July 20, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

EVE TeleSports LLC Ryan Bell
27 West Adelaide Ave Nashua, NH 03064 ryan.bell@evetelesports.com

Subject: EVE TeleSports Section 333 Exem ption Summary grant candidate request

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) And (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (1) and (2); 14 CFR 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, EVE TeleSports LLC, operator of Small Unmanned Aircraft System s (sUAS),

Comm ercial operator of sUAS, as described herein, which are equipped with camera(s) and sensor s, would operate in the manner described below.

For the expressed purpose of assisting with a more rapid response to this request for exemption and to
remain consistent with established precedence , EVE TeleSports LLC submits this petition in a format
flo w that is similar to Kadoo Aerial’s submission dated April 8, 2015 , Section 333 Exemption #12113 granted July 22 nd , 2015. Kadoo Aerial operations were found to align with EVE TeleSports intended operations. Except where explicitly identified ( using italics ) , this submission is the same as submission

# 12113 , and has been adapted to describe operations unique to EVE TeleSports. I t is thought that the
Administration ’ s familiarity with the content of that request will assist in the review and a pproval of this

r equest for aerial photography and aerial data collection operations per “summary grant” process.

EVE TeleSports LLC is pleased to operate in a manner consistent w ith the operational requests granted by Exemption # 12113

, with a focus on action sports film ing. EVE TeleSports LCC operates 3D Robotics SOLO
Smart Drones. At its core, EVE TeleSports LLC offers an aerial photography / videography service. EVE TeleSports LLC’s vision is to offer services to clientele at specialty car shows, sanctioned racing even ts, yachting and sailing regatta’s, as well as at extreme sports events offering 'follow me', 'orbit’, and 'cablecam' services. EVE TeleSports provides first person view (FPV) and third person point of view (bird’s eye

view) vantage points unavailable wi th traditional videography equipment which falls into the category of
aerial data collection

.

The FPV experience is offered to clientele as part of a ‘ride along’ experience during some services and is in no way used to pilot sUAV

. Si milar to previously approved aerial data collection usages, t he FPV equipment is a federated system (separate from the drones integrated control system) which transmits and records video feed. P ilotage of the sUAS will only be accomplished via unaided (corrective lenses and/o r sunglasses excepted) visual contact between a pilot in command and an unmanned aircraft sufficient to maintain safe operational control of the aircraft, know its location, and be able to scan the airspace in which it is operating to see and avoid other a ir traffic or objects aloft or on the ground without the aid of FPV. EVE TeleSports Pilot in Command (PIC) working with a Visual Operator will maintain direct view of flight operations and maintain Visual Line of Site ( VLOS ) remaining in full control
at al l times. As described by Exemption #12113, EVE TeleSports LLC will provide:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, public
events, cinematography and news gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers with help of F.L.I.R. (Forward Looking Infrared Camera) and/or thermal imaging cameras

.

 Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster (i.e. First Person View)

 Aerial photography / videography of yachts and boats

 Aerial photography / videography of actio n sports such as skiing, mountain biking, dirt biking, kayaking and/or autocross racing.

EVE TeleSports LLC h ereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its s UAS ’s , so long as such operations are conducted within
and under the conditions outlined herein or as may be established by the FAA as required by Section
333.

As described fully below, the requested exemption would permit the operation of a UAS under
controlled conditions in t he NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the established operations in the industry presently using conventional
aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.The name and address of the appli cant is:

EVE TeleSports LLC

Attn: Ryan Bell, GM

/ sUAS Operator
Phone: 603

- 921

- 6100
Email: ryan.bell@evetelesports.com Address: 27 West Adelaide, Ave Nashua, NH 03064

Owner /Operator of 3DR SOLO Smart Drone s

Regulations from which the exemption is requ ested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103
14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certa in unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: • The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated area s; and • Operation of the UAS within visual line of sight of the operator.

Reform Act 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such
aircraft in the nationa l airspace system.” Id. 333(c) (emphasis added) Appl icant interprets this provisionto place the duty on the Administrator to not only process applicatio ns for exemptions under section

333, but for the Administ rator to craft conditions for the safe operation of the UAS, if it should be
determined that the conditions set forth herein do not fulfill the statutory requirements for approval. The Federal Aviation Act expressly grants the FAA the authority to issue ex emptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under 40101 of the Act that includes sUAS, from the requirement that all civil aircraft must have a current airworthiness
certificate. The Administrat or may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. 44701(f) See also 49 U SC 44711(a); 49 USC 44704;

14 CFR 91.203 (a) (1).

EVE TeleSports LLC, sUAS are multi

- rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 55 mph and have the capability to hover,
and m ove in the vertical and horizontal plane simultaneously. They will operate only in visual line of sight and will operate only within a controlled area. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace sy stem or the public.” Reform Act Section 333 (b).
Given the small size of the sUAS inv olved and the restricted environment within which they will operate, the applicant projects the equivalent level of safety whi ch Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the
UASs and the restricted areas in which the relevant sUAS will operate, approval of the application
presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public bene fit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA gr ant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation proposed in conjunction with the limitations offer an equivalent or higher level o f safety

to persons and/or property as compared to using conventional aircr aft for the same operations . The applicant proposes that the exemption requested herein apply to civil unmanned aircraft that have the
characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure because the proposed operations represent s afety enhancement to the accepted safe ty of operations conducted
with conventional aircraft. The limitations and conditions to which EVE TeleSports , LLC agrees to be
bound when conducting commercial operations under an FAA issued exemption as set forth in the Flight Operations Manual (FOM) include (these parameters updated from requested parameters in # 12113 of to reflect the FAAs appro ved operating parameters ) :1. Operations authorized by this grant of exemption are limited to 3DR SOLO Smart Drone when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to am end this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not 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 ca librated airspeed to determine 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 above 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 ot her than corrective lenses, as 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 used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and
PIC must be able to comm unicate verbally at all times; electronic messaging or texting is not permitted during flight operation s. 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 VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations 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 availabl e to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Othe rwise, 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 or any law enforcement 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 the FAA granted this exemption, then the operator must petition for an 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.
8. 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 prior to conducting further operations under this exemption.Fun ctional 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 r esponsible 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 inspecti on 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 operated 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 curren t FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 6 1.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

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
unde r this exemption, 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).
Fl ights for the purposes of training the operator’s PICs and VOs (training, 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

pe rmitted under the terms of this 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 considere d nonparticipants, 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 vi sual meteorological 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 airports not denoted with an ARP, the center of the airport symbol 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 exem ption holder. The letter ofagreement 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 cl oud or when visibility is less than 3 statute miles from the PIC.

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

determined location within the private 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 afte r that for at least five 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 conducted in accordance with an ATO

- issued COA. The exemption 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.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registe red in accordance 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 documents 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 offici al
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 nonparticipating 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 nonp articipating 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 in a manner ensuring the safety of nonparti cipating p ersons; 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 p resent 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 controlled

- access property with permission from the propert y 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 operation that transgresses the lateral or vertic al
boundarie s 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.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as require d by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of t he Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational cap ability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions propos ed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated by EVE TeleSports is less than 55 lbs fully loaded , carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a
secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly
controlled and mo nitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property own ers than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no additional threat to national security posed by the UAS, due to i ts size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light‐sport category aircraft or experimental or provisionally certificated aircraft,
the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station,in letters not less than 2 inches nor m ore than 6 inches high, the words "limited," "restricted,"

"light‐sport,"

, "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS
will

, have no entrance to the cab in, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two‐inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of sa fety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. EVE TeleSports

, LLC will achieve an equivalent level of safety as achieved by current Regulations because the applicant’s sUAS do not carry any pilots or pass engers nor property.

EVE TeleSports , LLC sUAS do not carry any pilots or passengers nor property therefore the petitioner is requesting an exemption to 14 CFR 61.113(a) The se verity of impact of realized risks attendant to the operation of a sUAS is far less than the impact of realized risk inherent in the commercial activities outlined in 14 CFR 61. The level of safety provided by the requirements included in the Manual exceeds
that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are reduced from the level of risk associated with commercial operations contemplated by P art 61 when drafted. A llowing operations of the sUAS as

re quested with a pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness The regulation requi res that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthines s.

Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.‐registered civil aircraft ... (2) for which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.The UAS, given its size and configuration has no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. The
FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions befo re flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption
will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff
distances and aircraft performance data before initiation of flight as well as checking sUAS for any possible damage that might cause less than favorable flight conditions.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio
communications. The FAA has approved exemptions for flight training without fully functional dual
controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by
the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the perso n operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA.

As this exemption is for a UAS and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platf orm from which filming is planned, an exemption

may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than

400 AGL. It will be operated in a restricted area with security perimeter, where buildings and pe ople will not be exposed to operations without their pre‐obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of t he property owner or local officials. Because of the advancenotice to the property owner and participants in the filming activity, all affected individuals will be

aware of the planned flight operations. Compared to flight operations with aircraft or roto rcraft weighting far more than the maximum 55lbs and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, th e low‐altitude operations of the UAS will ensure separation between the sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting
available before departure.”

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude
in dicator before flight.

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

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering th e UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be prohibitive to the intended operations

. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR
conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating th e UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 25% battery power , does not engender the type of risks that Section 91.151(a) was intended to alle viate given the size and speed of the small UAS. Additionally, limiting UAS flights time s would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 25% of battery power. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regul ation provides in pertinent part:(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft u nless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully lo aded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the

UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations requir e that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these
sections will not apply to the applicant. Maintenanc e will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a li mited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and ke ep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be
achieved because maintenance and inspections will be performed in accordance with the UAS
Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintena nce needed including regular software and firmware updates

. EVE TeleSports will commence and conclude all operations using a preflight safety check list to ensure equivalent level of flight safety

.

Pre

- Flight Safety Check

- List

Aircraft and Controller

F light Battery Full Charge Controller Battery Full Charge Smart Phone battery Full Charge Payload camera battery Full ChargeTeleporter Goggle battery Full Charge

SOLO Drone Firmware Latest Firmware version installed
SOLO Application Software Latest A pplication software installed Propellers Secur e ly attached, positions confirmed Smart Phone Settings GPS Location Services ON, Bat Full charge
SOLO WiFi WiFi connection confirmed

Payload
GoPro Firmware Latest Firmware Version installed
GoPro Camera WiFi Confirm WiFi mode OFF GoPro Camera Orientation Setting auto orientation setting ON GoPro resolution setting Set to desired resolution
HDMI cable Connected
GoPro Record ON, red light flashing Teleporter FPV camera Mounted securely, clear of prop s Teleporter FPV camera Tx Antenna Mounted securely, clear of props Teleporter FPV camera memory card Installed Teleporter FPV camera Record ON, red light flashing

Operational Area

Operational Altitude Setting Confirm Application altitude setting <= 400 Ft AGL

Operational area / Airspace > 5 nautical miles from airport reference point (ARP) Identify Obstacles Confirm area clear for VLOS for PIC and VO
Area clear of non

- participating observers clear 500 ft radius PIC and VO positions Confirm VO an d PIC within verbal range Operating Documents Confirm Accessible by PIC or VO

UAV Home Position clear 500 ft radius, private or controlled

access property
UAV Return Home altitude Confirm sufficient to clear obstacles Weather Report Clear for duration of Operation

Maintenance Manufacturers recommended Mainten ance , replacement, inspection Confirm current First Flight since replacement of a flight critical component If Yes, perform functional test flight

Start Flight
S OLO Application Launch
SOL O Drone Power ON
controller Power ON

SOLO WiFi connect to Sololink_####, password sololink
S OLO Application Click FLY SOLO, confirm video feed
Area clear of non

- participating observers clear 500 ft radiusHold FLY button Confirm rotors turning

Hold F ly button Take off to Hover

End Flight
Area clear of non

- participating observers clear 500 ft radius
Land SOLO at home location Land Propellers Rotation stopped
SOLO Drone Power OFF
Controller Power OFF SOLO Application close application

GoPro re cording Stop recording Teleport FPV Camera recording Stop recording
GoPro Power OFF Teleport FPV Camera Power OFF Teleport Goggles Power OFF

Aircraft Specifications
3DR SOLO Smart Drone manufacturers user manual is available here : http://3drobotics.com/wp

- content/uploads/2015/08/v5_09_06_15.pdf

Solo is a quad

- rotor aerial vehicle powered by the 3DR Pixhawk 2 autopilot system and APM:Co pter flight control software. Solo communicates with the controller and Solo app over the 3DR Link secure
Wi

- Fi connection.

Autopilot: 3DR Pixhawk 2 Flight code: ArduPilot Copter
Control: 3DR Solo Controller
Wireless communication: 3DR Link 1.0 Frequency: 2.4 GHz Height: 10 in. (25 cm)

Motor

- to

- motor dimension: 18 in. (26 cm) Propulsion: 880 KV motors, two clockwise rotating motors and two counterclockwise rotating motors Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm) Weight with battery: 3.3 lbs. (1.5 kg) Controller battery life: 3 hours Extended controller battery life: 6 hours Controller battery: Li

- ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery) Power: Electric (rechargeable lithium polymer battery) Battery: Lithium polymer, 5200 mAh, 14.8 Vdc

Batt ery weight: 1 lb. (.5 kg) Estimated flight time: 25 minutes* Maximum altitude: 328 ft. (100 m)Range: .5 miles** (.8 km)

Payload capacity: 1.1 lbs. (500 g) Cruise speed: 5.7 mph (2.5 m/s) Maximum speed: 55 mph (25.5 m/s) Maximum climb rate: 11 mph (5.0 m/s ) Maximum descent rate: 5.5 mph (2.5 m/s) Headwind limitation: 25 mph (11 m/s) Crosswind limitation: 25 mph (11 m/s) Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4 Full compatibility with GoPro® HERO 3+ or 4 Solo app compatibility: iOS 8.0 or later / Android 4.3 or later Operating temperature: 32° F

- 113° F (0° C

- 45° C) Operating relative humidity: 0

- 85% RH

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style, and pilot skill. Listed flight t ime applies to elevations less than 2,000 ft above sea level.

**Range varies with location, antenna orientation, background noise and multi

- path.

Additional Information
The petitioner

, Ryan Bell, is a former helicopter pilot with flight hours on military helicopters such as UH

60M , S

- 92 Helibus, and RAH

- 66 Comanche simulators. Ryan has PIC time as a private pilot in Robinson R

22 and Enstrom 280C. Ryan holds a current FAA airmen medical certificate and has passed the requisite aeronautical knowledge exam . Ryan also holds a membership in the Academy of Model Aeronautics (AMA #1082255) and is an active member in the local chapter, the Southern NH Flying Eagles RC club (#23063

- 32731). Ryan also holds a Top Secret Clearance which requires US Citizenship among other security qualification criteria applicable to the TSAs review. In addition, EVE TeleSports LLC intends to employ other FAA certified pilots such as Albert Bell, Private Pilot

- Rotorcraft, for its sUAS operations.

Privacy All flights will occur ove r private or controlled access property with the property owner’s prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. The grant of this exe mption request will provide improved safety in day operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012‐size, weight, speed, and operating capabilities, proximity to airports and populated areas and operation within vi sual line of sight as well as national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s

UAS.

Operation outside of the US

 Include a specific, direct statement request ing that the exemption apply outside the
United States and state the reason(s) why you seek this authority.EVE TeleSports requests that the FAA disallow, redact, deny and/or line item veto this portion of this

exemption request if the precedent it would e stablish is cause for delay in granting initial operations in the US under the standard established operating parameters above. If it is deemed the request for OCONUS operations requires posting to the Federal Register for review and comment EVE TeleSports requests that the FAA issue a summary grant and restrict EVE TeleSports initial operations to US only.

 If you want to be able to operate under your exemption outside the United States, you

must specifically request this in your petition and give the FAA the reason for this use.

EVE TeleSports request authorization to conduct operations outside the Uni ted States, primarily in Canada, because of the numerous natural attractions such as ski resorts, hiking venues, rivers, lakes and coastal regions that EVE TeleSports can reach in a day’s drive from its Nashua, NH headquarters.

 Before the FAA extends your exemption for use outside the United States, it will verify that the exemption would be in compliance with the Standards of the International Civil Aviation Organization (ICAO). However, a foreign country still may not allow yo u to operate in that
country

.

EVE TeleSports believes that the rules and regulations it has agreed to operate within this petition are consistent with the measures described by the ICAO’s Remotely Piloted Aircraft Systems (RPAS)
documents such as the Manu al on Remotely Piloted Aircraft Systems, Rules of the Air and Aircraft Nationality and Registration Marks. In addition, EVE TeleSports will agree to operate at or below the 200 ft AGL restriction dictated by the FAA’s blanket COA restrictions for all int ernational operations.

Conclusions / Recommendations: Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption
from the follo wing rules: 14 C.F.R. 21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to o perate commercially a small Unmanned Vehicle (55 lbs or less).

Due to the small size of the UAS and the controlled access private property area of operation described, the proposed operations will adhere to the Reform Act’s safety requirements. The approv al of this application presents no national security issues and will enhance safety by reducing risk as compared to similar operations with conventionally piloted aircraft

. The grant of the requested exemption is in the public interest due to the ability t o safely fly and inspect where larger manned aircraft are unable to

maneuver or restricted to fly below 500 ABL; and the a bility to deploy a sUAS on site of a search and
rescue with infrared and thermal imaging technology to help government and law enforce ment officials locate persons in a timely manner. In the unlikely event of an in air flight failure during operations greater than 500 foot radius from non

- participating personnel, t he sUAS low weight (less than 55 pounds) will minimize property damage com pared to a larger 4,000lbs + manned aircraft carrying theequivalent equipment. Small UAS are powered by batteries verses a combustible material such as Jet A

or other equivalent fuel carried on board jets and piston powered aircraft therefore lowering the impact
associated with combustible fuel. L ightweight unmanned aircraft such as the 3DR SOLO Smart Drone operate at slow speed s, close to the ground, and in controlled environment s and are far safer than conventional operations conducted with helicopters operating in close proximity to the ground and people.

EVE TeleSports believes that the information provided satisfies the criteria in Section 333 of the Reform Act of 2012 and citation of the Kadoo Aerial’s submission dated April 8, 2015, Section 333 E xemption #12113 granted July 22 nd , 2015, provides the necessary support for the approval of the requested summary grant 333 exemption allowing the commercial operation of the applicant’s sUAS.

EVE TeleSports believes that a level of safety equivalent to t he current NAS standard s as well as the ICAO Remotely Piloted Aircraft Systems can be maintained when operating within the blanket COA
restrictions

, at or below the 200 ft AGL, and when the UAS is operated by the PIC in conjunction with a
VO. If it is deem ed that the request for OCONUS operations requires posting to the Federal Register for
review and comment EVE TeleSports requests that the FAA issue a summary grant for initial US operations

.