Triumphal	Bridges	|	AF400 1

FROM: Triumphal	Bridges | Aerial	Films	400,	LLC | 236	S	Broadway	St. Ridgecrest,	CA	93555
Tel: 601.951.1372 Email: aerialfilms400@gmail.com
TO:
DOCKET	OPERATIONS ROOM	W12

- 140	OF	THE	WEST	BUILDING GROUND	FLOOR 1200	NEW	JERSEY	AVENUE,	SE.	WASHINGTON,	DC, 20590

Regulatory	Docket	No.

PETITION	FOR	EXEMPTION	OF: Aerial	Films	400,	LLC	hereinafter	referred	to	as	AF400 FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF TITLE	14	OF	THE	CODE	OF	FEDERAL	REGULATIONS PART	21, SUBPART	H	AND	SECTIONS	§§	6 1.113(a)	&	(b),	91.109,	91.7(a),	91.121, 91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	AND 91.417(a)	&	(b)	CONCERNING	COMMERCIAL OPERATION	OF THE DRONES UNMANNED	AIRCRAFT	SYSTEMS PURSUANT	TO	SECTION 333	OF THE	FAA	MODERNIZATION	AND	REFORM	ACT OF 2012 (PUBLIC	LAW	112

- 95)
Submitted	on October	18,	2015Triumphal	Bridges	|	AF400 2

**Table of Contents**

**GLOSSARY	OF	ABBREVIATIONS**

**................................ ................................**  **........................... 3**  **SUMMARY**

**................................ ................................**  **................................ ................................**  **.... 4**  **INTRODUCTION	AND	INTERESTS**

**................................ ................................**  **........................ 5**  **BASIS	FOR	PETITION**

**................................ ................................**  **................................ ...............**  **5 A.	Name	And	Address	Of	The	Petitioner.** 

**................................ ................................**  **.................... 7**  **B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	AF400	Seeks	Exemption.**

**.................. 7**  **C.	The	Extent	Of	Relief AF400	Seeks	And	The	Reason	AF400	Seeks	The	Relief.** 

**....... 10**  **D.	Public	Interest	Benefits**

**................................ ................................**  **................................ ............**  **13 E.	The	Reasons	Why	Granting	The	Exemption	Would	Not	Adversely	Affect	Safety,	Or**  **How	The	Exemption	Would	Provide A	Level	Of	Safety	At	Least	Equal	To	That**  **Provided	By	The	Rule	From	Which	AF400	Seeks	Exemption.**

**................................ .........**  **15 F.	A	Summary	That	Can	Be	Published	In	The	Federal	Register,	stating:	The	Rules**  **From	Which	AF400	Seeks	Exemption: AF400	seeks**  **exemption	from	the requirements	of	14	C.F.R	Sections** 

**................................ ................................**  **............................. 27**  **G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support	UAV Aerial	Video	Request.** 

**................................ ................................**  **................................ .....................**  **27 CONCLUSION** 

**................................ ................................**  **................................ ............................**  **28 APPENDICES** 

**................................ ................................**  **................................ ................................**  **...... 29**  **Appendix A Summary	for	Federal	Register	Publication** 

**................................ ....................**  **29 APPENDIX**  **B:	Specific	Types	of	UAS	and	Their	Respective	Manuals**

**.............................. 30** Triumphal	Bridges	|	AF400 3 **GLOSSARY	OF	ABBREVIATI ONS**  Above	Ground	Level	Area	of	Interest Air	Traffic	ControlAir	Traffic Organization	Aerial	Vehicle Code	of	Federal	Regulations	Certificate	of	Authorization	Federal Aviation	Administration	Federal	Aviation	Regulation	Ground	Control Station
Global	Positio ning	System	Loss	of	Link National	Airspace	System Notice	to	Airman
Pilot	In	Command FAA	Modernization	and	Reform	Act	of	2012	(FMRA) Section	333	Safety	Observer Standard	Operating Procedures Unmanned	AircraftUnmanned	Aircraft	SystemVisual Flight	Rules Vi sual	Line	of	Site Visual	Meteorological Conditions Vertical	Takeoff	and	LandingTriumphal	Bridges	|	AF400 4 **SUMMARY** AF400 (Triumphal	Bridges)	seeks	exemption	from	the	requirements	of 14	C.F.R	§§	61.113(a)	&	(b),	91.109,	91.7(a),	91.121,	91.151(b), 91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)	(2),	and	91.417(a)	&	(b),	to operate	an	Unmanned	Aircraft	System	pursuant	to	Section	333	of	the FAA	Modernization	and	Reform	Act	of	2012	(FMRA). This	exemption	will	permit AF400 to	operate	an	Unmanned	Aircraft System	(UAS)	for	the	commercial	p urpose	of	conducting	aerial	video and	photography	of	Real	Estate	Properties	(for	homeowners,	realtors, home	builders,	home	contractors	and	/	or	home	inspectors	for	real estate	marketing	and	inspection	of	home	exteriors)	as	well	as	filming	of special	events,	film	sets,	scripted	and	unscripted	television	sets	and landscape,	conducting	power	line	inspection,	aerial	mapping,	surveying and	search	and	rescue	over	certain	areas	of	the	United	States.Triumphal	Bridges	|	AF400 5 **INTRODUCTION	AND	INTERESTS** AF400 is	a	production	company	based in California specializing	in	real estate, cinematography,	photography,	music	video	production,	special event	production	and	film	and	television	production. AF400 ’s	objective is	to	conduct	aerial	photography	and cinematography in	order	to provide	high	quality	digital	imaging	and	video	content	to	its	clients,	in particular	to	homeowners, real	estate	agents,	realtors,	home	builders, home	contractors,	and/or	home	inspectors	for	real	estate	marketing and	inspections	of	home	exteriors	as	well	as	filming	of	special	events, film	sets,	scripted	and	unscripted	television	sets	and	landscape, conducting	power	line	inspection,	aerial	mapping,	surveying	and	search and	rescue	utilizing the following	UAS’s	that	has already	bee n	granted exemption	by	the	FAA: DJI	Phantom	2 ,	DJI	Phantom	3,	DJI	Inspire	,	DJI S1000,	3D	Robotics	IRIS+,	3D	Robotics	Solo,	3D	Robotics	X8+,	and	3D Robotics	X8

- M UAS ;	hereinafter	referred	to	as	The	Drones

. More specifically, AF400 aerial	video	and	photography	operations	will	serve in	the	following	areas:

• Aerial	photography and	cinematography of	houses	/	residential	and commercial	buildings	and	power	lines

• Aerial	event	photography and	filming. •	Aerial	Film	&	Television	production •	Aerial	search	and	rescue	and	safety	inspections • Increase	pub lic knowledge	of	UAS	and	promote	safe	UAS	operations. A	FAA	commercial	pilot	license	holder	will	conduct	the	proposed	aerial filming

.

**BASIS	FOR	PETITION** Petitioner, AF400 ,	pursuant	to	the	provisions	of	the Federal	AviationTriumphal	Bridges	|	AF400 6

Regulations (14	C.F.R.	§	11. 61)	and	the FAA	Modernization	and	Reform Act	of	2012	(FMRA),	Section	333,	Special	Rules	for	Certain	Unmanned Aircraft	Systems,	hereby	petitions	the	Administrato r	to	commercially operate The	Drones in	the	National	Airspace	System	(NAS),	and	for	an exemption from	the	requirements	of	14	C.F.R	§§	61.113(a)	&	(b), 91.109,	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b). In	consideration	of	the	speed,	weight,	size,	and	limited	operating area associated	with	the	unm anned	aircraft	and	its	operation, AF400 operation	of		The	Drones meets	the	conditions	of	FMRA	Section	333	and therefore,	will	not	require	an	airworthiness	certificate	in	accordance with	14	C.F.R.	Part	21,	Subpart	H.	Accordingly, AF400 requests	relief from Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and 91.417(a)	&	(b),	as	these	sections	set	forth	requirements	for maintenance	that	only	apply	to	aircraft	with	an	airworthiness certificate. AF400 submits	that	the	requested	relief	is	proper	since	an equivalent level	of	safety	will	be	ensured. AF400 will	use	experienced personnel	or	technicians	to	perform	maintenance,	alterations,	or preventive	maintenance	on	the	UAS’s	using	the	methods,	techniques, and	practices	prescribed	in	the	operating	documents (i.e.,	Monthly Maintenance	Log, and	the The	Drones Instruction	Manual). Furthermore, AF400 will	document	and	maintain	all	maintenance records	for The	Drones

. Relief	from	certain	requirements	of	Section	61.113(a)	and	(b),	entitled Private	pilot	privileges and	limitations :	Pilot	In	Command,	is	requested by AF400 to	the	extent	necessary	to	allow	a	Pilot	in	Command	(PIC) holding	a Private Pilots	License (or	any	qualification	or	requirement deemed	acceptable	by	the	FAA) , and	who	has	demonstrated,	by meeting	minimum	flight

- hour	and	currency	requirements,	that	the	PIC is	able	to	safely	operate The	Drones in	a	manner	consistent	with	this exemption,	including	evasive	and	emergency	maneuvers	and maintaining	appropriate	distances	from	people,	vessels,	vehicles	and structures.
AF400 seeks	relief	from	Section	91.7(a),	entitled Civil	aircraft airworthiness,	because The	Drones do	not	require	an	airworthiness certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	As	such, AF 400 s ubmits	that	it	will	ensure	that	The Drones	are in	an	airworthyTriumphal	Bridges	|	AF400 7

condition,	prior	to	every	flight,	by	determining	that	the	UAS’s	are	in compliance	with	the	operating	documents (i.e.,	Monthly	Maintenance Log,	and The	Drones Instruction	Manual),	and	that the	aircraft	are	in	a condition	for	safe	flight. AF400 also	seeks	an	exemption	from	the requirements	of	Section 91.121,	entitled Altimeter	Settings,	as The Drones will	not	have	a	typical	barometric	altimeter	onboard.	However, altitude	information	of The	D rones will	be	provided	to	the	PIC	via	Global Positioning	System	(GPS)	equipment	and	radio	communications telemetry	data	link,	which	downlinks	from	the	UAS to	the	GCS	for	active monitoring	of	the	flight	path.	This	altitude information combined	with AF400 ’s operation	of The	Drones within	visual	line	of	sight,	at	or	below 200 (or	maximum	height	granted	by	the	FAA) feet	AGL (or	maximum height	granted	by	the	FAA) ,	will	ensure	a	level	of	safety	equivalent	to Section	91.121. Additionally, AF400 seeks	an	exemption from	the	requirements ofSection	91.151(b),	entitled Fuel	requirements for	flight	in	VFR conditions. AF400 submits	that	safety	will	not	be affected	by	operation of The Drones	during daylight	hours	in	visual	meteorological	conditions (VMC)	under	visual	flight	rules	(VFR), with	enough	battery	power	to	fly for	a	total	duration	of	approximately	13.5	minutes	to	the	first	point	of intended	landing	and,	assuming	normal	cruising	speed,	to	fly after	that for	at	least	4.5	minutes. In	accordance	with	14	C.F.R.	§	11.81, AF400 provid es	the	following information	in	support	of	its	petition	for	exemption: **A.	Name	And	Address	Of	The	Petitioner.** The	name	and	address	of	the	Petitioner	and	point	of	contact	is: Triumphal	Bridges | AF400 236	S	Broadway	St.	Ridgecrest,	CA	93555 Tel: 601.951 .1372 Email: aerialfilms400@gmail.com **B.	The	Specific	Sections	Of	14	C.F.R.	From	Which AF400**  **Seeks Exemption.**  1

. AF400 Seeks	Exemption	From	The	Requirements	Of	Section	91.7(a). Section	91.7,	entitled	Civil	aircraft	airworthiness,	subsection	(a),	states th e	following:Triumphal	Bridges	|	AF400 8

(a)	No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy condition.
2

. AF400 Seeks	Exemption	From	The	Requirements	Of	Section	91.121. Section	91.121,	entitled	Altimeter	settings,	subsection	(a),	states	the following,	in	part: (a)	Each	person	operating	an	aircraft	shall	maintain the	cruising	altitude	or	flight level	of	that	aircraft,	as	the	case	may	be, by	reference	to	an	altimeter	that	is	set,	when	operating

-- (1)	Below 18,000	feet	MSL,	to

-- (i)	The	current	reported	altimeter	setting	of	a station	along	the	route	and	within	100	nautical	miles	of	th e	aircraft; (ii) If	there	is	no	station	within	the	area	prescribed	in	paragraph	(a)(1)(i)	of this	section,	the	current	reported	altimeter	setting	of	an appropriate available	station;	or(iii)	In	the	case	of	an	aircraft	not equipped	with	a	radio,	the	elevation	of	the	departure	airport	or	an appropriate	altimeter	setting	available	before	departure.
3

. AF400 Seeks	Exemption	From	The	Requirements	Of	Section 91.151(b).	Section	91.151,	entitled	Fuel	requirements	for	flight	in	VFR conditions,	subsection	(b),	states	the	following: (b)	No	person	may begin	a	flight	in	a	rotorcraft	under	VFR	conditions	unless	(considering wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the first	point	of	intended	landing	and,	assuming	normal	cruising	speed,	to fly after	that	for	at	least	20	minutes.
4

. AF400 Seeks	Exemption	From	The	Requirement	Of Section 91.405(a).Section	91.405,	entitled	Maintenance	required, subsection	(a),	states	the	following:	Each	owner	or	operator	of	an aircraft

— (a)	Shall	have	that	aircraft	inspected	as	prescribed	in subpart	E	of	this	part	and	shall	between	required	inspections,	except	as provided	in	paragraph	(c)	of	this section,	have	discrepancies	repaired as	prescribed	in	part	43	of	this	chapter.
5

. AF400 Seeks	Exemption	From	The	Requirements	Of	Section 91.407(a)(1)	Section	91.407,	entitled	Operation	after	maintenance, preventive	maintenance,	rebuilding,	or	alteration,	subsection	(a)(1), states	the	following: (a)	No	person	may	operate	any	aircraft	that	has undergone	maintenance,	preventive	maintenance,	rebuilding,	or alteration	unless

-- (1)	It	has	been	approved	for	return	to	service	by	a	person	authorizedTriumphal	Bridges	|	AF400 9

under	§	43.7	of	this	chapter.
6

. AF400 Seeks	Exemption	From	The	Requirements	Of	Sections 91.409(a)(1)	And	91.409(a)(2). Section	91.40 9,	entitled	Inspections, subsection	(a),	states	the	following: (a)	Except	as	provided	in	paragraph	(c)	of	this	section,	no	person	may operate	an	aircraft	unless,	within	the	preceding	12	calendar	months,	it has	had

-- (1)	An	annual	inspection	in	accordanc e	with	part	43	of	this	chapter	and has	been	approved	for	return	to	service	by	a	person	authorized	by	§ 43.7	of	this	chapter;	or (2)	An	inspection	for	the	issuance	of	an	airworthiness	certificate	in accordance	with	part	21	of	this	chapter.
7

. AF400 Seeks Exemption	From	The	Requirements	Of	Sections 91.417(a)	And	91.417(b). Section	91.417,	entitled	Maintenance records,	subsections	(a)	and	(b),	state	the	following: (a)	Except	for	work	performed	in	accordance	with	§§	91.411	and 91.413,	each	registered	owner	o r	operator	shall	keep	the	following records	for	the	periods	specified	in	paragraph	(b)	of	this	section: (1) Records	of	the	maintenance,	preventive	maintenance,	and	alteration and	records	of	the	100

- hour,	annual,	progressive,	and	other	required	or approved inspections,	as	appropriate,	for	each	aircraft	(including	the airframe)	and	each	engine,	propeller,	rotor,	and	appliance	of	an	aircraft. The	records	must	include

-- (i)	A	description	(or	reference	to	data	acceptable	to	the	Administrator) of	the	work	performed;	and (ii) the date	of	completion	of	the	work performed;	and (iii) the signature,	and	certificate	number	of	the	person approving	the	aircraft	for	return	to	service. (2)	Records	containing	the	following	information: (i)	The	total	time	in service	of	the airframe,	each	engine,	each	propeller,	and	each	rotor. (ii) The	current	status	of	life

- limited	parts	of	each	airframe,	engine, propeller,	rotor,	and	appliance. (iii)	The	time	since	last	overhaul	of	all items	installed	on	the	aircraft	which	are	required	to be	overhauled	on	a specified	time	basis. (iv)	The	current	inspection	status	of	the	aircraft,Triumphal	Bridges	|	AF400 10

including	the	time	since	the	last	inspection	required	by	the	inspection program	under	which	the	aircraft	and	its	appliances	are maintained. (v)	The	current	status of	applicable	airworthiness directives	(AD)	and	safety	directives	including,	for	each,	the	method	of compliance,	the	AD	or safety	directive	number	and	revision	date.	If	the AD	or	safety	directive	involves	recurring	action,	the	time	and	date	when the	next	action	is	required.	(vi)	Copies	of	the	forms	prescribed	by	§ 43.9(d)	of	this	chapter	for	each	major	alteration	to	the	airframe	and currently	installed	engines,	rotors,	propellers,	and	appliances. (b)	The	owner	or	operator	shall	retain	the	following	records for	the periods	prescribed: (1)	The	records	specified	in	paragraph	(a)(1)	of	this	section	shall	be retained	until	the	work	is	repeated	or	superseded	by	other	work	or	for 1	year	after	the	work	is	performed. (2)	The	records	specified	in paragraph	(a)(2)	of	this	section	shall	be	retaine d	and	transferred	with the	aircraft	at	the	time	the	aircraft	is	sold. (3)	A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§ 43.11	of	this	chapter	shall	be	retained	until	the	defects	are	repaired	and the	aircraft	is	approved	for	return to	service. **C.	The	Extent	Of	Relief AF400**  **Seeks	And	The	Reason AF400**  **Seeks	The Relief.**  1.	Extent	Of	Relief and	the	Reasoning	that AF400 seeks	this	relief f rom Section	61.113(a)	And	(b). Relief	from	Section	61.113(a)	and	(b) entitled	Private	pilot	privileges	and	limitations:	Pilot	in	command,	is requested	to	the	extent	necessary	to	allow	a	PIC	holding	a	Supplemental Pilot	Certificate,	as	well	as	a	current	and valid	airman	medical certificate,	and	who	has	met	certain	flight

- hour	and	currency requirements,	to	conduct	the	proposed	UAS	flight	operations	for compensation	or	hire.	This	relief	is	requested	since	the	limitations	set forth	in	Section	61.113(a)	and	(b) state	that	a	private	pilot	may,	for compensation	or	hire,	act	as	PIC	of	an	aircraft	in	connection	with	any business	or	employment	if:	(1)	The	flight	is	only	incidental	to	that business	or	employment;	and	(2)	The	aircraft	does	not	carry	passengers or	property	for	compensation	or	hire. As	set	forth	more	fully	below, AF400 submits	that	an	equivalent	level	of	safety	will	be	maintained because	no	PIC will	be	allowed	to	operate The	Drones unless	that	PICTriumphal	Bridges	|	AF400 11

has	met	certain	flight

- hour	and	currency	requirements,	demo nstrating that	the	PIC	is	abl e to	safely	operate The	Drones in	a	manner	consistent with	the	operations specifications	as	described	in	this	exemption, including	evasive	and	emergency	maneuvers,	as	well	as	maintaining appropriate	distances	from	people,	vessels,	vehicles	and	structures. Further, AF400 s ubmits	that	all	flights	of The	Drones,	conducted	by	the PIC	pursuant	to	the	grant	of	this	Petition:	(1)	will	be	incidental	to AF400 business;	and	(2)	will	not	carry	passengers	or	property	for compensation	or	hire.
AF400 believes	that	though	UAS	are	not	traditional	aircrafts,	a	PIC operating	the	UA	must	have	knowledge	of	Airman	rules,	basic	Airspace and	comply	with	all	the	rules	proposed	by	the	FAA.	However, considering	the	fact	that	a	UA	is	almost	like	a	toy,	th e	PIC	may	be	except from	obtaining	a	Private	Pilot	Certificate,	a	Sports	Certificate,	a Recreational	Certificate	considering	these	certificates	require	flight hours	of	several	thousand	tons	weighing	aircrafts.	The	operation	of	UAS by AF400 is	strictly	for entertainment	/	informational	purposes,	thus the operators	of	the	UAS	have	a	career	and	/	or	freelance	employment as	a	Camera	Operator	and	Cinematographer	and	will	be	not	be entertaining	a	career	as	a	pilot.	Lastly, AF400 PICs	will	operate	the	UAS no	highe r	than	200	feet (or	maximum	height	granted	by	the	FAA) , consequently	causing	no	danger	do	any	other	aircraft	in	the	NAS. However, AF400 Proposes	PIC	Certification	as	a	Supplemental pilot	and a	minimum	requirement	of	successfully	completed	private	pilot	gro und school.	Additionally,	supplemental	pilots	certificate	must	have successfully	passed	the	private	pilot,	commercial	pilot,	or	airline transport	pilot	knowledge	test	within	the	past 24

- calendar months. 2. Extent	Of	Relief AF400 Seeks	And	The	Reason	UAV	Aerial Video	Seeks Relief	From	Section	91.7(a). Relief	from	Section	91.7(a)	entitled	Civil	aircraft	airworthiness,	is requested	to	the	extent	required	to	allow AF400 to	determine	that The Drones are	in	airworthy	condition prior	to	every	flight	by	ensuring	that the	UAS	is	in	compliance	with	the	operating	documents	(i.e.,	the AF400 Aerial	Operations	Manual,	Monthly	Maintenance	Log, and The	Drones Instruction	Manual). AF400 seeks	the	requested	relief because The Drones do	not	require	an	airworthiness	certificate	in	accordance	with 14 C.F.R.	Part	21,	Subpart	H.	Therefore, AF400 will	ensure	that	the UAS are	in	airworthy	condition	based	upon	its	compliance	with	theTriumphal	Bridges	|	AF400 12

operating	documents	(i.e.,	Monthly	Maintenance	Log, and The	Drones Instructio n	Manual)	prior	to every	flight,	and	further,	determine	that the	aircraft	are	in	condition	for	safe	flight,	as	stated	in	the	conditions and	limitations	below.
3.	Extent	Of	Relief AF400 Seeks	And	The	Reason	UAV	Aerial Video Seeks	Relief	From	Section	91.121

. Relief	from	Section	91.121,	entitled Altimeter	settings,	may	be	required	to allow	flight	operations	of The Drones,	which	utilize	a	barometric	pressure	sensor,	GPS	equipment,	and a	radio	communications	telemetry	data	link	to	downlink	altitude information from	the	UA	to	the	PIC	at	the	ground	control	station	(GCS). Since	the	FAA	requires	that	any	altitude	information	concerning	UAS operations	be	reported	to	air	traffic	control	(ATC)	in	feet	above	ground level	(AGL), AF400 seeks	the requested	relief	because The	Drones ’ altimeter	may	be	set	on	the	ground	to	zero	feet	AGL,	rather	than	the local	barometric	pressure	or	field	altitude,	before	each	flight. Considering	the	limited	altitude	of	the	proposed	operations,	relief	from 14	CFR	91.121	is	sought	to	the	extent necessary	to	comply	with	the applicable	conditions	and	limitations	stated	below.	As	more	fully	set forth	herein,	an	equivalent	level	of	safety	will	be	maintained	since The Drones equipped	with	a	barometric	pressure	sensor	and	GPS equipment,	which	automatically	ensures	that	a	ground	level	pressure setting	will	be	established	prior	to	each	flight,	and	provides	the	PIC	with altitude	information	of	the	UA	on	the	heads

- up	display	of	the	GCS.
4.	Extent	Of	Relief AF400 Seeks	And	The	Reason	UAV	Aerial Video Seeks Relief	From	Section	91.151(b). Relief	from	Section	91.151(b) entitled	Fuel	requirements	for	flight	in	VFR	conditions,	is	requested	to the	extent	required	to	allow	flights	of	the	battery	powered The	Drones UAS	during	daylight	hours	in	visual	meteorological conditions	(VMC), under	visual	flight	rules	(VFR),	for	a	total	duration	of	13.5	minutes	to the	first	point	of	intended	landing	and,	assuming	normal	cruising	speed, to	fly	after	that	for	at	least	4.5	minutes. AF400 seeks	the	requested	relief because	without an	exemption	from	Section	91.151(b),	the	flight	time duration	of	the	battery	powered The	Drones will	severely	constrain	the practicality	of	any	aerial	video	or	still	photo	flight	operations	that AF400 proposes	to	conduct	pursuant	to	this	Petition. Significantly,	as	set	forth below,	the	technical	specifications	of The	Drones UAS	operating documents,	and AF400 proposed	operating	limitations,	ensure	that AF400 will	safely	operate the	battery	powered	UAS	d uring	daylightTriumphal	Bridges	|	AF400 13

hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight rules	(VFR),	with	enough	battery	power	to	fly	for	a	total	duration	of	13.5 minutes	to	the	first	point	of	intended	landing	and,	assuming	normal cruising	speed,	to	fly	after that	for	at	least	4.5	minutes.
5.	Extent	Of	Relief AF400 Seeks	And	The	Reason AF400 Seeks	Relief From	Section	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And 91.417(a)	&	(b). Since	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1) &	(a)(2),	and	91.417(a) &	(b)	only	apply	to	aircraft	with	an airworthiness	certificate, AF400 requests	relief	from	these	Sections because The	Drones do	not	require	airworthiness	certificates.	As	set forth	more	fully	below, The	Drones meet	the	conditions	of	FMRA	Section 333	for	o peration	without	an	airworthiness	certificate.	Accordingly, AF400 will	use	trained	technicians	to	perform	maintenance,	alterations, or	preventive	maintenance	on	the	UAS	using	the	methods,	techniques, and	practices	prescribed	in	the	UAS	operating	documents (i.e.,	the AF400 Aerial	Operations	Manual,	Monthly	Maintenance	Log,	and The Drones Instruction	Manual).	Furthermore, AF400 will	document	and maintain	all	maintenance	records	for The	Drones

. **D. Public	Interest	Benefits** 
Granting	the	present	Petition	will	fu rther	the	public	interest	by	allowing AF400 to	safely,	efficiently,	and	economically	perform	aerial	video	and photography	of	real	estate,	special	events,	film	sets,	and	landscape	over certain	areas	of	the	United	States. Additionally,	use	of The	Drones wil l	decrease	congestion	of	the	NAS, reduce	pollution,	and	provide	significant	benefits	to	the	economy. Notably,	the	benefits	of AF400 ’s	proposed	operation	of The	Drones will be	realized	without	implicating	any	privacy	issues.
1.	The	Public	Will	Benefit	From Decreased	Congestion	Of	The	NAS.
The	Drones are	battery	powered	and	serve	as	a	safe,	efficient,	and economical	alternative	to	the	manned	aircraft	traditionally	utilized	to obtain	aerial	imagery.	By	reducing	the	amount	of	manned	aircraft needed	to	perform aerial	acquisitions,	an	exemption	allowing	the	use	of
a The	Drones UAS	would	reduce	the	amount	of	manned	aircraft	in	the NAS,	reduce	noise	and	air	pollution,	as	well	as	increase	the	safety	of	life and	property	in	the	air	and	on	the	ground.Triumphal	Bridges	|	AF400 14

Furthermore,	by	reducing	the	number	of	manned	aircraft	operating	in the	NAS,	congestion	around	airports	caused	by	arriving	and	departing aircraft	will	be	reduced. The	Drones do	not	require	an	airport	to	takeoff or	land.	Likewise,	a	reduction	of	manned	aircraft	conducting	aerial video	and	photography	missions	would	result	in	fewer	aircraft	that must	be	handled	by	air	traffic	control	during	the	ground,	takeoff, departure,	arrival,	and	landing	phases	of	flight	operations. 2.	The	Public	Will	Benefit	From	The	Safety	And	Effi ciency	Of The Drones

. Conducting	aerial	acquisitions	with The	Drones,	instead	of manned	aircraft,	will	greatly	benefit	the	public	by	drastically	reducing the	levels	of	air	and	noise	pollution	generated	during	traditional	aerial video	and	still	photography flight	operations.	By	using	battery	power and	electric	motors, The	Drones produce	no	air	pollution,	and	is	the most	viable	environmentally	conscious	alternative	to	the	cabin	class,	six cylinder	internal	combustion	engine	aircraft	that	are	typically	utilize d for	aerial	video	and	photography,	while	burning	approximately	20

- 30 gallons	per	hour	of	leaded	aviation	fuel. The	Drones,	while	reducing	the carbon	footprint	of	aerial	acquisitions,	also	eliminates	noise	pollution, as	the	UAS	are	propelled	by	battery	powered	electric	motors,	rather than	an	internal	combustion	engine.	By	using The	Drones to	perform aerial	acquisitions,	the	substantial	risk	to	life	and	property	in	the	air	and on	the	ground,	which	is	usually	associated	with	traditional	manned aircraft	flight operations,	will	be	substantially	reduced	or	completely eliminated.	Aside	from	the	lack	of	flight	crew	members	located	onboard the	aircraft, The	Drones has	less	physical	potential	for	collateral	damage to	life	and	property	on	the	ground,	and	in	the	air,	c ompared	to	the manned	aircraft	that	typically	conduct	similar	operations	(weighing approximately	6,000	pounds	with	a	wingspan	of	approximately	42	feet, a	length	of	34	feet,	and	a	fuel	capacity	of	180	gallons). 3.	Performing	Aerial	Video	and	Photography	Op erations	With The Drones Will	Benefit	The	Economy. In	addition	to	being	safe	and efficient, The	Drones is	also	an	economical	alternative	to	using	manned aircraft	to	conduct	similar	aerial	operations.	As	such,	operation	of The Drones will	allow	United	States	based	companies,	like AF400 ,	to	remain competitive	and	contribute	to	growth	of	the	U.S. economy.	Specifically, with	the	rising	cost	of	aviation	fuel	and	the	Environmental	Protection Agency	(“EPA”)	regulatory	actions	phasing	out	leaded	aviation	fuels,	U.S. owned	and	operated	companies	must	adopt	new	and	alternativeTriumphal	Bridges	|	AF400 15

technology in	order	to	remain	competitive.	Operating	the	battery powered The	Drones UAS	is	one	such	technology	that	not	only	allows companies	greater	operational	flexibility	compared	to	manned	aircraft, but	provides	su ch	flexibility	without	the	high	operational	cost	of	a traditional	manned	aircraft.	By	operating The	Drones,	companies	such
as AF400 ,	can	remain	competitive	and	profitable, and	therefore, provide	greater	job	stability	to	employees	and	contractors,	which	wil l ultimately	contribute	to	growth	of	the	U.S.	economy.	Improved	financial performance	of	U.S.	companies,	through	commercial	use	of The	Drones, provides	a	stable	workforce	that	increases	consumer	spending; improves	local,	state,	and	federal	tax	revenues;	an d	allows	companies	to invest	in	research	and	development	in	order	to	remain	competitive	both in	the	United	States	and	abroad. 4.	There	Are	No	Privacy	Issues. Similar	to	the	manned	aerial acquisition	flight	operations	that	have	been	conducted	for decades; AF400 proposed	operation	of The	Drones will	not	implicate	any	privacy issues.	Specifically, The	Drones will	be	operated	only	in	compliance	with operating	documents	(i.e.,	the AF400 Aerial	Operations	Manual,	Monthly Maintenance	Log,	and The	Drones Instructi on	Manual),	which require property	owner	involvement	as	well	as	local	law	enforcement notification,	and	in	accordance	with	the	Federal	Aviation	Regulations, including	the	minimum	altitude	requirements	of	14	C.F.R.	§	91.119. **E.	The	Reasons	Why	Granting	The Exemption	Would	Not	Adversely**  **Affect	Safety,	Or	How	The	Exemption	Would	Provide	A	Level	Of	Safety At	Least	Equal	To	That	Provided	By	The	Rule	From	Which**  **AF400 Seeks	Exemption.**  1.	Reasons	Why The	Drones Meet	The	Conditions	Of	The	FAA Modernization	and	Ref

orm	Act	of	2012	(FMRA)	Section	333. In consideration	of	the	size,	weight,	speed,	and	limited	operating	area associated with	the	unmanned	aircraft	and	its	operation, AF400 operation	of The	Drones meet	the	conditions	of	FMRA	Section	333,	and will	not	require an	airworthiness	certificate	in	accordance	with	14	C.F.R. Part	21,	Subpart	H.	Section	333	provides	authority	for	a	UAS	to	operate without	airworthiness certification	and	sets	forth	requirements	for considering	whether	a	UAS	will	create	a	hazard	to	users	o f	the	NAS	or the	public,	or	otherwise	pose	a	threat	to	national	security. Specifically, FMRA	Section	333	states	the	following,	in	part: (a)	In	General.

--Triumphal	Bridges	|	AF400 16

Notwithstanding	any	other	requirement	of	this	subtitle,	and	not	later than	180	days	after	the	date	of	e nactment	of	this	Act,	the	Secretary	of Transportation	shall	determine	if	certain	unmanned	aircraft	systems may	operate	safely	in	the	national	airspace	system	before	completion	of the	plan and	rule

- making	required	by	section	332	of	this	Act	or	the guidance required	by	section	334	of	this	Act. (b)	Assessment	of Unmanned	Aircraft	Systems.

-- In	making	the	determination	under subsection	(a),	the	Secretary	shall	determine,	at	a	minimum

-- (1) Which types	of	unmanned	aircraft	systems,	if	any,	as	a	result	of	their
s ize,	weight,	speed,	operational	capability,	proximity	to	airports	and populated	areas,	and	operation	within	visual	line	of	sight	do	not	create	a hazard	to	users	of	the	national	airspace	system	or	the	public	or	pose	a threat	to	national	security;	and (2) Whether a	certificate	of	waiver,	certificate	of	authorization,	or airworthiness	certification	under	section	44704	of	title	49,	United	States Code,	is	required	for	the	operation	of	unmanned	aircraft	systems identified	under	paragraph	(1). (c)	Requirements	f

or	Safe	Operation

. - - If	the	Secretary	determines under	this	section	that	certain	unmanned	aircraft	systems	may	operate safely	in	the	national	airspace	system,	the	Secretary	shall	establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the national	airspace	system. In	seeking	this	exemption, AF400 submits	that The	Drones can	operate safely	in	the	NAS	pursuant	to	FMRA	Section	333,	as	demonstrated	by: (a)	the	characteristics	of The	Drones UAS; (b)	The pilot	certification	requirement and	(c) the	specific	operating limitations. a.	The	Specifications	Of The	Drones Demonstrate	Its	Safe Characteristics.
The	Drones does	not	create	a	hazard	to	users	of	the	NAS	or	the	public,	or otherwise	pose	a	threat	to	national	security	considering	its	size,	we ight, speed,	and	operational	capability. i.	Technical	Specifications	Of The	Drones UAS

. The	technicalTriumphal	Bridges	|	AF400 17

specifications	of The	Drones is	set	forth	by The	Drones Specifications found in	their	respective	manuals	attached

. ii.	The Drones Autonomous	Flight	And	Navigation	Modes	Enable	The UAS	To	Remain	Within	A	Defined	Operational	Area. The	Drone s may	be operated	in	both	manual	and	fully	autonomous	flight	modes.	A	complete description	of	the	flight	and	navigational	modes	of The	Drones is provided in	the	Appendices,	attached	hereto	as

iii. The	Drones Designed	For	Automatic	Return	To	Home	Point	Or Hover In	The	Event	Of	Loss	Of	The	Control	Link	Or	Navigation.	When	the Control	Link	is	lost,	the		UA	will	remains	stationary,	in	flight,	for	3 seconds	or more.	If,	after	3	seconds, The	Drones does	not	reacquire control	link	data	from	the	GCS,	the	UA	will	a ssume	that	the	Control	Link is	lost	and	the	UA	will	return	to	the	home	position	(i.e.,	failsafe	mode) via	GPS,	and	will	descend	to	the	takeoff	position	and	shutdown.	A complete	description	o f	the	Failsafe	Functions	of	The	Drones	are	located in	their	respective	attached	manuals.

iv. The	Drones GCS	And	Its	Operation

. A	complete	description	of	the operation	and	specifications	of The	Drones GCS and	flight	control software	can	be	found	in	their	respective	appendices b.	Flight Operations	O f The	Drones UAS	Are	Limited	To	The	Line	Of	Sight	Of	A Certificated	Pilot	in	Command	With	A	Safety	Observer

. AF400 will	only utilize	certificated	pilots	who	possess	a	current	and	valid	airman medical	certificate	to	act	as	a	pilot	in	command	(PIC)	of The	Drones UAS. Additionally,	a	safety	observer	will	assist	all	pilots	during	flight	ti me. c.	Flights	Of The	Drones UAS	Will	Be	Conducted	Pursuant	To	Specific Operating	Limitations. In	seeking	this	exemption,	proposes	to commercially	operate The	Drones UAS	for	the	special	purpose	of conducting	aerial	video	and	photography	over	certain	areas of	United States,	pursuant	to	the	following	specific	operating	limitations: 1.	Operations	authorized	by	this	grant	of	exemption	will	be	limited	to the	following	aircraft	described	in	the	operating	documents,	rotorcraft UASs	weighing	less	than	55	pounds	m aximum	gross	weight: The	Drones Unmanned	Aircraft	System.	Proposed	operations	of	any	other	aircraft will	require	a	new	petition	or a	petition	to	amend	this	grant. 2.	UAS	operations	under	this	exemption	will	be	limited	to	conductingTriumphal	Bridges	|	AF400 18

operations	for	the	purp ose	of	aerial	video	and	photography	for homeowners,	Realtors,	home	builders,	contractors,	home	inspectors	for use	in	real	estate	marketing	and	real	estate	inspections.	Additionally, aerial	video	and	photography	may	be	conducted	on	occasional	basis	for film and	television	sets,	special	events	and	landscape	photography, conducting	power	line	inspection,	aerial	mapping,	surveying	as	deemed necessary. 3.	The	UAS	may	not	be	flown	at	an	indicated	airspeed	exceeding	29 knots	(15	m/s). 4.	The	UAS	must	be	operated at	an	altitude	of	no	more	than 200 feet (500	per	the	User	Manual)	above	ground	level	(AGL),	as	indicated	by	the procedures	specified	in	the	operating	documents	unless	a	special request	is	made	and	approved	by	ATC.	All	altitudes	reported	to	ATC must	be	in feet	AGL. 5.	The	UAS	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC at	all	times.	This	requires	the	PIC	to	be	able	to	use	human	vision unaided	by	any	device	other	than	corrective	lenses,	as	specified	on	the PIC’s	FAA

- issued	airman	medical certificate. 6.	The	use	of	first	person	view	(FPV)	by	the	PIC	or	safety	observer	(SO) is	not	permitted. 7.	All	operations	must	utilize	a	safety	observer	(SO).	The	SO	may	be	used to	satisfy	the	VLOS	requirement	as	long	as	the	PIC	always	maintains VLOS	cap ability. The	SO	and	PIC	must	be	able	to	communicate	verbally at	all	times.	Electronic	messaging	or	texting	is	not	permitted	during flight	operations.	The	PIC	must	be	designated	before	the	flight	and cannot	transfer	his	or	her	designation	for	the	duration	o f	the	flight.	The PIC	must	ensure	that	the	SO	can	perform	the functions	prescribed	in	the operating	documents. 8.	The	SO	must	not	perform	any	other	duties	beyond	assisting	the	PIC with	seeing	and	avoiding	other	air	traffic	and	other	ground	based obstacles /obstructions	and is	not	permitted	to	operate	the	camera	or other	instruments. 9.	The	operating	documents	and	the	grant	of	exemption	must	be accessible	during	UAS	operations	and	made	available	to	theTriumphal	Bridges	|	AF400 19

Administrator	upon	request.	If	a	discrepancy	exists	between	the conditions	and	limitations	contained	in	the	grant	of	exemption	and	the procedures	outlined	in	the	operating	documents,	the	conditions	and limitations	contained	in	the	grant	of	exemption	take	precedence	and must	be	followed.	Otherwise,	the	operator must	follow	the	procedures as	outlined	in	its	operating	documents.	The	operator	may	update	or revise	its	operating	documents.	It	is	the	operator’s	responsibility	to track	such	revisions	and	present	updated	and	revised	documents	to	the Administrator	upon	request.	The	operator	must	also	present	updated and	revised	documents	if	it	petitions	for	extension	or	amendment	to	the grant	of	exemption.	If	the	operator	determines	that	any	update	or revision	would	affect	the	basis	upon	which	the	FAA	granted	the exemptio n,	then	the	operator	must	petition	for	amendment	to	its	grant of	exemption.	The	FAA’s	UAS	Integration	Office	(AFS

- 80)	may	be contacted	if	questions	arise	regarding	updates	or	revisions	to	the operating	documents. 10.	Prior	to	each	flight	the	PIC	must	insp ect	the	UAS	to	ensure	that	it	is in	a	condition	for	safe	flight.	If	the	inspection	reveals	a	condition	that affects	the safe	operation	of	the	UAS,	the	aircraft	is	prohibited	from operating	until	the	necessary	maintenance	has	been	performed	and	the UAS	is	f ound	to	be	in	a condition	for	safe	flight.	The	Ground	Control Station	must	be	included	in	the	preflight	inspection.	All	maintenance and	alterations	must	be	properly	documented	in	the	aircraft	records. 11.	Any	UAS	that	has	undergone	maintenance	or	alterati ons	that	affect the	UAS	operation	or	flight	characteristics,	e.g.	replacement	of	a	flight critical	component,	must	undergo	a	functional	test	flight.	The	PIC	who conducts	the	functional	test	flight	must	make	an	entry	in	the	aircraft records. 12.	The	pre

- fl ight	inspection	must	account	for	all	potential discrepancies,	e.g.	inoperable	components,	items,	or	equipment,	not already	covered	in	the	relevant	sections	of	the	operating	documents. 13.	The	operator	must	follow	the	UAS	manufacturer’s aircraft/component, maintenance,	overhaul,	replacement,	inspection, and	life	limit	requirements. 14.	The	operator	must	carry	out	its	maintenance,	inspections,	andTriumphal	Bridges	|	AF400 20

record	keeping	requirements,	in	accordance	with	the	operating documents.	Maintenance,	inspection,	alterations, and	status	of replacement/overhaul	component	parts must	be noted	in	the	aircraft records,	including	total	time	in	service,	description	of	work accomplished,	and	the	signature	of	the	authorized	person	returning	the UAS	to	service. 15.	Each	UAS	operated	under	this	exemption	must	comp ly	with	all manufacturer	Safety	Bulletins. 16.	The	authorized	person	must	make	an	entry	in	the	aircraft	record	of the	corrective	action	taken	against	discrepancies	discovered	between inspections. 17.	The	PIC	must	possess	at	least	a Supplemental Pilot	certificate	and	at least	a	current	third

- class	medical	certificate.	Supplemental	pilots	must have,	at	a	minimum,	successfully	completed	private	pilot	ground	school. Additionally,	supplemental	pilots	without	a	current	FAA	private	pilot certificate	must	have	s uccessfully	passed	the	private	pilot,	commercial pilot,	or	airline	transport	pilot	knowledge	test	within	the	past	24 calendar	months. 18.	The	operator	may	not	permit	any	PIC	to	operate	unless	the	PIC meets	the	operator’s	qualification	criteria	and	demonstrates	the	ability to	safely	operate	the	UAS	in	a	manner	consistent	with	how	the	UAS	will be	operated	under	the	exemption,	including	evasive	and	emergency maneuvers	and	maintaining	appropriate	distances	from	persons, vessels,	vehicles	and	structures.	PIC	qu alification	flight	hours	must	be logged	in	a	manner	consistent	with	14	C.F.R.	§	61.51(b).	Flights	for	the purposes	of	training	the	operator’s	PICs	are	permitted	under	the	terms of	the	exemption.	However,	training	operations	may	only	be	conducted during	dedicated	training	sessions.	During	training,	proficiency,	and experience

- building	flights,	all	persons	not	essential	for	flight operations	are	considered	nonparticipants,	and	the	PIC	must	operate the	UA	with	appropriate	distance	from	nonparticipants	in	accordance with	14	C.F.R.	§	91.119. 19.	UAS	operations	may	not	be	conducted	during	night,	as	defined	in	14 C.F.R.	§ 1.1.	All	operations	must	be	conducted	under	visual meteorological	conditions	(VMC).	If	flight	at	night	is	required,	a	specialTriumphal	Bridges	|	AF400 21

request	will	be	ma de	at	the	FAA	office	closest	to	proposed	area	of operations.	Flights	under	special	visual	flight rules	(SVFR)	are	not authorized. 20.	The	UA	may	not	operate	within	5	nautical	miles	of	an	airport reference	point	as	denoted	on	a	current	FAA

- published	aeronautical chart	unless	a	letter	ofagreement	with	that	airport’s	management	is obtained,	and	the	operation	is	conducted	in	accordance	with	a	NOTAM as	required	by	the	operator’s	COA. The	letter	of	agreement	with	the	airport	management	must	be	made available	to	the	Administrator	upon	request. 21.	The	UA	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.
22.	If	the	UA	loses	communications	or	loses	its	GPS signal,	it	must	return to	a	predetermined	location	within	the	planned	operating	area	and	land or	be	recovered in	accordance	with	the	operating	documents. 23.	The	PIC	must	abort	the	flight	in	the	event	of	unpredicted	obstacles or	emergencies	in	accordance with	the	operating	documents. 24.	The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering wind	and	forecast	weather	conditions)	there	is	enough	power	to	fly	at normal	cruising	speed	to	the	intended	landing	point	and	land	the	UA with	25%	battery power	remaining. 25.	The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued Certificate	of	Waiver	or	Authorization	(COA)	prior	to	conducting	any operations	under	the	grant	of	exemption.	This	COA	will	also	require	the operator	to	request	a	Notic e to	Airman	(NOTAM)	not	more	than	72 hours	in	advance,	but	not	less	than	48	hours	prior	to	the	operation.	All operations	shall	be	conducted	in	accordance with	airspace requirements	in	the	ATO	issued	COA	including	class	of	airspace,	altitude level	and	potential	transponder	requirements. 26.	All	aircraft	operated	in	accordance	with	the	exemption	must	be identified	by	serial	number,	registered	in	accordance	with	14	C.F.R.	part 47,	and	have	identification	(N

- Number)	markings	in	accordance	withTriumphal	Bridges	|	AF400 22

14	C.F.R.	part 45,	Subpart	C.	Markings	must	be	as	large	as	practicable. 27.	Before	conducting	operations,	the	radio	frequency	spectrum	used for	operation	and	control	of	the	UA	must	comply	with	the	Federal Communications	Commission	(FCC)	or	other	appropriate government
oversight	agency	requirements. 28.	The	documents	required	fewer	than	14	C.F.R.	91.9	and	91.203	must be	available	to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time the	UAS	is	operating.	These	documents	must	be	made	available	to	the Administrator or	any	law	enforcement	official	upon	request. 29.	The	UAS	must	remain	clear	and	yield	the	right	of	way	to	all	manned aviation	operations	and	activities	at	all	times. 30.	The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device	or vehicle. 31.	Flight	operations	must	be	conducted	at	least	500	feet	from	all nonparticipating	persons	(persons	other	than	the	PIC,	SO,	operator trainees	or	essential	persons),	vessels,	vehicles,	and	structures	unless: a.	Barriers	or	structures	are	present	that	sufficiently protect nonparticipating	persons	from	the	UA	and/or	debris	in	the	event	of	an accident.	The	operator	must	ensure	that	nonparticipating	persons remain	under	such	protection.	If	a	situation	arises	where nonparticipating	persons	leave	such	protection	and	are within	500	feet of	the	UA,	flight	operations	must	cease	immediately	and/or; b.	The aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the owner/controller	of	such	vessels,	vehicles	or	structures	has	granted permission	and	the	PIC	has	made	a	safety	assessment	of	the	risk	of operating	closer	to	those	objects	and	determined	that	it	does	not present	an	undue	hazard,	and; c.	Operations	nearer	to	the	PIC,	SO, operator	trainees	or	essential	persons do	not	present	an	undue	hazard to	those	persons	per	§ 91.119(a). 32.	All	operations must be	conducted	over	private	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	fo r	each	flight	to	be conducted.Triumphal	Bridges	|	AF400 23

33.	Any	incident,	accident,	or	flight	operation	that	transgresses	the lateral	or vertical	boundaries	of	the	operational	area	as	defined	by	the applicable	COA	must	be	reported	to	the	FAA's	UAS	Integration	Office (AFS

- 80)	with in	24	hours.	Accidents	must	be	reported	to	the	National Transportation	Safety	Board	(NTSB)	per	instructions	contained	on	the NTSB	Web	site: www.ntsb.gov

. 2.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section 61.113(a)	And	(b)	Would	Not	Adversely	Af fect	Safety.
AF400 submits	that	the	equivalent	level	of	safety	established	by	Section 61.113(a) and	(b)	will	be	maintained	because	no	PIC	will	be	allowed	to operate The	Drones unless	that	PIC	has	demonstrated,	by	meeting minimum	flight

- hour	and	currency requirements,	that	the	PIC	is	able	to safely	operate	the The	Drones in	a	manner	consistent	with	the exemption,	including	evasive	and	emergency	maneuvers	and maintaining	appropriate	distances	from	people,	vessels,	vehicles	and structures. Considering AF400 proposed	area	of	operations,	and	the operating	limitations	set	forth

- above;	the	parallel	nature	of	private	pilot aeronautical	knowledge	requirements	to	those	of	commercial	pilot requirements	(See	Exemption	No.	11062);	and	the	airmanship	skills necessary	to safely	operate The	Drones UAS, AF400 submits	that	the additional	manned	airmanship	experience	of	a	commercially certificated	pilot	would	not	correlate	to	the	airmanship	skills	necessary for AF400 specific	proposed	flight	operations. The	FAA	has	previously granted	relief	from	Section	61.113(a)	and	(b)	specific	to	UAS,	in circumstances	similar,	in	all	material	respects,	to	those	presented herein	(e.g.	Exemption Nos.	11062,	11063,	11064,	11065,	11066, 11067,	11080,	11109,	11110,	11112, 11136,	11138,	11150,	11 153, 11156,	11158,	11159,	11160,	11161). 3.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section 91.7(a)	Would	Not	Adversely	Affect	Safety. The	equivalent	level	of safety	established	by	Section	91.7(a)	will	be	maintained	because	prior to	every	flight, AF400 will	ensure	that The	Drones is	in	an	airworthy condition	based	upon	the	UAS’s	compliance	with	its	operating documents	and	as	stated	in	the	conditions	and	limitations	herein. Additionally,	the	FAA	has	previously	granted	relief	from	Section	91.7(a) specific	to	UAS,	in	circumstances	similar,	in	all	material	respects,	to those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,Triumphal	Bridges	|	AF400 24

11065,	11066,	11067,	11080,	11109,	11110,	11112,	11136,	11138, 11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161). 4.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section 91.121 Wo uld	Not	Adversely	Affect	Safety. The	equivalent	level	of safety	established	by	Section	91.121	will	be	maintained because	the altitude	information	of The	Drones will	be	provided	to	th e	PIC	via	GPS equipment	and	a	radio	communications	telemetry	data	link,	which downlinks	from	the	UA	to	the	GCS	for	active	monitoring	of	the	flight path	and	altitude.	This	altitude	information,	combined	with AF400 ’s operation	of The	Drones within	visual	lin e	of	sight,	at	or	below	500	feet AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121.	The altitude	information	will	be	generated	by	GPS	equipment	installed onboard	the	aircraft.	Prior	to	each	flight,	a	zero	altitude	initiation	point is	automati cally	established	by	the	UASs	at	ground	level. The	FAA	has	previously	granted	relief	from	Section	91.121	specific	to UAS,	in	circumstances	similar,	in	all	material	respects,	to	those presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065, 11066, 11067,	11080,	11109,	11112,	11136,	11138, 11150,	11153, 11156,	11157,	11158,	11159,	11160,	11161). 5.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section 91.151(b)	Would	Not	Adversely	Affect	Safety. A	grant	of	this	exemption	would	ensure	an	equivalent	level	of	safety established	by 14	C.F.R.	Section	91.151(b)	as	a	result	of	(1)	the technical	specifications	of The	Drones UAS;	(2)	the	limitations	on	the proposed	flight	operations;	and	(3)	the	location	of	the	proposed	flight operations.	Accordingly, AF400 will	ensure	that	it	will	safely	operate	the battery	powered The	Drones during	daylight	hours	in	VFR	conditions, with	enough	battery	power	to	fly	for	a	total	duration	of	13.5	minutes	to the	first	point	of	intended	landing	and,	assuming	normal	cruising speed, to	fly	after	that	for	at	least	4.5	minutes. Here,	as	in	Exemption	No. 11109,	the	technical	specifications	of The	Drones ;	the	limitations	on	the proposed	flight	operations;	and	the	location	of	the	proposed	operations will	ensure	an	equivalent	level	o f	safety	established	by	14	C.F.R.	Section 91.151(b).	Furthermore, safety	will	be	ensured	as The	Drones provide audible	and	visual	warnings	to	the	PIC	at	the	GCS	when	the	UAS experiences	low	battery	voltage,	the	first	warning	occurring	atTriumphal	Bridges	|	AF400 25

approximately	33% remaining	battery	power,	and	again	at approximately	10%	remaining	battery	power.	At	the	critically	low battery	level, The	Drones will	descend	and	land	automatically. Significantly,	previous	exemptions	granted	by	the	FAA	concerning Section	91.151	establish that	safety	is	not	adversely	affected	when	the technical	characteristics	and	operating	limitations	of	the	UAS	are considered.	Relief	has	been	granted	for	manned	aircraft	to	operate	at less	than	the	minimums	prescribed	in	Section	91.151,	including Exemption Nos.	2689,	5745,	and	10650.	Moreover,	the	FAA	has previously	granted	relief	from	Section	91.151	specific	to	UAS,	in circumstances	similar,	in	all	material	respects,	to	those	presented herein	(e.g.	Exemption	Nos.	8811,	10808,	10673,	11042,	11062,	11063, 11 064,	11065,	11066,	11067,	11080,	11109,	11110,	11136,	11138, 11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161). 6.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Sections 91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b) Would	N ot	Adversely	Affect	Safety. In	seeking	this	exemption, AF400 submits	that	the	equivalent	level ofsafety	with	regard	to	the	regulatory	maintenance	and	alteration requirements	established	by	Sections	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a)(2),	and	91.4 17(a)	&	(b)	will	be	met	because AF400 will	use	trained	technicians	to	perform	maintenan ce,	alterations or preventive	maintenance	on	the	UAS	using	the	methods,	techniques, and practices	prescribed	in	the	operating	documents	(i.e.,	the AF400 Aerial	Operation s	Manual,	Monthly	Maintenance	Log,	and The	Drones Instruction	Manual).	Furthermore, AF400 will	document	and	maintain all maintenance	records	for The	Drones

. Since The	Drones will	be inspected	as	prescribed	by	the	operating	documents, AF400 will maintain	th e	equivalent	level	of	safety established	by	Sections 91.405(a),	91.409(a)(1),	and	91.409(a)(2).	Furthermore,	the	exemption sought	would	maintain	an	equivalent	level	of	safety established	by Sections	91.407,	91.417(a)	and	91.417(b),	because	all	maintenance of The	Drones UAS	will	be	performed	by	trained	technicians. Maintenance	will	be	documented	and	maintained	utilizing	the	monthly maintenance	log.	Significantly,	previous	exemptions	granted	by	the	FAA concerning	Sections 91.405(a),	91.407(a)(1),	91.409(a)(1 )	&	(a)(2), and	91.417(a)	&	(b)	establish	that	safety	is not	adversely	affected	when the	technical	characteristics	and	operating	limitations	of	the UAS	areTriumphal	Bridges	|	AF400 26

considered. In	consideration	of AF400 proposed	operating	limitations, the operating	documents,	and	the	technical	aspects	of The	Drones, AF400 submits	that	safety	will	not	be	adversely	affected	by granting exemption	from	14	C.F.R.	Sections	91.405(a),	91.407(a)(1)	and	(a)(2), 91.409(a)(2), and	91.417(a)	and	(b).	The	FAA	has	previously	granted relief	specif

ic	to	UAS	in	circumstances	similar,	in	all	material	respects,	to those	presented	herein	(e.g.	Exemption	Nos.	11062, 11063,	11064, 11065,	11066,	11067,	11080,	11109,	11110,	11112,	11136,	11138, 11150, 11153,	11156,	11157,	11158,	11159,	11160,	11161).
7.	Th e	FAA	May	Prescribe	Any	Other	Conditions	For	Safe	Operation. In accordance	with	Section	333	of	the	FAA	Modernization	and	Reform	Act of	2012 (FMRA)	and	14	C.F.R.	§	21.16	entitled	Special	Conditions, AF400 requests	that the	FAA	prescribe	special	conditions	f or the intended	operation	of The	Drones,	which	contain	such	safety	standards that	the	Administrator	finds	necessary	to	establish	a	level	of	safety equivalent	to	that	established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14 C.F.R	§§	61.113(a)	&	(b),	91.7	(a),	91 .121,	91.151(b),	91.405(a), 91.407(a)	(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	Such	special conditions	will	permit	safe operation	of	the	UAS	for	the	limited	purpose of	conducting	aerial	video	and	photography	over	certain	areas	of	the United	States for	compensation	or	hire.	FMRA	Section	333	sets	forth	the requirements	for	considering	whether	a	UAS	will	create	a	hazard	to users	of	the	NAS	or	the	public,	or	otherwise	pose	a	threat	to national security;	and	further provides	the	authority	for	such	UAS	to operate without	airworthiness	certification	in	accordance	with	any requirements that	must	be	established	for	the	safe	operation	of	the	UAS in	the	NAS.	Likewise,	the	Administrator	may	prescribe	special
c onditions	pursuant	to	14	C.F.R.	§	21.16,	for	operatio n	of The	Drones, since	the	airworthiness	regulations	of	14	C.F.R.	Part	21	do	not	contain adequate or	appropriate	safety	standards due	to	the	novel	or	unusual design	features	of	the	aircraft.	Section	21.16,	entitled	Special	Conditions, states	the	following: If	the	FAA	finds	that	the	airworthiness	regulations	of	this	subchapter	do not	contain	adequate	or	appropriate	safety	standards	for	an	aircraft, aircraft	engine,	or	propeller	because	of	a	novel	or	unusual	design feature	of	the	aircraft,	aircraft	engine	or propeller,	he	prescribes	special conditions	and	amendments	thereto	for	the	product.	The	special conditions	are	issued	in	accordance	with	Part	11	of	this	chapter	andTriumphal	Bridges	|	AF400 27

contain	such	safety	standards	for	the	aircraft,	aircraft	engine	or propeller	as	the	FAA	fi nds	necessary	to	establish	a	level	of	safety equivalent	to	that	established	in	the	regulations.	See	14	C.F.R.	§	21.16. Therefore,	in	accordance	with	FMRA	Section	333	and	14	C.F.R.	§	21.16, the	FAA may	prescribe	special	conditions	for AF400 ’s	intended operation	of The	Drones,	which	contain	such	safety	standards	that	the Administrator	finds	necessary	to	establish	a	level	of	safety	equivalent	to that	established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14	C.F.R	Sections 61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b) ,	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b). **F.	A	Summary	That	Can	Be	Published	In	The	Federal	Register, stating:	The	Rules	From	Which**  **AF400 Seeks	Exemption:**  **AF400 seeks	exemption	from	the	requirements	of	14	C.F.R	Sections**  61.1 13(a)&(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b). A	Brief	Description	Of	The	Nature	Of	The	Exemption AF400 Seeks:	This exemption	will	permit AF400 to	commercially	operate	an	Unmanned Aircraft	System	(UAS)	for	the	purpose	of	conducting	aerial	video	and photography	over	certain	areas	of	the	United	States. **G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To Support	UAV	Aerial	Video	Request.**  This	Petition	is	made	pursuant	to	the	FAA	Modernization	and	Reform Act	of	2012	(FMRA)	Section	333,	which	directs	the	Secretary	of Transportation	to	determine	if	certain	UAS	may	operate	safely	in	the NAS.	As	such, AF400 request	for	exemption	may	be	granted	pursuant	to the	authority	of	FMRA	Section	333	and	14	C.F.R.	Part	11,	as set	forth above.	FMRA	Section	333	sets	forth	the	requirements	for	considering whether	a	UAS	will	create	a	hazard	to	users	of	the	NAS	or	the	public,	or otherwise	pose	a	threat	to	national	security;	and	further,	provides	the authority	for	such	UAS	to	operate	without	airworthiness	certification. As	discussed	in	detail	above, AF400 will	operate The	Drones safely	in the	NAS,	without	creating	a	hazard	to	users	of	the	NAS,	or	the	public,	or otherwise	pose	a	threat	to	national	security.Triumphal	Bridges	|	AF400 28 **CONCLUSION** As	set	forth	herein, AF400 seeks	an	exemption	pursuant	to	14	C.F.R. § 11.61	and	Section	333	of	the	FAA	Modernization	and	Reform	Act	of 2012	(FMRA), which	will	permit	safe	operation	of The	Drones commercially,	without	an	airworthiness	certificate,	for the	limited purpose	of conducting	aerial video	and	photography	over	certain	areas of	the	United	States.	By	granting	this	Petition,	the	FAA	Administrator will	be	fulfilling	the	Congressional	mandate	of	the	FAA	Modernization and Reform	Act	of	2012,	while	also	advancing	the	interests	of	the	public, by	allowing	UAV Aerial	Video	to	safely,	efficiently, and	economically operate The	Drones commercially	within	the	NAS. WHEREFORE,	in	accordance	with	the	Federal	Aviation	Regulations	and the	FAA Modernization	and	Reform	Act	of	2012,	Section	333, AF400 respectfully requests	that	the	Administrator	grant	this	Petition	for	an exemption	from	the	requirements of	14	C.F.R	Sections	61.113(a)	&	(b), 91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	& (a)( 2),	and	91.417(a)	&	(b),	and	permit AF400 to	operate The	Drones commercially	for	the	purpose	of	conducting	aerial	video	and photography	of	Real	Estate	Properties	(for	homeowners,	realtors,	home builders,	home	contractors	and	/	or	home	inspectors	for	real	e state marketing	and	inspection	of	home	exteriors)	as	well	as	filming	of	special events,	film	sets,	scripted	and	unscripted	television	sets	and	landscape as	well	as	conducting	power	line	inspection,	aerial	mapping,	surveying and	search	and	rescue	over	certain	areas	of	the	United	States. Respectfully	submitted	by Triumphal	Bridges

. Triumphal	Bridges | AF400 | 236	S	Broadway	St.	Ridgecrest,	CA	93555 | 601.951.1372 | aerialfilms400@gmail.comTriumphal	Bridges	|	AF400 29 **APPENDICES Appendix**  **A Summary for Federal Register Publication**  

### Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA determines that publication is needed.
Petitioner: Aerial Films 400 , LLC
Sections of 14 C. F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.15114 C.F.R. §91.405(a)14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)14 C.F.R. §91.417(a)&(b) Description of Relief Sought:
Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS operations over AF400 Client’s owned or controlled land, solely during daylight hours, to provide requested services. In general, sUAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature of operations anticipated by AF400 requires that the sUAS be flown at relatively low altitudes. AF400 expects that in most instances, the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk of interference with other aircraft is minimal.Triumphal	Bridges	|	AF400 30

**APPENDIX B: Specific Types of UAS and Their Respective Manuals** 

 For	convenience,	please	click	on	the	links	to	access	each	UAS’s	manual and/or	see	attachments.

1. DJI	Phantom	2

a. Phantom	2	Applicable	Manuals b. See	Attachment 2. DJI	Phantom	3

a. Phantom	3	Applicable	Manuals b. See	Attachment 3. DJI	Inspire

a. Inspire	1	Applicable	Manuals b. See	Attachment 4. DJI	S1000

a. DJI	S1000	Applicable	Manuals b. See	Attachment

5. 3D	Robotics	IRIS+

a. IRIS	Applicable	Manuals b. See	Attachment 6. 3D	Robotics	Solo

a. Solo	Applicable	Manuals b. See	Attachment 7. 3D	Robotics	X8+ | 3D	Robotics	X8

- M

a. X8+	|	X8

- M	Appli cable	Manuals b. See	Attachment

APPENDIX	C : MONTHLY	MAINTENANCE	LOG
Month:	Year:

UAS	# Date	Issue Discovered Date	Issue

Addressed Issue	Description	&	Maintenance

Conducted
Software	UpdatesTriumphal	Bridges	|	AF400 31

Airframe Engines Propellers
Camera	Gimbal Landing	Gear Vibration	Dampening
Other: