William Young Synapse Film & Video, Inc.

PO Box 300414 Chicago, IL 60630

June 17, 2015

U.S. Department of Transportation Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE. Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Synapse Film & Video, Inc. hereby applies for an exemption from the Federal Aviation Regulations identified herein to allow for the commercial operation of its small unmanned aircraft system (sUAS) for the purposes of videography and photography for documentary, inspection, instructional and promotional uses , so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA).

Aerial videography has been an expensive and challenging proposition until the development of small UASs. The use of sUASs to perform these tasks increases worker and public safety, lowers costs, and saves time compared to the use of manned aircraft. These facts, among others, provide a significant and definitive public benefit and are in the public interest.

Conditions for sUAS operation as described in this application are consistent with and based upon proposed FAA sUAS regulations as outlined by the FAA on the 15 th of February, 2015.

Synapse Film & Video, Inc. contends that this application satisfies the conditions and criteria set forth in Section 333 of the Reform Act, that the operations described herein benefit the public interest as a whole in many ways and that the use of sUASs for aerial videography meets or exceeds the level of safety currently experienced by traditional manned aircraft utilized for these purposes. Thank you for your time and consideration in this matter

.

Respectfully yours,

William Young Vice President, Synapse Film & Video, Inc.

### I. Petition Summary

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub.
L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), Synapse Film & Video, Inc. (“Petitioner”) hereby petitions for exemptions from 14 C.F.R. Part 21, Subpart H, 14 C.F.R§45.23(b), 14
C.F.R.§45.25, 14 C.F.R.§45.27 (a), 14 C.F.R.§45.29, 14 C.F.R § 61.113 (a) & (b) ,
14 C.F.R. § 61.133 (a), 14 C.F.R. § 91.7 (a), 14 C.F.R. § 91.9 (b)(2)&(c), 14C.F.R.
§ 91.103, 14 C.F.R. § 91.105, 14 C.F.R. § 91.109 (a), 14C.F.R.§91.119, 14 C.F.R. §
91.121, 14C.F.R.§91.151(a)(1)&(b), 14C.F.R.§91.203(a)&(b), 14 C.F.R. §§ 91.405 (a), 91.407 (a)(l), 91.409 (a)(2), 91.417 (a) & (b). The proposed exemptions, if granted, would allow Petitioner to operate small, camera-mounted unmanned aircraft systems (“UAS”) weighing 55 pounds or less for the purpose of closed-set filming and aerial photography.

Based on the small size of Petitioner’s UAS, the qualifications and experience of Petitioner’s UAS operators, and the restricted, sterile environment within which Petitioner will operate, the requested exemptions fall squarely within the zone of safety envisioned by Congress and set forth in Section 333. Additionally, the enhanced safety achieved by replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS operations enabled by the instant Petition are in the public interest. Thus, the requested exemptions should be granted.

### II. Statutory Authority for Requested **Exemptions**

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it does not create a hazard to users of the national airspace system (“NAS”) or the public or pose a threat to national security based on the following considerations:

• The size, weight, speed and operational capability;

• Operation in proximity to airports and populated areas; and

• Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. See 14 C.F.R. § 11.81.



### III. Synapse Film & Video, Inc. Background Information

Synapse Film & Video, Inc. has been dedicated to providing outstanding videography services to its clients for the past 29 years from our home in Chicago, Illinois. Providing our Fortune 500 clients with the video services they need has found us documenting from the land, water, and the sky. We serve the corporate, industrial, medical, educational, advertising and agricultural

markets.

During our 29 years of videography services, we have proudly experienced a 100% safe operating record. We emphasize the importance of safety with our staff and crew. When using camera cars, cranes and aircraft mounted cameras on a set with many crew members, safety is the first priority. This dedication to safe operations will continue with our newest capability, UA videography.

Dwight Irwin, President of Synapse Film & Video is an award winning cinematographer with over 30 years of experience in the film and video industry.

William Young, Vice President of Synapse Film & Video is an award winning producer, videographer and editor with over 35 years of experience in the film and video industry.**Protocols and Controls**

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre-flight preparation and during flight.

**Pre-Flight Protocol:**

1. Check batteries with voltage meter to insure fully charged and ready for use.

2. Inspect batteries for damage or leakage that may affect proper operation.

3. Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageable/ uncontrolled flight.

4. Check weather forecasts for wind advisory or other conditions that may impact flight.

5. Consult five (5) mile radius map for airport vicinity.

6. Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information.

7. Inspect flight area for : -vicinity of public safety helipads/heliports -vicinity of medical helipads/heliports -vicinity of light poles -vicinity or utility wires -vicinity of trees -flocks of birds that may cause interference and potential flight impact -vicinity of any elevated obstructions that may pose potential flight hazard -vicinity of roadways with moderate to heavy traffic that can be distracted - public gatherings that may attract viewers - optional point of control for best visual site of UAS while in flight

**Takeoff and landing Protocol:**

1. Inspect area for best and safest point of takeoff and landing

2. If in a subdivision or area that is within 150 feet of a residential street, post warning sign(s): “Attention Aerial Photography In Progress - Remain Back 150 Feet "

**Flight Protocol:**

1. Takeoff and land from same location

2. Remain alert to birds, sound or aircraft, curious public, and approaching vehicles

3. Do not allow anyone to engage in conversation or distract the remote control pilot

4. Restrict flight to minimal elevation sufficient to acquire desired results

5. Remained prepared for emergency landing at all times \

6. Pay attention to flight time

. 7. If possible set a timer as a safety alert

. 8. Land UAS and shut down propulsion immediately following landing

.

### IV. Proposed Operations

Synapse Film & Video, Inc. is requesting exemptions from the Federal Aviation Regulations (the “FARs”) stated herein pursuant to Section 333 of the Reform Act in order to perform aerial videography and photography for businesses, municipalities, charities and the agriculture industry utilizing sUASs. Corporations desire aerial photography of their facilities and the real estate industry wants aerial photography of their properties. However, the primary use would be 10-40’ altitude videography of closed-set situations.

Synapse Film & Video, Inc. will operate a DJI Inspire 1 UAS with a gimbal mounted highresolution camera. The camera system will acquire still photographs and/or video of client operation locations and environments. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 UA is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The specifications are

available in **Appendix A**

.

An sUAS also does not carry flammable fuel and does not release emissions.

The sUASs will be controlled via radio transmission from a Ground Control Station (“GCS”). All remote control equipment will be off the shelf industry standard devices available to both professionals and consumers and utilize FCC approved transmission and reception components.

The sUAS will be controlled by a pilot and a second operator will control the camera with a second remote control. The sUAS will contain a second, forward looking camera for the pilot, allowing for the camera operator to record images to the side and down without compromising the pilot’s view of flight direction. The two-operator method of aerial videography is the safest method of flight by allowing the pilot to concentrate on flying without being concerned with videography concerns.

At no time will the sUAS be operated over any non-participating persons. The flight area will be monitored by the operator and / or observers for any encroaching individuals.

Synapse Film & Video, Inc. will utilize a operator specifically trained in sUAS operations for all commercial flights. When deemed necessary by Synapse Film & Video, Inc. an observer will be utilized for added visual coverage. They may also utilize a camera operator via remote video

feed.

The observer will be in voice contact with the operators at all times during flight via either direct contact, radio or equivalent methods, depending on the optimal observer position as determined by operator and observer. The observer, when used, will assist the operator in identifying both air and ground hazards and maintaining safe operating conditions. The flight will be altered or terminated immediately should a hazard such as a low flying aircraft or unauthorized person in the flight area be observed by either the operator or observer.

Additionally, the sUAS will not be operated over non-participating persons. It will remain a minimum of 50 feet from all non-power distribution structures and will not operate higher than

250 feet AGL.Predetermined potential landing zones will be identified and briefed by the operator, observers and participating persons prior to flight. Landing zones will be selected according to proximity to obstructions, observed ground conditions and limited exposure to persons and property.

**Operating Conditions and Limitations**

All operations will be conducted according to and in compliance with the following conditions

and limitations.

(A) All sUASs utilized will weigh less than 55 lb.. (25 kg). (B) The aircraft will remain within visual line-of-sight (“VLOS”) of the operator and/or visual observer(s) at all times using vision unaided by any device with the exception of corrective

lenses. (C) A visual observer (“VO”) may be utilized to satisfy the VLOS and observation requirements

as defined herein. (D) The aircraft will not operate over non-participating persons. (E) Flight operations will be conducted only between the period of official sunrise and sunset as defined in the Aeronautical Information Manual (AIM). (F) The sUAS will yield right-of-way to other aircraft, manned or unmanned. If there isa risk of a collision, the operator will immediately maneuver away. (G) Prior to flight, the sUAS operator will assess weather conditions using FAA approved weather sources and direct weather observation, will check airspace restrictions and TFRs and will assess the location of people and property to lessen risks if he or she loses control of

the sUAS. (H) Flight operations will be conducted only with flight visibilities at or exceeding 3 statute

miles. (I) The sUAS will not be operated in airport flight paths, restricted airspace, or areas under current Temporary Flight Restrictions (TFRs). (J) The operator will discontinue the flight when continuing would pose a hazard to other aircraft, people or property. (K) The sUAS will not exceed an airspeed of 87knots(100mph). (L) The sUAS will not be operated at an altitude exceeding 500 feet above ground level(“AGL”). (M) Operations will not be conducted in Class A airspace. ( N) ATC permission will be obtained prior to operations in Class B, Class C, Class D or Class E airspace. (O) The operator / observer(s) will operate / observe only one sUAS at a time. (P) A thorough preflight of the sUAS will be conducted by the designated operator in command (“OIC”) prior to the first flight of the day or after any suspected or observed anomalies or damage. (Q) The OIC will follow the suggested preflight actions as outlined in the sUAS operator’s

manual. (R) The operator will not operate an sUAS should he or she know or has any reason to know of any physical or mental condition that would interfere with their safe operation of the aircraft. (S) The sUAS will not be operated in a careless or reckless manner.

**Operator Certification and Requirements** 

All Synapse Film & Video, Inc. operators will abide by the following conditions and requirements.(A) All operators will be trained on the specific sUAS aircraft and have a minimum of 100 hours of safe operation in a controlled environment before operating in a commercial environment

.

(B) All operators will be 18 years of age or older. (C) Operators or a designated Synapse Film & Video, Inc. official will make available to the
FAA, upon request, the sUAS for inspection or testing. (D) Operators or a designated Synapse Film & Video, Inc. official will maintain a log of flights as practicable for future currency or flight logging requirements. (E) An operator or a designated Synapse Film & Video, Inc. official will report an accident to the FAA within 10 days of any operation that results in damage to property, other than the aircraft, estimated to exceed $25,000 for repair (including materials and labor) or fair market value in the event of total loss, whichever is less and/or results in significant injury or death. (F) sUAS Registration, Markings and Requirements

All Synapse Film & Video, Inc.’s s UASs will be registered and marked according to the following conditions and requirements.

(A) All sUASs to be operated by Synapse Film & Video, Inc. will be maintained in condition

for safe operation.

(B) The UASs will be inspected prior to flight by the OIC to ensure that it is in a condition for

safe operation.

(C) All s UASs to be operated by Synapse Film & Video, Inc. for commercial operations will be registered with the FAA.

(D) All sUASs to be operated by Synapse Film & Video, Inc. for commercial operations will

be marked with an aircraft registration number according to 14 C.F.R. Part 45 or in the largest practicable manner taking into account the size and configuration of the aircraft. See Section VI, subsections B, C, D and E in this document.



### V. Public Benefit and Public **Interest**

Currently, aerial videography is performed via helicopter or, occasionally, via fixed-winged aircraft. The aircraft are typically flown at low altitude and in relative close proximity to structures. The use of an sUAS rather than a manned aircraft in such applications will further the public interest in several areas

.

The DJI Inspire 1 UA is battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA

does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAs (weighing approximately 6 pounds 7.5 ounces at it’s maximum gross weight with a length of 17.3 inches

, width of 17.7 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like Synapse Film & Video, Inc. , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Synapse Film & Video, Inc., can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

### VI. Discussion of Requested FAR Exemptions

Synapse Film & Video, Inc. seeks an exemption from the following regulations including provisions of Part 21, 45, 61 and 91 for the purposes of aerial videography described herein. Presented here are the specific FAR sections for which exemption is requested and the methods and safeguards by which Synapse Film & Video, Inc. will ensure a level of safety equivalent to exceeding the regulations from which exemption is sought. See 14 C.F.R. § 11.81(e).

**A. 14 C.F.R. Part 21, SubpartH–Airworthiness certificates.** Section 91.203(a)(1) requires civil aircraft to have “an appropriate and current airworthiness certificate.” Part 21, Subpart H (“Airworthiness Certificates”) establishes the procedural requirements and applicability for the issuance of air worthiness certificates as directed by 14 C.F.R. § 91.203(a)(1).

**Equivalent level of safety:** The sUASs operated will be have a gross weight less than 55 lbs. and will be flown at speeds less than 87 knots (100 mph). They do not carry a pilot or passengers, do not carry flammable fuels and will be operated in well-defined locations using an operator and, if deemed required by Synapse Film & Video, Inc. a visual observer(s). All operations will be conducted in compliance with the limitations and conditions stated in this petition for exemption. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement of an airworthiness certificate upon consideration of the sUASs’ size, weight, speed, operational capability and proximity to airports and populated areas.

The characteristics and conditions under which the sUASs will be operated, as outlined in this petition, given the size, weight, speed, operation capability and proximity to airports and populated areas, achieve or exceed the equivalent level of safety over a manned aircraft with an airworthiness certificate used for the purposes outlined in this petition. The FAA will have advance notice of all operations through the filing of Certificates of Waiver or Authorizations (COA) and, if deemed required by the FAA, the filing of Notices to Airman (NOTAMS) not more than 72 hours, but not less than 48 hours, prior to conducting operations under this grant of exemption.

The FAA has stated that no exemption is required from this section if a finding is made under the Reform Act that an sUAS provides an equivalent level of safety when compared to aircraft normally used for the same application. See granted exemptions 11138, 11062, 11067, 11080,

11114 and 11112.

**B. 14 C.F.R § 45.23(b)–Display of marks; general**

.

Regulation 14 C.F.R. § 45.32 (b) states: “...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 more than 6 inches high, the words ‘limited,’ ‘restricted,’ ‘light-sport,’ ‘experimental,’ or ‘provisional,’ as applicable.”**Equivalent level of safety:** These sUAS does not have a “cabin, cockpit or pilot station entrance” therefore the required marks cannot be displayed “near each entrance.” Additionally, letters not less than 2 inches nor more than 6 inches may not be practical given the small size of the sUAS. If the sUAS is too small to display markings in the size described in regulation § 45.23 (b), then markings will be displayed in the largest practicable manner.

**C. 14 C.F.R. § 45.25–Location of marks on fixed winged aircraft.** 

Regulation 14 C.F.R. 45.25 describes the marking requirements on fixed winged aircraft. It states that the aircraft, “...must display the required marks on either the vertical tail surfaces or the sides of the fuselage...”. It continues to describe the specific locations on which marks may be displayed.

**Equivalent level of safety:** An sUAS does not carry a pilot or passengers, does not have a cabin and may have a design that is significantly different from traditional manned aircraft. As such, the markings requirements of 14 C.F.R. § 45.25 may not be feasible given the design and layout of the aircraft. To provide an equivalent level of safety, the sUAS will display required markings on conspicuous locations of the aircraft.

**D. 14 C.F.R. § 45.27(a)–Location of marks; non fixed-wing aircraft.** 

Regulation 14 C.F.R. 45.27 (a) states: “Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23.”

**Equivalent level of safety:** An sUAS does not carry a pilot or passengers, does not have a cabin and may have a design that is significantly different than traditional manned aircraft. As such, the markings requirements of 14 C.F.R. § 45.25 may not be feasible given the design and layout of the aircraft. To provide an equivalent level of safety, the sUAS will display required markings on conspicuous locations of the aircraft.

**E. 14 C.F.R. § 45.29–Size of marks.** 

Regulation 14 C.F.R. 45.29 describes the required size of marks and the characteristic of lettering for aircraft. In many cases it dictates that marks must be at least 12 inches high.

**Equivalent level of safety:** An sUAS is, by definition, significantly smaller and may have a design and layout significantly different than traditional manned aircraft. As such, the size and layout of markings as stated in 14 C.F.R. § 45.29 may not be feasible due to the inherent characteristics of sUASs. To provide an equivalent level of safety, the sUAS will display required markings on conspicuous locations of the aircraft. If the aircraft is too small to display markings in standard size, then the aircraft will display markings in the largest practicable

manner.

**F. 14 C.F.R § 61.113 (a) & (b) and 14 C.F.R. § 61.133 (a) - Private pilot privileges and limitations; pilot in command; commercial pilot privileges and limitations.** 

Regulation 14 C.F.R. § 61.113 restricts private pilots from flying aircraft for compensation or hire and would require a second class medical certificate. Regulation 14 C.F.R. § 61.133 requires a pilot to hold a commercial pilot’s license when acting as pilot in command of an aircraft usedfor compensation or hire. This is intended to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if the pilot is carry passengers or cargo for hire.

**Equivalent level of safety:** Synapse Film & Video, Inc. sUASs will be operated as part of a commercial operation, however they do not carry passengers or cargo. Additionally, they remainbelow 500 feet AGL, are operated at less than 87 knots (100 mph), will not be operated over nonparticipating individuals, are under 55 lbs and do not carry flammable fuel. In FAA Docket No. FAA-2014-0352, the FAA determined that sUAS operations did not warrant the additional cost and restrictions imposed by requiring the operator to have a commercial pilot certificate and class

II medical certificate.

Synapse Film & Video, Inc.’s operators will attend sUAS specific training either at a third party location or through a custom designed in-house program specifically tailored to Synapse Film & Video, Inc. ’s operations, sUASs and operating environment. This program will be developed using input and guidance from currently operating sUAS training programs and will follow industry standard processes and procedures. The program will consist of industry standard ground based and hands on training in a controlled flight environment.

Using these processes, procedures and restrictions, the level of safety of sUAS operations for the uses as outlined herein is equivalent to or significantly exceed those as regulated by §61.113 and §61.133.

**G. 14 C.F.R. § 91.7 (a) – Civil aircraft airworthiness.**

The regulations states: “No person may operate a civil aircraft unless it is in airworthy

condition.”

**Equivalent level of safety:** The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Synapse Film & Video, Inc. requests that the requirements for § 91.7 be treated in accordance with FAR Part 21 Subpart H. Additionally, Synapse Film & Video, Inc. operators will inspect the aircraft prior to flight in order to ensure it is in a condition that is safe for flight. See granted exemption 11062.

**H. 14 C.F.R. § 91.9(b)(2)&(c)–Approved flight manual in the aircraft.** 

Regulation 14 C.F.R. § 91.9 (b)(2) states: “No person may operate a U.S.-registered civil aircraft ... 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.”

Regulation 14 C.F.R. § 91.9 (c) states: “No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.”

**Equivalent level of safety:** Synapse Film & Video, Inc. requests an exemption from this regulation in part as outlined in the request for exemption from regulation 14 C.F.R. § 91.203 (a) and (b). An equivalent level of safety will be achieved by maintaining the proper documentation at the location of the Ground Control Station readily available to the operator. This includes the sUAS operation manual as provided by the manufacturer or equivalent documents as created by Synapse Film & Video, Inc.Additionally, the FAA, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the operator during flight. The Chief Counsel’s Office has held that for all

UAS operations, this alternate method constitutes full compliance with the regulations. See granted exemption 11062.

**I. 14 C.F.R. § 91.103–Pre flight action.** 

14 C.F.R. § 91.103 requires the PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft.

**Equivalent level of safety:** The sUAS does not have a Flight Manual on board because of its inherent design and lack of on board pilot. The operator will review information prior to flight to maintain the safety of the operation, including but not limited to, the weather, battery levels, landing and takeoff distances and aircraft performance data. The operator will refer to the manufacturer supplied sUAS manual for technical data and information as provided. The manual will be kept at the ground station during operations.

The FAA has stated that no exemption is required (see Grant of Exemption No. 11062, p. 20) however, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

**J. 14 C.F.R. § 91.105 - Flight crew members at stations.** 

This section contains requirements for crew members during takeoff and landing of the aircraft. The regulation requires crew members to be at the crew member’s station unless absence is necessary to perform their duties. It also requires crew members to keep safety belt(s), including their shoulder harness if so equipped, fastened.

sUASs do not carry pilots or passengers and therefore do not have a “crew member station.” However sUASs do have a Ground Control Station from which an operator controls the aircraft via radio signals. The Ground Control Station may be at a fixed location or may be movable. However, because it is not a physical part of the aircraft, the Ground Control Station may not have a seat(s) and does not utilize safety belts.

Visual observers, when deemed necessary by Synapse Film & Video, Inc., may be at various locations in the vicinity of the flight operations area in order to provide the best line of sight view of the sUAS during flight. The visual observers may or may not be at a fixed location and may or may not utilize a seat. The seat will not be equipped with safety belts.

**Equivalent level of safety:** The sUAS operator will remain at the Ground Control Station where the control of the aircraft takes place for the duration of the flight. Visual observers, when deemed necessary by Synapse Film & Video, Inc., will be positioned in the flight operations area according to the operator’s determination of the optimal viewing area given the planned flight. The use of safety belts is not feasible because the crew member stations are not physically a part

of the aircraft and are not in motion.**K. 14 C.F.R. § 91.109 (a) – Flight instruction.**

14 C.F.R. § 91.109 (a) states that, “No person my operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.” sUASs do not have functioning dual controls by design. They are piloted using a Flight Control System / Ground Control Station that communicates with the aircraft via radio signals.

**Equivalent level of safety:** During flight instruction, there are no pilots or passengers on the

aircraft and the Ground Control Station will be a safe distance from the aircraft. The aircraft will remain a safe distance from non-participating individuals causing no safety hazard.

Given the size and speed of the sUAS, an equivalent level of safe training can be performed without dual controls because no pilot or passengers are aboard the aircraft and it is a safe distance from the public and structures.

The FAA has previously approved exemptions for flight training without dual controls for a number of aircraft. See Granted Exemptions: 11109, 11138 and 11110.

**L. 14 C.F.R. § 91.119–Minimum safe altitudes.** 

14 C.F.R. § 91.119 prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure. The nature of the operations described herein may require operation in relatively close proximity to buildings and people . However, operations will not be conducted over non-participating individuals.

**Equivalent level of safety:** The sUASs operated by Synapse Film & Video, Inc. are far smaller than manned aircraft, such as rotorcraft and fixed winged aircraft, used for similar operations. Additionally, the sUASs do not carry a pilot or passengers, weigh less than 55 lbs., do not carryflammable fuel, will not exceed 87 knots (100 mph) and will not be operated over nonparticipating persons. The sUASs will be operated below 500 feet AGL with the use of an operator and, if determined to be required by Synapse Film & Video, Inc. , a visual observer(s) to avoid risk to aircraft, persons and property. This provides an equivalent or greater level of safety than achieved with conventional aircraft currently performing similar operations.

See Granted Exemptions: 4063, 11138, 11136, 11112, 11110, 11109, 11080, 11066, 11063, 11062

and 11067.

**M. 14 C.F.R. § 91.121 – Altimeter settings.**

14 C.F.R. § 91.121 requires an aircraft to be operated by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure when operating below 18,000 feel MSL. Some sUAS contain a barometric pressure sensor. Others utilize GPS sensors to determine altitude. Typically barometric pressure sensors are corrected to the point of takeoff; not a departure airport.

**Equivalent level of safety:** The operator will confirm the elevation of the launch site prior to launch. This will be compared to the GPS sensor or barometric sensor derived altitude asdisplayed on the sUAS telemetry reading at the Ground Control Station. The operator will then determine the maximum permissible altitude to maintain flight below 500 feet AGL and will not exceed this altitude. The maximum permissible altitude will also be monitored and estimated by visual means through the use of the operator and / or visual observer(s) as a secondary backup to sUAS telemetry data. This provides a level a safety equal to or exceeding the regulation.

See Granted Exemptions: 11153, 11150, 11138, 11136 and 11159.

**N. 14 C.F.R. § 91.151(a)(1)&(b)–Fuel requirements for flight in VFR conditions.** 

14 C.F.R. § 91.151 (a) (1) states: “No person may begin 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...”

14 C.F.R. § 91.151 (b) states: “No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20

minutes.”

The sUAS will be operated only during daylight hours in VFR conditions. The technical limitations of most sUASs limit total flight time to approximately 30 minutes before the battery is depleted. This means that no meaningful flight time would be possible given the limitations of § 91.151 (a) (1) and (b).

**Equivalent level of safety:** The sUAS flight will be terminated with at least 20% reserve power. This allows the sUAS to return to its landing zone with adequate power remaining to conduct a safe and controlled landing. Given the sUAS’s size, weight and speed, the sUAS when operated with this limitation provides an equivalent or greater level of safety than manned aircraft represented by this regulation.

See Granted Exemptions: 2689F, 5745, 10673, 10808, 11138, 11136, 11112, 10650 and 10159.

**O. 14 C.F.R. § 91.203(a)&(b)–Carry civil aircraft certification and registration.** 

The regulation states: (a) “...no person may operate a civil aircraft unless it has ... an appropriate and current airworthiness certificate.” Furthermore: (b) “No person may operate a civil aircraft unless 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.”

**Equivalent level of safety:** In regard to 14 C.F.R. § 91.203 Part (a), an equivalent level of safety is achieved through the methods and characteristics as outlined in the request for exemption from 14 C.F.R. Part 21, Subpart H.

In regard to 14 C.F.R. § 91.203 Part (b), the sUAS does not carry a pilot or passengers, does not have a “cabin or cockpit entrance” and does not have onboard storage in which to carry certification and registration documents. An equivalent level of safety will be achieved by maintaining the proper documentation at the Ground Control Station readily available to theoperator. The FAA has issued numerous exemptions to this regulation. See granted exemptions 9565A, 9565B, 9789, 9789A, 9797, 9797A, 9816A and 9816.

Additionally, the FAA, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the operator during flight. The Chief Counsel’s Office has held that for all

UAS operations, this alternate method constitutes full compliance with the regulations. See granted exemption 11062.

**P. 14 C.F.R. §§ 91.405 (a), 91.407 (a)(l), 91.409 (a)(2), 91.417 (a) & (b) – Maintenance inspections.** 

The regulations 14 C.F.R. §§ 91.405 (a), 91.407 (a)(1), 91.409 (a)(2) and 91.417 (a) & (b) specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. Specifically, 14 C.F.R. § 91.405 (a) requires that each owner or operator of an aircraft, “...[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspection ... have discrepancies repaired as prescribed in part 43 of this chapter.” An exemption is required from these regulations because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the sUASs will not have.

**Equivalent level of safety:** The sUASs will be maintained and inspected in accordance with the manufacturer-supplied manual. This includes maintenance, overhaul, replacement and inspection requirements for the sUASs. The operator, prior to the first flight of the day and as deemed necessary otherwise, will undertake preflight inspection procedures in order to ensure the sUAS is in a condition for safe operation. Discrepancies that may affect the safety of flight will be addressed and repaired if required. The operator, and Synapse Film & Video, Inc., will maintain the sUASs in a condition for safe operation. Given the size, characteristics and operating limitations of sUASs as described herein, this provides a level of safety equivalent to or greater than manned aircraft performing similar operations.

### APPENDIX – A

**DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**

Synapse Film & Video, Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire 1

. 2.2.1 Aircraft

2.2.1.1 Model – T600 2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle - 350 2.2.1.6 Max Ascent Speed – 5m/s 2.2.1.7 Max Descent Speed – 4m/s 2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s 2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510 2.2.1.13 Propeller Model – DJI 1345 2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 2.2.1.15

Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

. 2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3 2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range - ±0.030 2.2.2.5 Mounting – Detachable 2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

. 2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – FC350 2.2.3.3 Total Pixels – 12.76M

2.2.3.4 Effective Pixels – 12.4M 2.2.3.5 Image Max Size – 4000x3000 2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 9402.2.3.8 CMOS – Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C)

2.2.4 Transmitter 2.2.4.1 Name – C1 2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 Communicating Distance (unobstructed) – 2000m 2.2.4.4 Output Power – 9W 2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 2.2.4.6 Battery – 600mAh LiPo 2S