manuals onboardthe aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2): (b) No personmay operate a U.S.-registered civil aircraft- (2) For which anAirplane or Rotorcraft Flight Manual is required by § 21.5 ofthis chapter, unless there is available inthe aircraft a current approvedAirplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuantto 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and cmTent airwmihiness certificate

... (b) No person may operate a civil aircraft unless the airwmihiness 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. Giventhe small size and configuration ofthe AC-UAS, itwouldbe impossible to keep airworthiness documents and other aircraft manuals onboardthe AC-UAS because there is simply no room and the AC-UAS has no cabin or cockpit. As a way to comply withthe code Aircam will maintain the documents withthe PIC and make them available for inspection. 

### EquivalentLevelof Safety In an FAA Office ofChiefCounsel's Opinion datedAugust 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the UAS flight

13 See Id. at 13-14, 22.U.S Department ofTransportation November 17,2015 Page 16 manual, registration certificate, and other required documents from the ground control station from whichhe or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilot has 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: PreflightAction Aircam seeks an exemption from 14 C.F.R. 

### § 91.103, whichrequires a PIC to become familiar with specific information before each flight, including information contained inthe FAAapproved FlightManual onboardthe aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extent that an FAAapproved Flight Manual is required. EquivalentLevelof Safety An equivalent level ofsafety will be provided by following the Aircam's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance with theAircam's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flightprocedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoff distance, UAperformance data, and contingency landing areas-before initiation offlight. Aircam'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 operatingthe UAS. 

### I. 14 C.F.R. § 91.109(a): Flight Instruction Aircam seeks an exemption from 14 C.F.R. § 91.109(a), whichprovides inpertinentpartthat "[n]o personmay operate a civil aircraft (except a manned free balloon) that is being used for flight instructionunless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use ofa device that communicates withthe 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 ofthe UASs thatAircamintends to use, an equivalent level ofsafe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required bytheAircam's Operations Manuals, all persons will be a safe distance away inthe eventthatthe UAS experiences any difficulties during flight instruction. Moreover, as required bytheAircam's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safetyprocedures provided for inAircam's

14 Memorandum from Mark Bury, FAAAssistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAAFlight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18.U.S Department ofTransportation November 17,2015 Page 17 Operations Manuals ensure that the proposed UAS operations provide an equivalent or higher level ofsafetythan that providedbythe flight instruction regulations. J. 14 C.F.R. 

### § 91.119(c): Minimum SafeAltitudes Aircamrequests 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 helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons orproperty onthe surface," provided that "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters bythe FAA." An exemption is required because the proposedAC-UAS operation will normally needto occur below 400 feet AGL. In circumstances where theAC-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the AC-UAS will notbe 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 need to be less than 500 feet away from the AC-UAS. EquivalentLevelof Safety Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack offlammable fuel withthe above noted UASs, any risk associated with these operations is far less thanthose whichpresently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe AC-UASs, as well as the controlled location where the operations will occur. Inorderto avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, or when inspecting a U.S. structure whose height exceeds 400 feetAGL, within 100 feet above the highest point onthat structure and 50 feet horizontally ofthe structure. As set forth inthe Operations Manuals, theAC-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 that person is in a position where he or she is shielded from theAC-UAS and any possible debris resulting from its failure. As required bythe Operations Manuals, flights will be terminated ifa nonparticipatingperson within 500 feet ofthe AC-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timelyhas granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and, operations near the PIC or Observer will notpresent anundue hazard per 

### § 91.119(a). Adherence to these restrictions in

15 Relieffrom§ 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons orpropetty 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 a tree Aerial (FAA-20 14-0534 at 15).U.S Department ofTransportation November 17, 2015 Page 18 Aircam's Operations Manuals will ensure operations canbe conducted without compromising public safety. 16 K. 14 C.F.R. § 91.121: Altimeter Settings Aircam seeks an exemptionfrom 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeterthat is setto the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extent thatthe UASs do nothave a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety The FAAhas statedthat an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 canbe achieved in circumstances where: (1) the UASs will be operated below400 feetAGL or below1

### 7, (2) withinVLOS, (3) where GPS based altitude infmmation is relayed in real time to the operator at a ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiationpoint is established for the PIC to confirm accuracy ofthe onboard GPS. 18 TheAC-UAS thatAit·cam intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required byAircam's Operations Manuals, the PIC will berequired to calibrate the aircraft's GPS compass priorto each flight operation. Like prior FAA Section 333 Grants ofExemption, theAC-UASAircam intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level ofsafety or greater level willbe 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 Aircamrequests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight inVFR conditions. Section 91.151 states:

16 See e.g., Grant ofExemptionNo. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are presentthat can sufficiently protect nonparticipatingpersons from the UA or debris in the event ofan accident, then the UAmay operate closer than 500 feet to persons afforded suchprotection. The operatormust also ensure that nonparticipatingpersons 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 notpresent an undue hazard." 17 Ifthe height ofthe structure being inspectedexceeds 400 feet AGL, the UAS will notbe operated more than 100 feet above the highest point on the structure. 18 See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation November 17, 2015 Page 19 (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (1) Duringthe day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Here, the technological limitations onUAS battery power means that no meaningful flight operations can be 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, it is not Aircam's intention to fly theAC-UASs at night. EquivalentLevelof Safety In the Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAAdetermined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions could be achieved by prohibiting the PIC from beginning a AC-UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intended point oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAAconsideredthat the UAS batteries for theAC-UAS provide approximately 50 minutes ofpowered flight (withpayload) and providedbattery level and battery time remaining inminutes and seconds to the PIC. 19 The FAA also considered the fact the AC-UAS operating manual states: "start every flight with a fully charged battery inthe aerial vehicle", and that inthe event thatthe AC-UAS should run low on power, the PIC will be alerted and can safely land the- AC-UAS as soon as possible. Like the VDOS Grant ofExemption, Aircam's use oftheAC-UAS, combined with the requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety canbe achieved and in fact exceeded. Similarly, inthe Grant ofExemptionto Alan Purwin (ExemptionNo. 11161), the FAA detetmined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions could be achieved by prohibiting the PIC from beginning a flight with the UAunless (considering wind and forecast weather conditions), there was enoughpowerto safely fly at normal cruising speed to the intended landing point and land the UAwith 25% battery power remaining. Ait·cam will adhere to this limitation for its AC-UAS flights. TheAC-UAS includes a lowbattery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from theAC-UAS to a ground-based-on-screen display. 20 As required by Aircam's Operations Manuals, the PIC will promptly fly theAC-UAS backto the home launch location or predetermined abort location where it may safely land, while still maintaining a minimum of25%

19

. Grant ofExemptionNo. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20

. TheAC-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 Depmiment ofTransportation November 17, 2015 Page 20

reserve battery power. Aircam submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and withinVLOS ofthe PIC and Observer(s), ensure that the proposed operation will provide an equivalent or higher level ofsafety to the public to that provided by the regulations from which exemption is sought. 

### VI. DRUGAND ALCOHOLPROGRAM Aircam will have policies inplace to ensure that no person may participate inAC-UASs flight operations ifthey are under the influence ofalcohol or any dmg. 

### VII. PUBLIC INTEREST The public interest will be served by grantingAircam'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 in this Petition. Granting this Petition for Exemptionhelps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-theFAAAdministrator's assessment ofwhether certain UAS may operate safely in the NAS before completion ofthe statutorily required mlemaking. The proposedAC-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 propetiies, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be in the local vicinity. Traditional methods ofinspecting and monitoring potential locations and relevant sites and facilities requires locationpersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perfotm elevated work for which the individual is neither trained nor equipped to perform, which exposes them to unnecessary risk ofserious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposedto hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifying specific locations for potential recording sites to be used inthe endproduct. The use ofsmall UASs can eliminate these hazards and ultimately create a much safer method of perfotming these types ofinspections creating a safer environment for the public as well as Aircam employees. The use ofsmall UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, canying crewin addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthetmore, inthe unlikely event of an accident, Aircam's small battery poweredAC-UAS presents significantly less danger to persons on the ground when compared to operations by conventional manned aircraft.21 As

21 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Mannedhelicopters 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 onboardpilot 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 onboardpilot and crew during an incident or accident is eliminated with the use ofa UAfor the aerial filmingU.S Department ofTranspotiation November 17,2015 Page 21 Petitioner'sAC-UAS are battery powered, the public will also benefit from a reduction in harmful petroleum based 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 bythe FAAinprior Section 333 Grants ofExemption to filmmakers, UASs provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the cunent capabilities offered by manned aircraft.22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the cunentUAS industry and provide additionaljobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the cunentindustrial product is increasing and will continue to increase giventhe enhanced flexibility ofproduction; therefore, given the lower cost, owner/operators and others in the relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All AC-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted over private or controlled-access property withpermission 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 FEDERALREGISTER, should itbe determined that publication is needed: Petitioner seeks an exemptionfrom the following mles 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)(1); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemption will enhance safety byreducing risk to the aircraft crew, production crew, general public, propetiy owners and city stmctures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or other methods. 

### X. CONCLUSION Ait·cam's Petition for Exemption satisfies the criteria miiculated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airpmis and

operation." 22 See e.g., Grant ofExemptionNo. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation November 17,2015 Page 22 populated areas; operation withinVLOS and national security. The proposedAC-UAS operations will benefit the public as a whole by improving safety and reducing risk by 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 FAA with more than adequatejustification for granting the requested exemptions allowingAircam to use smallAC-UAS sinthe recorded production ofits product. We thank you for your p 1

### /mpt consideration ofourrequested exemptions. 

# Resryny Submit!

# d 

# /1**~(JW/~** Thomas Glue Aircam360 7259 University Drive Moorpark, CA 93021 Phone: 805.338.3969 Email: thomas@aircam360.com (The following attached items containproprietary and commercial information exempt from disclosure under the Freedom ofInformationAct, 5 U.S.C. § 522 et seq., and should beheld in a separate file pursuant to 14 C.P.R.§ 11.35(b)). Attachments: 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. Post Flight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals