Triumphal	Bridges	|	AF400 1

FROM:	

Triumphal	Bridges |	Aerial	Films	400,	LLC|	236	S	Broadway	St.	

Ridgecrest,	CA	93555

Tel:	601.951.1372Email:	aerialfilms400@gmail.com

TO:	

DOCKET	OPERATIONSROOM	W12-140	OF	THE	WEST	BUILDING	

GROUND	FLOOR1200	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	REGULATIONSPART	21,	

SUBPART	H	AND	SECTIONS	§§	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)	CONCERNING	COMMERCIALOPERATION	OF	THE	

DRONES UNMANNED	AIRCRAFT	SYSTEMSPURSUANT	TO	SECTION	

333	OFTHE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	

2012(PUBLIC	LAW	112-95)	

Submitted	on	October	18,	2015	
Triumphal	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	ABBREVIATIONS

Above	Ground	Level	Area	of	InterestAir	Traffic	ControlAir	Traffic	

Organization	Aerial	Vehicle	

Code	of	Federal	Regulations	Certificate	of	Authorization	Federal	

Aviation	Administration	Federal	Aviation	Regulation	Ground	Control	

Station	

Global	Positioning	System	Loss	of	LinkNational	Airspace	System	

Notice	to	Airman	

Pilot	In	CommandFAA	Modernization	and	Reform	Act	of	2012	(FMRA)	

Section	333	Safety	ObserverStandard	Operating	

ProceduresUnmanned	AircraftUnmanned	Aircraft	SystemVisual	

Flight	RulesVisual	Line	of	SiteVisual	Meteorological	

ConditionsVertical	Takeoff	and	Landing	
Triumphal	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	permitAF400 to	operate	an	Unmanned	Aircraft	

System	(UAS)	for	the	commercial	purpose	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	been	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	public	

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	Aviation	
Triumphal	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	Administrator	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	unmanned	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

equivalentlevel	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,	

AF400 submits	that	it	will	ensure	that	The	Drones	are in	an	airworthy	
Triumphal	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	Drones 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	flyafter	that	

for	at	least	4.5	minutes.	

In	accordance	with	14	C.F.R.	§	11.81,	AF400 provides	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	93555Tel:	601.951.1372Email:	

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	

the	following:	
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(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	flightlevel	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	the	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	

appropriateavailable	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	

Section91.405(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	thissection,	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	authorized
Triumphal	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	91.409,	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	accordance	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	or	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	orsafety	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	retained	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 from	

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	PIC	
Triumphal	Bridges	|	AF400 11

has	met	certain	flight-hour	and	currency	requirements,	demonstrating	

that	the	PIC	is	ableto	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 submits	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,	the	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	higher	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	ground	

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	AerialVideo	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	conditionprior	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	the	
Triumphal	Bridges	|	AF400 12

operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	The	Drones

Instruction	Manual)	prior	toevery	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	AerialVideo	

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	therequested	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	AerialVideo	

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	operatethe	battery	powered	UAS	during	daylight	
Triumphal	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	operation	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	further	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 will	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	Efficiency	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	utilized	

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,	compared	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	Operations	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	alternative	
Triumphal	Bridges	|	AF400 15

technologyin	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	such	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	will	

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;	and	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 Instruction	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	Reform	Act	of	2012	(FMRA)	Section	333.In	

consideration	of	the	size,	weight,	speed,	and	limited	operating	area	

associatedwith	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	airworthinesscertification	and	sets	forth	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. 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	enactment	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	planand	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	

size,	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	for	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,	weight,	

speed,	and	operational	capability.	

i.	Technical	Specifications	Of	The	Drones UAS.	The	technical	
Triumphal	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	Drones 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	assume	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	of	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	Of 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	time.	

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	maximum	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	conducting	
Triumphal	Bridges	|	AF400 18

operations	for	the	purpose	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	capability.	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	of	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	andis	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	the	
Triumphal	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	

exemption,	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	inspect	the	UAS	to	ensure	that	it	is	

in	a	condition	for	safe	flight.	If	the	inspection	reveals	a	condition	that	

affects	thesafe	operation	of	the	UAS,	the	aircraft	is	prohibited	from	

operating	until	the	necessary	maintenance	has	been	performed	and	the	

UAS	is	found	to	be	in	acondition	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	alterations	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-flight	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,	and	
Triumphal	Bridges	|	AF400 20

record	keeping	requirements,	in	accordance	with	the	operating	

documents.	Maintenance,	inspection,	alterations,	and	status	of	

replacement/overhaul	component	partsmust	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	comply	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	successfully	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	qualification	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	special	
Triumphal	Bridges	|	AF400 21

request	will	be	made	at	the	FAA	office	closest	to	proposed	area	of	

operations.	Flights	under	special	visual	flightrules	(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	Noticeto	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	with	
Triumphal	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	personsdo	not	present	an	undue	hazard	

to	those	persons	per	§ 91.119(a).	

32.	All	operations	must be	conducted	over	private	or	controlled-access	

propertywith	permission	from	the	land	owner/controller	or	

authorized	representative.	Permission	from	land	owner/controller	or	

authorized	representative	will	be	obtained	for	each	flight	to	be	

conducted.	
Triumphal	Bridges	|	AF400 23

33.	Any	incident,	accident,	or	flight	operation	that	transgresses	the	

lateral	orvertical	boundaries	of	the	operational	area	as	defined	by	the	

applicable	COA	must	be	reported	to	the	FAA's	UAS	Integration	Office	

(AFS-80)	within	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	Affect	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.	ExemptionNos.	11062,	11063,	11064,	11065,	11066,	

11067,	11080,	11109,	11110,	11112,11136,	11138,	11150,	11153,	

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 Would	Not	Adversely	Affect	Safety.	The	equivalent	level	of	

safety	established	by	Section	91.121	will	be	maintainedbecause	the	

altitude	information	of	The	Drones will	be	provided	to	the	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	line	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	automatically	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	by14	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	of	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	at	
Triumphal	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,	

11064,	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	Not	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	91.417(a)	&	(b)	will	be	met	because	AF400

will	use	trained	technicians	to	perform	maintenance,	alterations	or	

preventive	maintenance	on	the	UAS	using	the	methods,	techniques,	

andpractices	prescribed	in	the	operating	documents	(i.e.,	the	AF400

Aerial	Operations	Manual,	Monthly	Maintenance	Log,	and	The	Drones

Instruction	Manual).	Furthermore,	AF400 will	document	and	maintain	

allmaintenance	records	for	The	Drones.	Since	The	Drones will	be	

inspected	as	prescribed	by	the	operating	documents,	AF400 will	

maintain	the	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	safetyestablished	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	Sections91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	

and	91.417(a)	&	(b)	establish	that	safety	isnot	adversely	affected	when	

the	technical	characteristics	and	operating	limitations	of	theUAS	are	
Triumphal	Bridges	|	AF400 26

considered.In	consideration	of	AF400 proposed	operating	limitations,	

theoperating	documents,	and	the	technical	aspects	of	The	Drones,	

AF400 submits	that	safety	will	not	be	adversely	affected	bygranting	

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	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,	

11150,11153,	11156,	11157,	11158,	11159,	11160,	11161).	

7.	The	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	thatthe	FAA	prescribe	special	conditions	for	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	

conditions	pursuant	to	14	C.F.R.	§	21.16,	for	operation	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	and	
Triumphal	Bridges	|	AF400 27

contain	such	safety	standards	for	the	aircraft,	aircraft	engine	or	

propeller	as	the	FAA	finds	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	FAAmay	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	

61.113(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).	

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

respectfullyrequests	that	the	Administrator	grant	this	Petition	for	an	

exemption	from	the	requirementsof	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	estate	

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.com
Triumphal	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. §91.12114 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	Applicable	Manuals

b. See	Attachment

APPENDIX	C: MONTHLY	MAINTENANCE	LOG	

Month:	Year:	

UAS	#	 Date	Issue	

Discovered	

Date	Issue	

Addressed	

Issue	Description	&	Mainten

Conducted	

Software	Updates	
Triumphal	Bridges	|	AF400 31

Airframe	

Engines	

Propellers	

Camera	Gimbal	

Landing	Gear	

Vibration	Dampening	

Other: