November 27, 2015 U.S. Department ofTransportation Docket Management System 1200NewJersey Ave., SE Washington, DC 20590
Re: Petition ofWV Drone Mediafor an ExemptionPursuantto Section 333 ofthe FAA Modernization and Reform Actof2012 Director: Flight Standards Service:
Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, WV Drone Media, ("Drone Media") hereby applies for anexemption from the Federal Aviation Regulations ("FARs") identified belowto allow commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of aerial photography, videography, cinematography, data collection and mapping for the motion picture, television, real estate and agriculture industries: additionally, infrastructure inspection of oil/gas lines andwildlife management.

This petition for exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying Drone Mediadocuments;
1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. FlightManual 1 (Collectively 3 and4 are referred to as "Manufacturer's Manuals")
Drone Media submitsthese supporting materials as confidential documents pursuantto 14 C.F.R. § 11.35(b), as the materials containconfidential commercial and/orproprietary informationthat Drone Mediahas not and will not share with otherrequesting parties. Additionally, these documents contain operating conditions andproceduresthat are not generally available to the public and are protected from release underthe Freedom oflnformationAct, 5 U.S.C. § 552 et. seq. 

### NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIAL AND SHALL NOT BE

1

. The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited to: opemtions and flight manuals, user guides, component maintenance manuals, pilot training manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation November 27, 2015 Page2 

### RELEASED TOTHE PUBLIC WITHOUTWRITTENAUTHORIZATION FROM THE PETITIONER.
Foryour convenience, this Petitionis organized as follows: 

### I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Photography, Videography, Cinematography, Mapping, Data Collection and Infrastructure Inspection 

### III. Relevant StatutoryAuthority IV. DroneMedia's Proposed UAS Operations MeettheRequirements of Section 333 oftheReform Act A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions Set Forth in the Operations Manuals 

### V. Regulations FromWhich Exemption is Requested A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. 

### § 91.203(a)(1) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. 

### § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual inthe Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration H. 14 C.F.R. § 91.103: Preflight Action I. 14 C.F.R. 

### § 91.109(a): Flight Instruction J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes K. 14 C.F.R. § 91.121: Altimeter Settings L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFRConditions 

### Vl. Drug andAlcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. ConclusionU.S Department ofTransportation November 27, 2015 Page 3 

### I. DESCRIPTION OF PETITIONER
Drone Media, based in Bridgeport, WV provides aerial photography, videography, cinematography and mapping for the real estate industry; data collection and inspection ofoil and gas lines as well as infrastructure inspection, crop control and wildlife management. The Company's Principal and ChiefPilot Darren P. Lannanhas been flying UAV Quadcopters as a hobby for more than one year without incident, spending hundreds ofhours flying. Upon the grant ofthe 333 Exemptionthe Company'sbusiness will specialize inproviding data collection, and inspection ofoil and gas infrastructures as well as photography and videography for the real estate industry, crop control and wildlife management. Drone Media's staffare well trained and experienced in providing support as visual observers ("VO") for the pilot in command ("PIC") in additionto any other needed on site assistance. All ofthe equipment owned by Drone Media is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. Drone Media's goal is to advise the perspective clientthat Drone Media is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. Drone Media seeks an exemption to allow for aerial photography, videography, cinematography, mapping and inspection. The contact information for Petitioner is as follows:
Darren P. Lannan WV Drone Media 4083 Brushy Fork Road Bridgeport, WV 26330 Phone: (304) 641-2011 Email: darrenlannan@hotmail.com 

### II. DESCRIPTION OF PROPOSED OPERATION
Drone Media seeks an exemptionpursuantto Section 333 ofthe Reform Act to operate DJI Phantom 2 and 3; DJI Inspire (referred to DM-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions on private property or approved location where Drone Mediahas received verifiable permissionto operate from the landowner, controller or authorizedrepresentative. The proposed UAS operations will be conducted in accordance withthe conditions and limitations ofthis Petition for Exemption and Drone Media's Operations Manuals. As detailed in Drone Media's Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-ofsight ("VLOS") ofthe operator, in uncontrolled airspace, and will occur at least 5 nm away from an airport reference point. Moreover, Drone Media's Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. 

### A. Aerial Photography, Videography, Cinematography, Mapping, Data Collection and Infrastructure InspectionU.S Department ofTransportation November 27, 2015 Page4 Drone Media seeks to use small DM-UAS for the aerial photography, videography, cinematography, mapping and data collection for the real estate, motionpicture andtelevision industries and inspection ofoil and gas pipelines and infrastructure inspection as well as crop control and wildlife management. Drone Mediahas purposefully tailored its operations to meet the requirements established by the FAAinpriorgrants ofexemption authorizing commercial use ofUAS inthe real estate industry, including:



### • 

## • • • 

### • • Pine Peaks, LLC (ExemptionNo. 12132) Jackson Family Wine (ExemptionNo. 11334) Mark Ingle (Exemption No. 11856) Thomas Johann Walker (ExemptionNo. 12719) Starnes Aviation, LLC (Exemption No. 12377) Eagle ViewAerial Imaging (Exemption No. 11790) All UAS photography and videography operations will occur onprivate property or approved location in a controlled area away from spectators and persons not involved in the recording process. In addition, the filming will be conductedbetween dawn and duskto ensure maximum safety for the public and those involved in the manipulation and operation ofthe UAS; VFR conditions, at altitudes below400' above ground level ("AGL"). As set forth below, Drone Media's operations provide an equivalent level ofsafety which is superior to performing the same work using conventional fixed-wing aircraft orhelicopters.
Small UAS video production is also safer than traditional manned aircraft performingthe same function. Videographer-inspectors also frequently need to climb rooftops, trees, orotherwise perform elevated work, whichexposes them to the risk ofdangerous falls, electrocution or other workrelated injuries. In addition, depending onthe nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk ofexposure to hazardous conditions. The use ofDM-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most othertypes ofinspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operationspresentrisks associated with vehicles weighing tens ofthousands ofpounds (including payload) and carrying large amounts offuel whichinherently presents significant fire hazards as well as exposure to other chemical contaminates. Itis important to note the use of small UAS inthis area will not only be safer and more cost effective to the perspective user or purchaser ofthe service, butthe quality and expanse ofacquired information will be far more robust given the low cost associated with its acquisition and otherpotential consumers an inexpensiveproduct. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greaterprecision and duration at a very low cost. Small UASs will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible orhighly dangerous using conventional aircraft orother inspection methods.U.S Department ofTransportation November 27, 2015 Page 5 

### III. RELEVANT STATUTORYAUTHORITY
This Petition for Exemption is submittedpursuantto Section 333(a) through (c) ofthe FAA Modernization and Reform Act of2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 33 3 ofthe Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate 

### in the National Airspace Systems ("NAS") where it is safe to do so based on the following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS within the visual line ofsight ofthe operator. Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is inthe public interest. See 49 U.S.C. § 106(±) (defining the authority ofthe Administrator); 49 U.S.C. §44701(±) (permitting exemptions from§§ 44701(a), (b) and §§ 44702-44716, et seq.). A party requesting anexemptionmust explainthe reasons why the exemption: (1) would benefitthe public as a whole, and (2) would not adversely affect safety (or how it would provide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. DRONE MEDIA'S PROPOSED DM-UAS OPERATIONSMEET THE REQUIREMENTS OF SECTION 333 OFTHE REFORMACT
The small DM-UAS operationsproposedby Drone Media as noted above in this Petition for Exemption qualify for expedited approval pursuantto Section 333 ofthe Reform Act as each of the statutory criteria and relevant factors are satisfied. 

### A. Approval is WarrantedBased on the UAS's Size, Weight, Speed, and Operational Capability
A GrantofExemption is appropriate for operations conductedusing the UASs due to their size weight, speed, and operational capability.

• The DM-UAS utilized by Drone Media has been approved for use in prior Section 333 Grants ofExemption from the FAA.2

• The DM-UAS weighs less than 55 pounds, including payload

• The DM-UAS will not be flown at a ground speed in excess of50 knots. The exemptionholder may use either groundspeed orcalibrated airspeed to determine compliance with the 50 knot speed restriction.

2See e.g., Grant ofExemption to Mark Ingle (Exemption No. 11856); Grant ofExemption Thomas Johann Walker (Exemption No. 12719); Grant ofExemption to Starnes Aviation, LLC (Exemption No. 12377).U.S Department ofTransportation November 27,2015 Page6

• Altitude information will be generated by equipment onboardthe UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combinationthereof. This information will be transmitted to the pilot via telemetric data feed.

• The DM-UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. Ifconnection to the remote control orground control station is lost, failsafe systems will permit the UASs to return to a predetermined location and safely land without injury ordamage.

• The radio frequencies used for operations and control ofthe DM-UAS comply withthe Federal Communications Commission ("FCC") and otherappropriate government oversight agency requirements. The operating frequency for the DMUAS is 2.4 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending onpayload. The difference in weightbetweenthe DMUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event ofan unintended accident or incident. In addition, the risk to the onboardpilot and cameraoperator is eliminated. 

### B. Approval is Warranted Based on the Operational Restrictions Set Forth in Drone Media's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected DM-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Drone Media'sproposed operations, below is a summary ofoperational limitations and conditions that Drone Mediawill adhere to, and which will ensure anequivalent orhigher level ofsafety to operations conducted under currentregulatory guidelines:
1. The DM-UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted overprivate or controlled-accessproperty with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UAS operatedunder the Grant ofExemption will be identified by serial number, registered in accordance with 14 CFRpart47, and have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings will be as large as practicable. 4. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe DM-UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct the mission.U.S Department ofTransportation November 27, 2015 Page 7 5. PICs shall possess either a private, recreational, or sport pilot certificate. The PIC must also hold a currentFAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his orherpilot certificate.
6. The DM-UAS shall be operated within VLOS ofthe PIC and Observer at all times. The PIC mustuse human vision unaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issued medical certificate.
7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging ortexting will notbe permitted during flight operations.
9. The additional requirements identified in the Grant ofExemption shall be added to the Drone Media's Operations Manuals. The Operations Manuals will be maintained and made available to the Administratoruponrequest. Ifa discrepancy exists betweenthe conditions and limitations 

### inthe Grant ofExemption and Drone Media's Operations Manuals, the conditions and limitations in the Grant ofExemption shall take precedence and must be followed. Otherwise, Drone Media shall follow the procedures outlined intheir Operations Manuals. 10. Drone Media may update orrevise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to the Administrator uponrequest. Drone Media will also present anupdated andrevised Operations Manuals ifit petitions for extension or amendment to its Grant ofExemption. Ifan update or revisionwould affect the basis upon which the FAA grants the exemption, Drone Media will seek an amendment to its Grant ofExemption. Drone Mediawill contact the FAA'sUAS Integration Office (AFS-80) ifquestions arise regarding updates or revisions to the operating documents. 11. Drone Media Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the DM-UAS is operating.
12. The PIC is prohibited from beginning a DM-UAS flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly to the first intendedpoint of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes.
13. Maximumtotal flight time for each operational flight using the DM-UAS will be limitedto 40 minutes orthe amount oftime the UAS canbe flown and still maintain a reserve battery power ofno lessthan 25%, whichever occurs first.
14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enter navigable controlled airspace withouttimely prior written authorization and approval from the FAA. Inthe event the structure being inspected exceeds 400 feetU.S Department ofTransportation November 27, 2015 Page 8 AGL, the UAS will notbe operated more than 100 feet above the highestpoint on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons otherthanthe PIC, VO, operator trainees oressential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris inthe event ofan accident. The operator must ensure that nonparticipating personsremain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearerto the PIC, VO, operatortrainees oressential persons do not present anundue hazard to those persons per§ 91.119(a).
16. The DM-UAS may notbe 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.
17. The DM-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the Drone Media COA. The letter ofagreement withthe airportmanagement will be made available to the Administratorupon request. 18. Priorto each test flight the PIC shall inspect the DM-UAS to confirm that itis in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, orequipment, not already covered in the relevant sections ofthe operating documents as well as equipment updates. The PIC shall not operate any DM-UAS ifthe inspectionreveals a conditionthat affects the safe operation ofthe DM-UAS until the necessary maintenance has beenperformed and the DM-UAS is found to be in a condition for safe flight. The ground control station shallbe included in the preflightinspection. All maintenance and alternations mustbe properly documented inthe UAS records as required by Drone Media's Operations Manuals. 19. Drone Media will timely carry out its maintenance, inspections, and record keeping requirements in accordance withthe Operations Manuals. Maintenance, inspection, and alterations will be fully noted inthe DM-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized personreturning the DM-UAS to service. 20. Any DM-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component) must timely undergo a functional test flight in accordance with Drone Media'sU.S Department ofTransportation November 27, 2015 Page9 Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and DM-UAS record entry shall be included in the Drone Media's Operations Manuals. 21. The DM-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins andproductupdates.
22. Priorto the operation, a Mission Packet will be created in accordance with the requirements on Drone Media's Operations Manuals.
23. Drone Media will obtain an AirTraffic Organization ("ATO") issued Certificate of Waiver orAuthorization, otherwise known as a COA, priorto conducting any operations underthis Grant ofExemption. A NOT AMwill be issued as required by the COA. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. Ifthe DM-UAS loses communication with the PIC, it will have the capability to safely returnto a pre-determined location withinthe operational area and land safely.
26. Contingency plans will be inplace to safely terminate flight ifthere is a loss of communication between the PIC and the Observer.
27. The DM-UAS will have the capability to safely abort flight in the case ofunpredicted obstacles oremergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued within the United States 29. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraftpilot and at least 10 hours logged as a UAS pilot with a similar DM-UAS type platform. This requirement canbe achieved by flights conducted and logged as a hobbyist. 30. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51(b), a minimum ofhours pursuantto 54 CFR 

### § 61.51(b) as UAS pilot operating the make and model ofDM-UAS to be utilized for operations under the exemption andthree take-offs and three landing in the preceding 90 days. 31. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted.U.S Department ofTransportation November 27, 2015 Page 10

32. The DM-UAS shall remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralightvehicles, parachute activities, parasailing activities, hang gliders, etc.).
33. DM-UAS Operations under Instrument Flight Rules, at night, orbeyond VLOS are prohibited. 34. The UAS will notbe operated from an elevatedplatform unless designed and engineered specifically for such purposes and be in compliance withthe general restrictions imposed by the applicable regulations. Additionally no PIC will provide any film-flight operations while in motion from atop any elevated platform vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe DM-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED
The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 

### § 40101 ofthe Act, including UAS, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest. 3 Drone Media seeks an exemption from several interrelated provisions ofTitle 14 ofthe Code ofFederal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconducting the requested operations using DM-UAS platforms noted above. Listedbelow are: (1) the specific sections of 14 C.F.Rfor which exemption is sought, and (2) the operating procedures and safeguards that Petitionerhas established which will ensure a level ofsafety betterthan or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.203(a)(1) The FAAhas stated that no exemption is needed from this section ifa finding is made underthe Reform Actthatthe UAS selected provides an equivalent level ofsafety when comparedto aircraft normally used for the same application. These criteria are met and inpoint offact exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines that there

3 49 U.S.C. § 4470I(f) (authorizing the grant ofexemptions from requirements ofregulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716).

4 14 C.F.R § Jl.81(e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level ofsafety at least equal to that provided by the rule from which you seek exemption.

5See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).U.S Department ofTransportation November 27, 2015 Page 11

are some characteristics ofthe chosen UAS that fail to meet the requirements ofthe Reform Act, an exemption is requested. EquivalentLevelof Safety
Drone Media's use ofthe DM-UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth in the description ofproposedoperations in SectionIV (A), the DM-UAS weighs less than 55 pounds, includingpayload and will notbe flown at a ground speed in excess of50 knots. The DM-UAS is also equipped with safety features which will allow Petitionerto operate the DM-UAS safely after experiencing certain in-flightcontingencies or failures as noted below.6 7 Additionally, the DM-UAS carries neitherpilots norpassengers, carries no explosive materials orflammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in Drone Media's Operations Manuals. Operations conductedunder this exemption will be closely controlled and monitoredby the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. Drone Media will also provide the FAAwith advance notice of all operations viaNO TAMs as required by the applicable COA. In all cases, operation ofthe DM-UAS under the proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operating with an airworthiness certificate. Lastly, the DM-UASs do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboardthe DM-UAS. 8 Inaddition, no sense-and-avoid

6See e.g., Grant ofExemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DH S1000] has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation."

7See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): The DM-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The DM-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned tlight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the DM-UAS to detect a system fault while in the air and automatically fly back to its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set wind thresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight termination link- to preventa 'fly away' or other potentially dangerous situation- is available to the operator."

8See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).U.S Department ofTransportation November 27,2015 Page 12 technology is necessary for the DM-UASs because they will be operated at all times inVFR conditions and within VLOS ofthe PIC and Operator.9
B. 14 C.F.R. Part27Airworthiness Standards: Normal Category Rotorcraft
Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Drone Media's small DM-UASs would otherwise require certificationunder Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified 

### in the request for exemption from 14 C.F.R. R. Part 21, Subpart H, 

### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Drone Media seeks anexemption from the aircraft marking and identification requirements contained in 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. 

### § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthischapter.

• 14 C.F.R. 

### § 45.23(b), Markings ofthe Aircraft, states: 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 orprovisionally certificated aircraft, the operatormust also display on that aircraft near eachentrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable.

• 14 C.F.R. §45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display onthat rotorcraft horizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks required by 

### §45.23. In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10

10. FAA DocketNo. FAA-2014-0352.U.S Department ofTransportation November 27, 2015 Page 13 EquivalentLevelof Safety
All DM-UASs flown by Drone Mediawill bearN-number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11


### D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections Drone Media seeks anexemption from the maintenance inspectionrequirements contained in 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. 

### § 91.405(a) (stating that each owner or operator ofanaircraft "[s]hall have the aircraft inspected as prescribed in subpartE ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed in part43 ofthis chapter"). Anexemption from these regulations is neededbecause Part43 andthese sections onlyapply to aircraftwith an airworthiness certificate, which the VASplatforms to be operatedunderthis grant of exemption will nothave. (Emphasis added) EquivalentLevelof Safety
An equivalent level ofsafety will be achieved orexceededbecause maintenance and inspections will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Drone Media's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe DM-UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditionspotentially affecting safe operation ofthe DMUAS and no flights will occurunless, and until, all flight critical components ofthe DM-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by Drone Media's Operations Manuals, the PIC who conductsthe functional test flight will make an entry inthe DM-UAS aircraft records ofthe flight.
Drone Media's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Drone Media's Operations Manuals also include procedures to document and maintain a record ofthe DM-UAS's maintenance, preventative maintenance, alterations, status ofreplacement/overhaul componentparts, and the total time in service ofthe DM-UAS used under this Grant ofExemption. As a whole, the maintenance and inspectionprocedures required in Drone Media's Operations Manuals ensure that an equivalent orhigher level ofsafety will be achieved. 

### PILOT -IN-COMMAND OF THE UAS
E. 14 C.F.R. § 61.113: Private PilotPrivileges and Limitations

II. See, e.g., FAA Docket No. FAA-2014-0352, at 14.U.S Department ofTransportation November 27, 2015 Page 14 Drone Media seeks exemptionfrom 14 CFR § 61.113, whichrestricts privatepilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. Thepurpose ofPart 61 is to ensure thatthe skill and competency ofany PIC matches the airspace in whichthe PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. In this case, while the DM-UAS will be operated as part ofa commercial operation, they carry neitherpassengers nor cargo. Inthe Grant ofExemptionto Astraeus Aerial, the FAA determined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost andrestrictions attendant withrequiring the PIC to have a Commercial Pilot Certificate and Class III Medical Certificate.12 The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved. 

### EquivalentLevelof Safety The restrictions Drone Mediahas placed on its DM-UAS operations meet orexceedthe restrictions similarly imposed onAstraeus Aerial. Drone Mediawill operate onprivate property away from persons andproperty not involved inthe operation. Drone Media will also obtain an ATO issued COApriorto conducting any operations underthis GrantofExemption. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements. A NOT AM will also be issued as required by the applicable COA.
In additionto these flight restrictions, Drone Mediawill further ensure safe operationby requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also inthe unique aspects ofDM-UAS flight. As set forth inthe Operations Manuals, pilots will have experience not only in DM-UAS operations generally buthave logged flight time in the specific make and model used for the operationsbefore they
are permittedto participate incommercial flights onbehalfofDrone Media. The pilot qualification, training, and currency requirements inthe Operations Manuals ensure that Drone Mediapilots are competent and proficient in the DM-UAS they are operating. Drone Media's training and qualification requirements are consistent with those contained inpriorFAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency andproficiency for its pilots and will ensure at least an equivalent level ofsafety to the public. 

### OPERATING PARAMETERS OFTHE UAS
F. 14 C.F.R. 

### § 91.7(a): Civil AircraftAirworthiness Inasmuch as there will be no airworthiness certificate issued for the UASs, Drone Media seeks
an exemptionfrom 14 C.P.R.§ 91.7(a), whichrequires that a civil aircraftbe in airworthy conditionto be operated. The FAAhas statedthat no exemptionis required for 14 C.P.R.§ 91.7(a) to the extentthat the requirements ofPart 21 are waived orfound inapplicable. 13

12 Exemption No. 11062 (FAA DocketNo. FAA-2014-0352).

13 See Id. at 13-14,22.U.S Department ofTransportation November 27, 2015 Page 15 Accordingly, Petitionerrequests that the requirements for§ 91.7(a) betreated in accordance with SectionV (A), supra. G. 14 C.F.R. 

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

### § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration Title 14 C.F.R. § 91.9(b) (2) and § 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2): (b) Noperson may operate a U.S.-registered civil aircraft- (2) Forwhich an Airplane orRotorcraft FlightManual is required by§ 21.5 ofthis chapter, unless there is available inthe aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under § 91.715 is displayed at the cabin orcockpit entrance so that it is legible to passengers or crew. Giventhe small size and configuration ofthe DM-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals onboardthe DM-UAS because there is simply no room and the DM-UAS has no cabin or cockpit. Asa way to comply withthe code Drone Media will maintain the documents with the PIC and make them available for inspection. EquivalentLevelof Safety
In an FAA Office ofChiefCounsel's Opinion dated August 8, 2014, andprepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledged thatthe intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from whichhe or she is operatingthe aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilothas access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS.

14 Memorandum from Mark Bury, FAA Assistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also DocketNo. FAA-2014-0352 at 16-18.U.S Department ofTransportation November 27, 2015 Page 16 H. 14 C.F.R. 

### § 91.103: Preflight Action Drone Media seeks an exemption from 14 C.F.R. 

### § 91.103, whichrequires a PIC to become familiar with specific informationbefore each flight, including information contained in the FAA-approved Flight Manual onboard the aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extentthat an FAA-approved FlightManual is required. EquivalentLevelof Safety
An equivalent level ofsafety will be providedby following the Drone Media's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects orinoperable components in accordance withthe Drone Media's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flightprocedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoffdistance, UAperformance data, and contingency landing areas-before initiation of flight. Drone Media's Operations Manuals and the Manufacturer's Manual will be kept atthe ground control station and will be accessible to the PIC at all times while operatingthe UAS.
I. 14 C.F.R. § 91.109(a): Flight Instruction
Drone Media seeks an exemption from 14 C.F.R. §91.109(a), whichprovides in pertinentpart that "[n]o 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." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplishedthroughthe use ofa device that communicates with the aircraftviaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. §91.109(a). EquivalentLevelof Safety Given the size and speed ofthe UAS that Drone Mediaintends to use, an equivalent level ofsafe training can still be performed without dual controls because no pilot orpassengers are aboard the UAS, and as required by the Drone Media's Operations Manuals, all persons will be a safe distance away inthe eventthat the UAS experiences any difficulties during flight instruction. Moreover, as required by the Drone Media's Operations Manuals, all flight training will be conducted incontrolled and sterile environment. As a whole, the safety proceduresprovided for in Drone Media's Operations Manuals ensure that the proposed UAS operationsprovide an equivalent orhigher level ofsafety thanthat provided by the flight instructionregulations.
J. 14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes
Drone Mediarequests an exemptionfrom the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not

15 Relieffrom § 9l.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event ofa failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant ofExemption No. 11157 to Slugwear, Inc., dba Like on atree Aerial (FAA-2014-0534 at 15).U.S DepartmentofTransportation November 27, 2015 Page 17 operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. 

### § 91.119(c). Section 91.119(d) allows for a helicopterto operate at less than those minimum altitudes when it canbe operated "without hazard to persons orproperty onthe surface," providedthat "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."
Anexemption is required becausethe proposed DM-UAS operation will normally needto occur below400 feet AGL. In circumstances where the DM-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the DM-UAS will not be operated more than 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the DM-UAS. EquivalentLevelof Safety Comparedto flight operations withrotorcraft weighing far more thanthe maximum weights proposed herein, and giventhe lack offlammable fuel withthe above noted UASs, any risk associated with these operations is far less than those whichpresently exist with conventional aircraft. Anequivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe DM-UAS, as well as the controlled location where the operations will occur. In orderto avoid any riskto manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highestpointonthat structure and 50 feet horizontally ofthe structure.
As set forth inthe Operations Manuals, the DM-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless that person is in a position where he orshe is shielded from the DM-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe DM-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controllertimely has granted permission and the PIC has made a safety assessment oftherisk ofoperating closerto those objects and, operations nearthe PIC or Observerwill not present an undue hazard per 

### § 91.119(a). Adherence to these restrictions in Drone Media's OperationsManuals will ensure operations can be conducted without compromisingpublic safety. 16

16See e.g., Grant ofExemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are present that can sufficiently protect nonparticipating persons from the UA ordebris in the event ofan accident, then the UA may operate closerthan 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determines that it does not present an undue hazard."U.S Department ofTransportation November 27,2015 Page 18 

### K. 14 C.F.R. § 91.121: Altimeter Settings
Drone Media seeks an exemption from 14 C.F.R. § 91.121, whichrequires a person operating an aircraftto maintain cruising altitude or flight level by reference to an altimeterthat is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extent thatthe UASs do not have a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety The FAAhas stated that an equivalentlevel ofsafety to the requirements of 14 C.F.R. §91.121 can be achieved incircumstances where: (1) the UASs will be operated below400 feet AGL or below17

, (2) within VLOS, (3) where GPS based altitude information is relayed inreal time to the operator at a ground-based on-screen display and, (4) where prior to eachflight, a zero altitude initiation point is established for the PIC to confirm accuracy ofthe onboard GPS. 18
The DM-UAS that Drone Media intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Drone Media's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass priorto each flight operation. Like prior FAA Section 333 Grants ofExemption, the DM-UAS Drone Media intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemptionto the requirements of § 191.121 is therefore appropriate. 

### L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
Drone Mediarequests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFRconditions. Section 91.151 states: (a) Noperson may begin a flight in an airplane under VFRconditions 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 afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Here, the technological limitations onUAS battery powermeans that no meaningful flight operations canbe conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. 

### § 91.151(a) is therefore required. Moreover, it is not Drone Media's intentionto fly the DM-UASs at night. EquivalentLevelof Safety

17 Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure.

18See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21 ).U.S Department ofTransportation November 27, 2015 Page 19
In the Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight in VFR conditions couldbe achieved by prohibiting the PIC from beginning a DM-UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intended point oflanding and, assuming normal cruising speed, to fly afterthat for at least 10 minutes. Inreaching this conclusion, the FAA consideredthatthe UAS batteries for the DM-UAS provide approximately 50 minutes ofpowered flight (with payload) and provided battery level and battery time remaining in minutes and seconds to the PIC. 19 The FAA also considered the fact the DM-UAS operating manual states: "startevery flight with a fully chargedbattery in the aerial vehicle", and that in the eventthat the DM-UAS should run low on power, the PIC will be alerted and can safely land the- DM-UAS as soon as possible. Like the VDOS Grant ofExemption, Drone Media'suse ofthe DM-UAS, combined withthe requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety can be achieved and in fact exceeded. Similarly, inthe Grant ofExemption to Alan Purwin (Exemption No. 11161), the FAA determined that anequivalent level ofsafety to the fuel requirements for flight inVFR conditions couldbe achieved by prohibiting the PIC from beginning a flight withthe UA unless (considering wind and forecast weather conditions), there was enoughpowerto safely fly at normal cruising speed to the intended landing point and land the UAwith 25%battery power remaining. Drone Media will adhere to this limitation for its DM-UAS flights.
The DM-UAS includes a low battery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the DM-UAS to a ground-based-on-screen display. 20 As required by Drone Media's Operations Manuals, the PIC will promptly fly the DM-UAS back to the home launch location orpredetermined abort location where it may safely land, while still maintaining a minimum of25% reserve battery power. Drone Media submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined withthe requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, andwithin VLOS ofthe PIC and Observer(s), ensure thatthe proposed operation will provide an equivalent orhigher level ofsafety to the public to that providedby the regulations from which exemption is sought. 

### VI. DRUG AND ALCOHOL PROGRAM Drone Media will have policies in place to ensure that no person may participate in DM-UAS flight operations ifthey are underthe influence ofalcohol orany drug. 

### VII. PUBLIC INTEREST

19. Grant ofExemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 20. The DM-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and orientation relative to the UAS.U.S Department ofTransportation November 27, 2015 Page 20 Thepublic interest will be servedby granting Drone Media'sPetitionfor Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemptionhelps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act-the FAA Administrator's assessment ofwhether certain UAS may operate safely in the NAS before completion ofthe statutorily required rulemaking. The proposed DM-UAS operations inthis Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whompermission was granted for use by Petitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be in the local vicinity. Traditional methods ofproviding surveillance and modeling services requires locationpersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped to perform, which exposes them to unnecessary risk of serious physical injury from dangerous falls orotherphysical mishaps. Moreover, inspectors/surveyors are oftenunnecessarily exposedto hazardous conditions, unsafe environments, culturally tense situations and otherhazards associated with identifying specific locations for potential recording sites to be used in the end product. The use ofsmall UASs can eliminate these hazards and ultimately create a much safer method ofperformingthese types of inspections creating a safer environment for the public as well as Drone Media employees.
The use ofsmall UAS also enhances safety and reduces riskto the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in additionto flammable fuel, the UASs carry no passengers, crew orexplosive fuel. Furthermore, inthe unlikely event of an accident, Drone Media's small battery poweredDM-UAS presents significantly less danger to persons onthe ground when comparedto operations by conventional manned aircraft? 1 As Petitioner's DM-UAS are battery powered, the public will also benefitfrom a reduction in harmful petroleumbased emissions associated with conventional aircraft performing inthe same functions proposedherein. Airquality will naturally be improved with the reduction offuel powered vehicles. Lastly, as recognized by the FAA in prior Section 333 Grants ofExemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplementsthe current capabilities offered by manned aircraft. 22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide additionaljobs as the cost of providing the neededproduct is greatly reduced while reducing the difficulty with whichthe

21 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event ofan incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation."

22 See e.g., Grant ofExemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation November 27,2015 Page 21 finished product is created. The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibility ofproduction; therefore, giventhe lower cost, owner/operators and others in the relevant industry will be more inclinedto utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All DM-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate orcontrolled-access property with permission from the land owner/controller orauthorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY Pursuantto 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: Petitioner seeks an exemption from the following rules in Title 14 ofthe Code ofFederal Regulations:
Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a) (1) & (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or other methods. 

### X. CONCLUSION Drone Media's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas; operation within VLOS and national security. The proposed DM-UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger while loweringthe attendant related costs thereby increasing the demand for the finished product. In consideration ofthe foregoing, this Petition for Exemption provides the FAA with more than adequatejustificationfor granting the requested exemptions allowing Drone Mediato use small DM-UAS inthe recorded production ofits product.
We thankyou for yourprompt consideration ofour requested exemptions. 

# Res£sJ)l--

Darren P. Lannan WV Drone Media 4083 Brushy Fork Road Bridgeport, WV 26330U.S Department ofTransportation November27, 2015 Page 22 Phone: (304) 641-2011 Email: darrenlannan@hotmail.com (The following attached items containproprietary and commercial information exempt from disclosure under the Freedom oflnformation Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)). Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals