# Delta Media Corporation

3501 NW Evangeline THWY Carencro, LA. 70520



### July 13, 2015

Matthew LeBlanc
Delta Media Corporation
3501 NW Evangeline THWY
Carencro, LA. 70520

Dear Sir or Madam
We are requesting that Delta Media Corporation be exempted from the Federal Aviation Regulations
listed below so that Delta Media Corporation may integrate small unmanned aircraft commercially in
airspace regulated by the Federal Aviation Administration as long as operations are conducted within
the conditions established by the FAA as required by section 333. The exemptions are proposed for
the use of a DJI Inspire 1 (Model T600).

Reasons why granting the request would be in the public interest

- Aerial video/photography or live video feed to assist with search and rescue
operations in cases of an emergency if requested by local or government authorities
by contract or donation

- Gathering overhead footage for both public and private interests for

Television broadcast purposes

- An exemption would give Delta Media the ability to provide a more competitive level of

video production allowing local merchants in our marketplace to compete with larger
marketplaces, thereby stimulating our local economy

- An exemption would allow Delta Media to compete against the current un-exempted UAS

services in the area. This would cut down on flights by others that currently have no safety
protocol in place, thereby protecting the public from more “at risk” flights.Specifications of UAS

Weight (Battery Included) 2935g (6.47lbs) Hovering Accuracy (Gps Mode)

Vertical: 0.5 m

Horizontal: 2.5 m Max Ascent Speed
5 m/s Max Descent Speed
4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude

4500 m Max Wind Speed Resistance
10 m/s Max Flight Time Approximately 18 minutes

Motor Model

DJI 3510 Propeller Model

DJI 1345 Operating Temperature Range
-10° to 40° C Diagonal Distance

559 to 581 mm
Dimensions

438x451x301 mm

Additional Information, Views, or Arguments

Louisiana is a destination state for motion picture, documentary, and reality television due to current
state tax credits. Exemptions would allow Delta Media to legally compete in an already competitive
production environment. Furthermore, the overall purpose of our states tax credits is to boost
Louisiana's economy. Allowing Delta Media to provide UAS services would stifle the need to have
these types of services brought in from outside areas and thus would keep the stimulus within our

own economy.

Many of our current loyal clients are fending off proposals from amateur, un-exempted UAS pilots in
order to continue their production relationship with us. This means that their competitors, who are
accepting proposals, are afforded the opportunity to have an unfair advantage. They are patiently
awaiting our news of exemption.

Charles Chatelain (owner), is an experienced and proven Television and Radio broadcaster, HAM
operator, and Licensed Pilot. His company Delta Media Corporation has provided Television and
Radio production services to south central Louisiana for over 35 years.

To date, Delta Media Corporation has rejected all offers for commercial UAS use in order to comply
with any applicable FAA regulation. We have had many requests for aerial photography/
videography, and are very aware that these UAS’s services are currently being provided in our area
by amateurs without exemption. We understand that the FAA has been inundated with numerous
exemption requests, as are we with requests for UAS services. We will not provide these serviceswithout exemption, but we respectfully request exemption so that we can legally compete in our
marketplace.

Delta Media Corporations exemption request would permit it’s operation of lightweight unmanned
(remotely controlled in line of sight) in a controlled and limited airspace.

Commercial operation of a UAS would be conducted in the following manner

- Pre Flight inspection will be conducted by both the PIC and VO, and all repairs and
maintenance will be handled by qualified personnel

- Two persons will operate the UAS at all times. The flight operator (PIC) will be a
licensed pilot and will be assisted by a Visual Observer (VO).

- Flights will be operated within line of sight of the PIC and VO

- Flights will only be conducted during daylight hours

- The PIC and VO will be able to communicate by voice at all times

- All flights will be conducted at an altitude of no more than 200 feet

- Flights will be conducted no closer than a 5 mile radius of the geographic center
(ARP) of an airport.

- If necessary to conduct operations within a 5 mile radius of ARP the respective
airport will be notified of flight time, flight duration, and elevation of flight

- The operator will obtain verbal/written consent of all persons involved with the
planned operation and ensure that only consenting persons will be allowed within
100 feet of the flight operation

- If the UAS loses communications with the remote controller or GPS signal, the UAS
will have the capability to return to a pre-determined location and land
autonomously

- The UAS will have the ability to abort a flight in case of unpredictable obstacles,
weather, or emergencies

Exemptions requested from the following regulations

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

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

The UAS to be operated hereunder is less than 6.5 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.



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

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

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”



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

**in Command.**Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. The applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have a Commercial Pilot’s License along with a current Second Class or higher Medical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b)

.



## 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.



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

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.



## 14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including but not limited to reviewing weather, flight battery requirements, landing and takeo ff distances and aircraft performance data before initiation of flight.



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

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 200 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 200 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 2 00 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property
owner or local o ffi cials. Because of the advance notice to the property owner and participants in the filming activity, all a ff ected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section

91.119.



## 14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.



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

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable.Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property

owners or o ffi cial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.



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

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft 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.

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

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



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

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

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 2 00 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.

Sincerely yours,

Matthew A LeBlanc