July 7, 2015 U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590 Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b). Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 (the "ReformAct") and 14 C.F.R. Part 11, Lewis Communications Inc., an operator ofSmall UnmannedAircraft Systems ("sUASs") for aerial image acquisition including but not limited to, thefollowing industries: motion picture and television, real estate, short range inspection, mapping & survey, agriculture, search & rescue, hereby appliesfor an exemption ·from the FederalAviation Regulations ("FARs") to allow commercial operation of its sUASs. Lewis Communications lnc,'s requested exemption would permitthe operation ofsUAS under controlled and secure conditions that is: (i) limited, (ii) predetermined, (iii) subjectto controlled access, and (iv) provide greater safety in connection with aircraft operations. As established bythe exemptions already granted by the FAA, approval of Lewis Communications Inc. 's exemption would enhance safety and fulfill the Secretary of Transportation's (the FAAAdministrator's) responsibilities to "

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe ReformAct. The name and address ofthe applicant is:

John Pope Lewis Communications lnc.Phone: 205-721-0657 Email: jpope@lewiscommunications.com Address: 2420 Chandabrook Drive Pelham, AL 35124

Regulations from which the exemption is requested: 14 CFR 61.113(a) and (b) 14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151(a)

· 14 CFR 91.405(a)

14 CFR407(a)(1) 14 CFR409(a)(2) 14 CFR417(a) and (b) Page 1 of 6sUASs operated by Lewis Communications Inc. weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). They operate at speeds ofno more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Lewis Communications Inc. will only operate its sUASs in line ofsight and will operate only within the secure area described in the FOPM. Such operations will insure thatthe sUAS will "not create a

. hazard to users ofthe national airspace system orthe public."

Given the small size of Lewis Communications Inc.'s sUASs and the restricted secure environment within which they will operate, Lewis Communications Inc.'s sUAS operations adhere to the Reform Act's safety requirements. Additionally, dueto the size ofthe sUASs, permission from relevant property owners or other applicable parties, and the limited areas in which they will operate, approval ofthis application presents no national security issues. Based on the substantial level ofsafety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant ofthe requested exemption is in the public interest. Accordingly, Lewis Communications Inc.respectfully requests thatthe FAA grantthe requested exemption.
AircraftAnd Equivalent Level OfSafety The operating limitations proposed by Lewis Communications Inc. providefor at least an equivalent or higher level ofsafety because operations further enhance safety of aerial image collection using conventional aircraft. The limitations and conditions include: The sUASs will weigh less than 55 pounds. Frequently far less. Flights will be operated within line ofsight ofa pilot and/or observer. Maximum flighttime for each operational flight will be no more than 30 minutes. Flights will be terminated at no less than 25% battery power reserve should that occur priorto the 30 minute limit. Flights will be operated at an altitude below 400 feetAGL, and not more than 200 feet above an elevated platform from which filming is planned. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator. A sUAS pilotwil maintain athird class medical and valid US or Canadian drivers license.

A sUAS pilotwill be Pilot in Command (PIC). The sUAS will only operate within a confined secure area as defined in the

**·FOPM~**

Page 2 of 6A briefing will be conducted for planned sUAS operations priorto each day'sflight. All personnel performing dutieswithin the boundaries of the safety perimeter are required to attend. The operatorwill obtain consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 500 feet ofthe flight operation. The Pilot and observer must be trained in sUAS operations and have received current information on the particular sUAS to be operated as required by the FOPM. The Observer and pilotwill be able to communicate by voice and/or text at all times. Written and/or oral permission from the relevant property holderswill be obtained priorto flight operations. All appropriate permissions and permits will be obtained from territorial, state, county, or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. Ifthe sUAS loses communications or loses its GPS signal, the sUAS will havethe capability to return to a pre-determined location within the secure perimeter and land. The sUAS will havethe capability to abort aflight in case of unpredicted obstacles or emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Becausethe sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety of current operations by requiring the PIC operating the aircraftto have a private pilot's license ratherthan a commercial pilot's license to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is remotely controlled by a ground-based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the use of a sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 allowing sUAS use by asport pilot as the PIC exceedsthe present level ofsafety sought by 14 C.F.R. §61.113 (a) and (b).

14 C.F.R. § 91.103: PreflightAction Section 91.103 requires each pilotto preflight an aircraft before flight Page 3 of 6to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level ofsafety will be provided. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before commencement of flight.
14 C.F.R. §91.119(c): Minimum SafeAititudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 provides, in pertinent part, that: "exceptwhen necessaryfor takeoffor landing, no person may operate an aircraft belowthe following altitudes:

..... (c) Over otherthan congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feetto any person, vessel, vehicle, orstructure." Because Lewis Communications Inc. requests authority to operate at altitudes no higherthan 400AGL, and not more than 200 above an elevated platform from which filming is planned, an exemption is needed to allow such operations. Exceptforthe limited conditions stated in the FOPM, the sUAS will never operate higherthan 400AGL. It will, however, be operated in a restricted area within a security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, and speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission of property owners or local officials. Because ofthe advance noticeto the property owners and participants in the filming activity, all affected individualswill be informed ofthe planned flight operations. Compared to flight operations for manned aircraft and the lack offlammable fuel, any risk associated with the proposed sUAS operations is far lessthan conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between a sUAS and conventional aircraft.

14 C.F.R. §91.121: Altimeter Settings Section 91.121 requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation of the departure airport or an appropriate altimeter setting available before departure."As a sUAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level ofsafety will be achieved by the operator, pursuantto the FOPM and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator beforeflight.

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions

Page 4 of 6Section 91.151(a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to thefirst point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes

...." The typical battery powering the Lewis Communications Inc. sUASs provides less than 30 minutes of powered flight. To meetthe 30-minute reserve requirement in 14 CFR §91.151, sUAS flightwould not be possible. Given the limitations on the sUAS's proposedflight area and its proposed operations within a predetermined location, a longertimeframe forflight in daylightVFR conditions is reasonable. Furthermore, operating the sUASs in a tightly controlled area where only people, property owners, or official representativeswho have signed waiverswill be allowed, less than 30 minutes of reserve fuel does not engenderthe type of riskthat §91.151(a) was intended to address. Lewis Communications Inc. believesthat safety can be achieved by limiting flights to 30 minutes or 25% of battery power, whichever occurs first. This restriction would be morethan adequate to return the sUAS to its predetermined landing zonefrom anywhere in its limited operating area.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or ownershall "have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintainthe aircraft in compliancewith Part43. Given thatthese sections and Part43 apply only to aircraftwith an airworthiness certificate, these sectionswill not apply to Lewis Communications lnc.operations. Maintenancewill be accomplished by the operator. An equivalent level ofsafetywill be achieved becausethe sUASs are limited in size, will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise, the sUAS can land immediately and will be operating from no higherthan 400 feetAGL. As provided in the FOPM, the operatorwill ensurethatthe sUAS is in working order priorto flight, perform any required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the sUAS and best suited to maintain it in an airworthy condition. Summary for Publication Pursuantto 14 C.F.R. Part 11, thefollowing summary is provided for publication in the Federal Register, should it be determined that publication is needed: Lewis Communications Inc. seeks an exemption from thefollowing rules: 14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate Page 5 of 6commercially a small unmanned vehicle (55 pounds or less) in commercial image acquisition operations. As established bythe sUAS exemptions already granted by the FAA, allowing commercial operations ofsUASs in agriculture, real estate, inspection, S & R, and film industrieswill enhance safety by reducing risk. Conventional survey, agricultural, mapping, inspection, and film operations, using turbine aircraft, operate at low altitudes and presentthe risks associated with aircraftthatweigh around 4,000 pounds, and which carry large amounts ofJetA fuel. Such aircraft must also fly to and from the target location. In contrast, a sUAS weighing fewerthan 55 pounds and powered by batteries eliminates virtually all ofthat risk given the small size and lack ofcombustible fuel. The sUAS is carried, and notflown, to target site. In this regard, the sUAS carries no passengers or crew and, therefore, will not expose them to the risks associated with manned flights. The operation ofsUASs conducted in the strict conditions outlined in the FOPM will provide an equivalent level ofsafety supporting the grant ofthe exemption requested herein. The sUASs operate at slow speeds, closeto the ground, and in a secure environment. As a result, they are far saferthan conventional operations conducted with turbine helicoptersflying nearthe ground and people. Privacy All flights will occur over private or controlled access areaswith the property owner's prior consent and knowledge. Recognizable imageswill only be recorded of peoplewho have given their consent orotherwise have agreed to be in the areawhere active image acquisition will take place. Satisfaction ofthe criteria provided in Section 333 ofthe ReformAct of2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security) provide morethan adequatejustification to grant Lewis Communications Inc.'s requested exemption, allowing for Lewis Communications Inc.'s sUAS commercial operationsforthe listed industries pursuantto the included FOPM. Ifyou have any questions or need any additional information, please contactthe undersigned by phone at 205-721-0657 orvia email at jpope@lewiscommunications.com

Lewis Communications Inc.

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