July 10, 2015

Exemption No. 12007 Regulatory Docket No. FAA

– 20 15

– 0718

Mr. Greg Steinmetz
Chosen Productions
4316 McCahill Road Red Bank, TN 37415

Dear Mr. Steinmetz :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated March 17, 2015

, you petitio ned the Federal Aviation Administration (FAA) on

behalf of Chosen Productions ( hereinafter petitioner or operator ) for an exemption

. The exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to

conduct aerial photography, videography, and closed

- set filming of motion pictures

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a K130 Multirotor.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements o f part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1 and closed set motion picture and filming

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No.

FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and

11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Chosen Productions is granted an exe mption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection and closed set motion picture and filming

. This exemption is subject to the conditions and
limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Chosen Productions is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the K130 Multirotor when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determ ine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet ab ove ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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, a s specified on the PIC’s FAA

- issued airman medical certificate or
U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be use d to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designate d before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operation s in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon re quest. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follo w 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 or any law enfo rcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which th e FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS tha t 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 prior to conducting further operations under this exemption.

Functi onal test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is respo nsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. 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 found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS oper ated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal

G overnment. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 i n an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this e xemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights fo r the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonpar ticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual mete orological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for air ports not denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption

hold er. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that f or at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemptio n holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accord ance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any docume nts required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request

.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpart icipating 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 person s 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 in a manner ensuring the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight op eration that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A'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

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following a dditional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exempti on must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities

must inclu de at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Mak e, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.8

This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/
John S. Duncan Director, Flight Standards Service1

March 17 , 2015 Chosen Productions

Attn: Greg Steinmetz

4316 McCahill Rd

Red Bank, TN 37415

352

- 266

- 7180
greg@chosenproductions.org

U.S. Dept. of Transportation, Docket Operations
West Building Ground Floor, Room w12

- 140

12 00 New Jersey Avenue, SE.,
Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal
Aviation Regulations

De ar Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 11,
and the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C.
§ 44701(f), Chosen Productions (“Petitioner”) hereby petitions for exemptions from :

14 C.F.R. Part 21 Subpart H

14 CFR § 45.23

14 CFR § 45.29
14 CFR § 91.203(a) & (b)

14 CFR § 91.9(b)(2)

14 CFR § 61.113 (a) and (b)

14 CFR § 91.11 9

14 CFR § 91.121

14 CFR § 91.151
14 CFR Subpart E § 91.403
14 CFR Subpart E § 91.405 (a)
14 CFR Subpart E § 91.407
14 CFR Subpart E § 91.409
14 CFR Subpart E § 91.417
8900.227 Paragraph 16(e)(1)2



### Petition Summary
The proposed exemptions, if granted, would allow Petitioner to operate unmanned aircraft systems (“UAS”) weighing 55 pounds or less for the purpose of aerial still photography, aerial videography and closed

- set f ilming of motion pictures

. Based on the small size of Petitioner’s UAS, the qualifications and experience of Petitioner’s UAS operators, and the restricted, sterile environment within which Petitioner will operate, the requested exemptions fall squarely

wi thin the zone of s afety envisioned by Congress set forth in Section 333. The Petitioners, in the past have chartered full

- sized helicopters for the purpose of video production, which has proven more costly and with a higher safety risk than that of a small UAS . Chosen Productions highest goal is the s afety of the public, property and national airspace. The UAS will be operated in accordance with the FAA policy N 8900.227 Section 14 “Operational Requirements

for UAS”. T he specific guidelines and procedures detailed in the “Operations Manual” and the “Pilots Operating Handbook” proposed by the Petitioner gives the FAA good cause to find that the UAS operations are in the public interest.



### EXEMPT ION REQUESTS AND EQUIVELANT LEVE L OF SAFETY

14 CFR Part 21, S ubpart H: Airworthiness Certificates
Petitioner requests an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the following paragraph and attached operations manual

. If an airworthiness certificate exemption is not appropriate for this application, then petitioner requests an experimental certificate be issued

under either or both of the f ollowing provisions:

21. 191 Experimental C ertif icates Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiat e major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes, we would expect that an experimental certificate , if applica ble, would permit o ur commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements outlined in Petitioners Operations Manual.

14 CFR 45.23 Display of marks; gen eral and 45.29 Size of marks
These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word3

"EXPERIMENTAL" in letters at least 2 inc hes high near the entrance to the cabin, cockpit, or pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA.

Petitioner proposes to achieve an equivalent level of safety

, if an experimental certificate is required

, by including the word "EXPERIMENTAL" on a placard on the rear of the aircraft where the PIC, VO and others in the vicinity of the will be able to see the designation. An additional pla card , described in the following section, displayed on the aircrafts ground station will provide the aircraft's registration information at the ground level also

.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required The regulation provides tha t an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircra ft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockp it entrance so that it is legible to passengers or crew."

At a maximum gross weight of 27 pounds, the UA S is too small to carry the required “legible”
documentation, is not capable of carrying passengers or crew, and does not have an entrance. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In o rder to identify the aircraft, we propose that the information placard outlined in the 14 CFR 45.23 exemption

section above

, be permanently affixed to the aircraft via placard containing the word

“EXPERIMENTAL” (if applicable) to satisfy the requirement of 14 CFR 45.23

. Petitioner is also prepared to “fold” documentation into a smaller form factor to be displayed in the aircraft if

needed.

14 CFR 91.9 (b)(2), Civil aircraft flight manual, marking, and placard requirements

. This regulation provides that no person may operate an aircraft unless a current, approved flig ht manual is in the aircraft. Petitioner assume s that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry

documentation.

To obtai n an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA S Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 (a) and (b) Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Su bparagraph (b) allows a private pilot to act as pilot in command 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 carry4

passengers or property f or compensation or hire. Our proposed operations require that the PIC

must either :

1. Hold a Private Pilot s Certificate issued by the FAA

2 . Meet the requirements of 8900.227 para 16(c)(2)(c ) "Operations without a pilot certificate"

in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the

FAA Private Pilot written examination."

T here are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply f o r a commercial pilot's license, we propose to
generate an equivalent level of safety. Petitioner ’ s PIC currently holds a Private Pilots

Certificate issued by the FAA. Since the aircraft cannot carry passengers or property, we feel

we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to

conduct a business.

14 CFR 91.119 Minimum safe altitudes: General 14 CFR 91.119(c) states that over sparsely populated areas the aircraft cannot be operated closer

than 500 feet to a ny person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement.

Consistent with the relief typically provided to manned operations under FAA Order 8900.1, Volume 3, Cha pter 8, Section 1, Petitioner requests relief from 14 CFR 91.119 in respect to those participating persons, vehicles, and structures directly involved with the filming process. Petitioner’s Operating Manual sets forth safety factors for authorizing and con senting production personnel. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft.

14 CFR 91.121 Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an barometric altimeter setting available within 100 NM of the aircraft.

The UA S will always fly below 400 feet AGL and will not need to maintain cruising altitudes i n order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement

, in feet, above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter onboard the UAS. Instead,

altitude information is generated by GPS equip ment installed onboard the UAS and digitally transmitted to the ground station display. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requeste d relief from 14 C.F.R. § 91.121.

14 CFR 91.151 Fuel requirements for flight in VFR conditions The regulation provides that no person may begin a flight in an airplane under day

- VFR5

conditions unless there is enough fuel to fly to the first point of inten ded landing and to fly after

that for at least 30 minutes.

Petit ioner seeks exemption regarding; t he UA S is battery operated and the maximum d uration of flight with payload from a single battery charge is 9 minutes 30 seconds minutes with a 30 %

reserve. S ince the aircra ft will never fly more than 3/4 NM from the point of intended landing, a full battery charge at launch (procedures outlined in the Pilots Operating Handbook) will ensure

that we meet the reserve energy requirement of this paragraph.

14 CF R Subpart E (91.403, 91.405 (a) , 91.407, 91.409, 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the VO perform maintenance and inspec tion of the aircraft and "be authorized to approve the aircraft for return to service." Petitioners VO has six years’ experience in maintenance and service with this type of aircraft. As provi ded in the Pre

- Flight

Checklis t, both the PIC and VO will ensure that the aircraft is in an air worthy condition prior to every flight. This is also how the petitioner will comply with 14 C.F.R. 91.7(a) Civil Aircraft

Airworthiness. The Pilots Operating Handbook outlines documentation required for the maintenance, service and inspecting the UAS. The VO will document work performed in

accordance with 91.417 . We feel that due to the size, construction, and sim plicity of the aircraft, petitioner can ensure an equivalent level of safety.

8900.227 Paragraph 16(e)(1) Observer Medical This policy provides that both the PIC and VO must have a valid FAA second

- class medical

certificate issued under P art 67 in order to perform as a pilot or observer.

Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA S will return autonomously to the site of launching and land without crew intervention. Petitioner currently complies with the minimum medical requirements for the PIC as described in Paragraph 16(c)(4). Petitioner requests exemption from 8900.227 Paragraph 16(e)(1) requiring the VO to

meet the same medic al requirements as commercial pilot carrying passengers in a l arge airc raft Petitioner requests the minimum requirements for VO be vision corrected to 20/20. The 20/20

vision r equirement will ensure that both the PIC and VO can see and av oid air traffic

.