August 19 , 2015

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

- 140 1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulat ions from 14 CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407

INTRODUCTION

Pursuant to Section 333 of the FAA Modernizations and Reform Act of 20 12 and 14 CFR Part 11, Larry Welk

, operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for KNBC, KTLA, and various other news outlets for the purpose of electronic ne ws gathering in Los Angeles, CA. Additional operations to include closed set filming for the movie and television industry, and data acquisition. Larry Welk hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of sUASs under the conditi ons outlined here or modified by the FAA. Larry Welk submits supporting material in this application as confidential documents pursuant to 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and proprietary information that Larry Welk ha s not and

will not share with others.

In the detailed explanation to follow, the series of exemptions being requested would allow operation of the commercially procured, DJI S1000, an eight engine and blade, light weight, relatively slow (<50 knots) unman ned rotary aircraft (or like platform), and an Intuitive Aerial Aerigon IAH3 an twelve engine and blade, light weight relatively slow (<50 knots) unmanned rotary aircraft (or like platform), in and around the city of Los Angeles during active news, traffic and weather events using very controlled conditions and operational procedures to provide robust safety buffers both vertically and horizontally to ensure personnel and property safety. These flights would only fly within

200 feet of the control vehicle w ith a dismounted pilot and safety team using an auto

pilot system that would control speed, vectoring and hovering. At no time would the vehicle fly directly over locally assembled c rowds or over any ongoing fires. The launch and recovery point would be co rdoned off by the safety team in coordination with law enforcement and/or first response units. Approval of this exemption would help to prove the safe concept of UAS activity while conducting electronic news gather (ENG) during active news, weather or tra ffic events in a major metropolitan environment with safety controls to provide proactive risk management that is technically within the NationalAirspace System, but realistically segregated well below any other air traffic and well clear of the Los Angel es International Class B airspace (beneath the lateral confines).

To date, the FAA has granted an exemption for ENG operations to Arrow Data, LLC

, Aerigon IAH3 airframe approval to Vision Pictures LLC, and closed set filming approval

to Team 5 LLC

.

The f ollowing is contact information for the applicant:

Larry Welk III

12653 Osborne St. #6

Los Angeles, CA 91331

1 (818)625

- 1320

EXMEPTIONS (Regulations from which exemption is requested)

• 14 CFR Part 21, Subpart H

- Airworthiness Certificates

• 14 CFR 45.23 (b)

,,

o Aircraft Marking

o Certification and Registration

• 14 CFR 61.113 (a) & (b)

o Pilot in Command

• 14 CFR 91.7 (a)

o Civil aircraft airworthiness

• 14 CFR 91.9 (b) (2)

o Document/Flight Manual

• 14 CFR 91.103 (b)

o Preflight Action

• 14 CFR 109

o Flight Instruction

• 14 CFR 91.1 13o Right

- of

- way rules

• 14 CFR 91.119

o Minimum safe altitude

• 14 CFR 91.121

o Altimeter setting

• 14 CFR 91.131 (a) (1) (c) (2) (d) (1)

o Operations in class B airspace

• 14 CFR 91.151

o Fuel requirements for VFR flight

• 14 CFR 91.203 (a) & (b)

o Civil Aircraft: Certificat ions required

• 14 CFR 91.405 (a) (1); 409 (a); 417 (a) &(b)

o Maintenance and maintenance inspections

• 14 CFR 407

o Operation after Maintenance, preventative maintenance, rebuilding, and inspections

• 14 CFR 409

o Inspections

• 14 CFR 417

o Maintenance records

• NOTAM 9/ 5151, NOTAM 4/3621

o Flying around sporting events

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFETY

Section 333 refers to exemptions for sUASs for commercial operations. Those operations could include a vast array of events such as electronic news gathe ring (ENG). Much like the movie industry, aerial news and traffic/weather information gathering is both useful and entertaining to the general public. The quick deployment and less restrictive weather constraints will create a safer environment, while deli vering a superior and timelierproduct to the general public, providing near real time information for traffic, severe

weather and crime scene avoidance considerations. The sUAS aircraft to be employed by Larry Welk

, has a number of safety features t hat make it ideal for use in this environment. The state of the art DJI S1000 with single 22,000 mAh, 22.2 volt battery technology and the ability to fly with two engines inoperable. The Intuitive Aerial Aerigon with a triple 10,000 mAh or 16,000 mAh, 22.2 volt battery technology and the ability to fly with 4 engines inoperable. Both UAS are well under 55 pounds with a top speed of approximately 40 knots. Additionally, there is redundancy in the power system to the data link, motherboard, and wireless

commu nications within the sUAS team operating the system. The mobile vehicle to be used with the UAS is already fitted with redundant power sources for satellite and camera operations and would be available to the UAS safety team as well. The aircraft would be employed utilizing Visual Line

- of Sight (VLOS) operations not to exceed 200 feet vertically and launched from a sterile area created upon arrival at the news event by the safety team in coordination with local law enforcement and first responders. Any vert ical obstructions would be noted upon arrival and the pilot and safety team would ensure operations remained well clear of those obstructions. The pilot would launch the aircraft and navigate to an acceptably safe hover point at which time a waypoint would be designated and the auto

- pilot would be engaged in an auto

- hover mode while filming

commences. A loss of communication “return to base” fail

- safe system is integrated as well. The battery life is approximately 30 minutes with a planned flight time of no t more
than 15 minutes. Larry Welk

, will file a FAA Form 7711

- 1 or any such form deemed appropriate with the local Flight Standards District Office. Additionally, an Operations Plan would be submitted on a mutually agreed periodical basis to the FSDO.

All sUAS pilots being employed by Larry Welk

, for this mission will have a FAA Private Pilot Certificate and a second class FAA medical certificate with additional experience in unmanned aircraft operations. The team composition will consist of a mi nimum of one pilot, one camera operator and one safety observer during all mobile news events, giving redundancy to the human element as well. Pilots will be well trained in areas of both normal and abnormal operations equipped with checklists and operatio ns and maintenance manuals to be able to contend with any scenario. After extensive range testing and pilot training, the sUAS team will perform “dry

- runs” to simulate and practice actual news events and situations. To help prepare for actual flight and n ews gathering with a UAS, the team would deploy with the mobile news team and observe conditions and scenarios where future operations might take place. This would give the team a feel for the “cadence” of an active news event to allow them to be able to p lan timing and coordination issues. Unlike other uses for sUASs, these flights would be mostly shorter in length, obviating the need for a backup pilot. The designated safety observer would help to provide greater situational awareness for the team in orde r maintain alertness and vigil at all times. An environmental assessment will be performed to measure such parameters

as noise and hazardous material concerns.

Additionally, Larry Welk proposes that the exemption requested apply to civil

aircraft that ha ve the characteristics and that operate with the limitations listed. These limitations provide for at least an equivalent or even higher level of safety to operationsunder the current regulatory structure because the proposed operations represent a safety enhancement to the already safe aerial photography and closed set aerial filming for movie and television filming operations conducted with conventional aircraft.

These limitations and conditions to which Larry Welk agrees to be bound when conducting com mercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to

the 30 minute limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Minimum crew for each operation will consist of the sUAS Pilot and the Visu al

Observer. 6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s

certificate and third class medical. 7. sUAS Pilot assume all duties and responsibilities as Pilot in Command (PIC). 8. The sUAS will only operate within a confined “Sterile Area”. Security will be performed by the operator and designated security personnel. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s production activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 10. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting persons will be allowed within 100 feet o f the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination. With the advanced permission of the relevant FSDO, operations at closer range can be approved. 11. When required, the operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot. 12. Pilot and observer will have been trained in operation of UAS generally and received up

- to

- date information on the particular UAS to be operated.

13. ALL crew members will at all times be able to communicate by ONLY voice

communications as to ensure all crew members maintain a visual contact with the

UAS at ALL TIME. 14. Written and/or oral permission from the relevant property holders will be

obtained. 15. All requi red permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 16. If the sUAS loses communications or loses its GPS signal, the UAS wi ll have capability to return to a pre

- determined location within the Security Perimeter and

land. 17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.UAS Crew Requirements:

UAS Pilot in Command must:

1. Hold at least a FAA Private Pilot with current 3 rd class medical

2. Have a minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least 10 hours as a sUAS pilot with a similar sUAS type (single blade or multirotor);

a min imum of 5 hours as sUAS pilot with the make and model of sUAS to be utilized for operations under the exemption and 3 take offs and landings in the preceding 90 days;

3. Received training in the safe operation of the UAS to be operated. Training will include :

a. Normal and emergency modes of operation

b. Familiarization with the operation manual published by

the UAS manufacturer.

c. Types of maneuvers to be performed during operations including safe operation in relation to persons, property and applicable airspace using the actual UAS or

manufacturers simulation software

Camera Operator must:

1. Become familiar with the operation manual published by the UAS

manufacturer.

2. Receive training in the safe operation of the systems operated onboard the UAS. Training will i nclude:

a. Proper method of loading, rigging, or attaching the camera mount, lighting, and any external equipment

b. Types of maneuvers to be performed during operations

c. Safe operation in relation to persons, property and applicable airspace.

d. Receive trainin g on basic VFR weather minimums

outlined in 14 CFR 91.155

In a dual control configuration, the Camera Operator will not operate the master

controller.

Visual Observer must:

1. Be familiar with the use of VHF / FM radio communication.

2. Have received traini ng on the National Airspace System 14 CFR 71 and

the basic VFR weather minimums outlined in 14 C.F.R. 91.155.

The Plan of ActivitiesThe Plan of Activities must include the following:

1. Dates and times for all flights;

2. Name and phone number of the person responsible for the photography / filming event;

3. Name and phone number of the person responsible for the aircraft;

4. Make, model and serial number and/or registration number of all UAS t to be used;

5. Name and certificate number, if applicable, of all crewmem bers to be utilized in the event including copies of FAA Medical Certificates and endorsements;

6. A statement that the Waiver Holder has obtained permission from property owners and/or local governmental officials to conduct the event;

7. Signature of Waiver H older or representative;

8. A description of the flight activity including maps or diagrams of any area, city, town, county, and/or State over which filming will be conducted and the minimum altitudes essential to accomplish the operation.

Briefing

Larry W elk or his appointed event representative will conduct a verbal and written briefing for the members involved, including emergency, if applicable, and security personnel. This briefing will be conducted prior to each day ’ s UAS activities and will

include the follow ing items.

1. Authorization UAS flight operations, Plan of Activities, special provisions and any additional provisions issued by the Flight Standards District Office having jurisdiction over the photo / filming area.

2. Radio communications.

3. Takeoff pr ocedures.

4. Aviation activities to be conducted during the event.

5. Approach and landing procedures.

6. Alternate landing zone in the event of emergency or security breach.

7. Recall procedures.

8. Emergency procedures.

9. Possible risk to personnel that are involved.

10. Con trol of non

- participating persons.

11. Location of boundaries or deadlines, man

- made or natural, readily visible to the participants. 13. Local governmental limitations, restrictions, or any special circumstances, such as noise sensitive areas, time of day res trictions or changes in operating procedures.

SecurityThe exclusion from the flight operations area of unauthorized persons, vehicles or aircraft will be enforced by designated event personnel, private security officers or sworn

law enforcement officers at the direction of Larry Welk

. Larry Welk or his designated representative will halt flight operations in the event unauthorized persons, vehicles or aircraft enter the flight operations area. A predetermined abort signal will be used to halt flight ope rations should a breach of perimeter security occur, or for any other reason in the interest of safety. Alternate UAS landing sites will be made available prior to the start of the event.

14 CFR Part 21, Subpart H

– Airworthiness Certificates 14 CFR 91.20 3 (a) (1)

Subpart H (Airworthiness Certificates) defines the requirements for airworthiness certificate issuance IAW FAR 91.203 (a) (1). Existing law (49 USC 44701 (f)), Part 11 and Section 333 allow the FAA to exempt aircraft from the requirements of a n airworthiness certificate upon consideration of the size, weight, speed, operational capability and proximity to airports and populated areas of the identified sUAS. Unlike a manned helicopter, the sUAS being employed is lightweight, has no flammable fue l or other lubricants, operates at very slow speeds and stays well below any conflicting air traffic thereby providing, an equivalent level of safety when compared to currently employed manned aircraft.

The proposed sUAS to be employed is under 55 lbs. when outfitted with all equipment and batteries. There are no flammable liquids or other hazardous materials that would propose a danger to the public or event participants. Accordingly, no threat to national security exists due to the inability of carriag e of any external stores or ordnance and the exhaustive vetting of team personnel. All activities will be closely monitored by a team of aviation professionals and using a system with redundancies in all areas.

14 CFR 45.23 (b) Display of Marks; general

CFR 45.23 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 or provisionally certificated aircraft, the operator must also disp lay 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.

An exempti on to this section is needed due to the lack of a cabin, cockpit or pilot station where any reference to the term “Experimental” could be affixed. Accordingly, the wording will be placed on the fuselage. This equivalent level of safety will allow the

team to clearly see “Experimental.” Previous precedence exists within Exemptions 10700, 10167, and 10167A.CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command

CFR 61.113 (a) & (b) states:

(a) Except as provided in paragraphs ( b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in comm and of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

To reach an equivalent level of safety, the self

- imposed experience and training requirements would more than offset any risk introduced by using private pilots to fly an

unmanned aircraft in v ery restricted and controlled areas.

CFR 91.7 (a) Civil aircraft worthiness

CFR 91.7 (a) states:

No person may operate a civil aircraft unless it is in an airworthy condition.

Assuming no airworthiness certificate will be required due to relief f rom Subpart H, no regulatory standard exists for determining airworthiness. The equivalent level of safety will be achieved through the employment of the manufacturers flight manual and maintenance manual procedures, pilot training and analytical risk mana gement for each

event.

CFR 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft

CFR 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

th is 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.

Given the size of the sUAS being utilized in this endeavor, ther e is no room onboard for an aircraft flight manual.The equivalent level of safety will be achieved by keeping the flight manual with the pilot/team on the ground with easy access. Previous precedence is resident in Exemptions 8607, 8737, f8738, 9299, 9 299A, 9565, 9565B, 10167, 10167A, 10602, f32827, and 10700.

CFR 91.103 (b) Preflight action

CFR 91.103 (b) states:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This in formation must include

—

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff a nd landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

This regulation dictates that a pilot conduct preflight activities. Without an FAA approved flight manual, relief is requ ired from this regulation. Extensive pre

- flight planning will provide an equivalent level of safety by using the operations plan, aircraft flight manual, maintenance manual and available weather and NOTAM information.

CFR 91.109 Flight instruction

CFR 91.109 states:

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.

sUASs clearly have no onboard flight controls. An equivalent lev el of safety will be accomplished by conducting pilot training via the control system that communicates with the aircraft from the ground.

CFR 91.113 Right

- of

- way rules: Except water operations.

CFR 91.113 deals with the many scenarios whereby differen t types of aircraft in different states must give way to other aircraft.Because the sUAS PIC does not have “see and avoid” capability, the petitioner requests relief from this regulation. All operations will be within V LOS of the pilot and

well below a ny airspace where other flight activity is taking place.

CFR 91.119 (d) (1) Minimum safe altitudes; general

CFR 91.119 states:

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to pe rsons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed f or helicopters by the FAA.

Recognizing that this relief is unprecedented, the petitioner asks that the FAA recognize the inherent capability of the Larry Welk

, we feel that an acceptable level of safety can be achieved. Extensive range testing and additional on

- site testing in a benign

environment would be conducted in real or near

- real time conditions. The current altitude

and/or horizontal restrictions on rotorcraft assumes a much heavier manned aircraft loaded with fuel and possible external stor es. The light

- weight sUAS being proposed for use in this activity along with its precise guidance and redundant systems create an entirely different paradigm that should be considered by regulatory bodies.

The activities being proposed by this petitione r are in a very controlled and open area. The flights would be confined to the immediate area of the mobile control center (MCC). Given these considerations, Larry Welk

, proposes allowing flights to operate no
more than 300 feet from the MCC and well clear of the Class B airspace and attendant

manned air traffic.

CFR 91.121 Altimeter settings

CFR 91.121 states:

Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by referenc e to an altimeter that is set, when operating

—

Below 18,000 feet MSL, to

—

The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

The sUAS aircraft intended for this activity will not be e quipped with a barometric altimeter. Instead it will incorporate radio altimetry via the onboard GPS. Anequivalent level of safety will be achieved through use of the operations and maintenance manuals governing altitude control. A preflight calibration o f launch site altitude will be accomplished.

CFR 91.131 (a) (1) (c) (2) & (d) (1) Operations in Class B airspace

CFR 91.131 states:

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in compliance with § 91. 129 and the following rules:

(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.

(c) Communications and navigation equipment requirements. Unless otherwis e authorized by ATC, no person may operate an aircraft within a Class B airspace area unless that aircraft is equipped with

—

(2) For all operations. An operable two

- way radio capable of communications with ATC on appropriate frequencies for that Class B airspace area.

(d) Other equipment requirements. No person may operate an aircraft in a Class B airspace area unless the aircraft is equipped with

—

(1) The applicable operating transponder and automatic altitude reporting equipment specified in § 91 .215 (a) , except as provided in § 91.215 (e) , and

Much of the city of Los Angeles lies within the limits of the Class B airspace, or various other controlled airspace. Because the planned sUAS to be employed lacks an onboard transponder or two way commu nication capability, relief from this regulation is required. An equivalent level of safety will be achieved by limiting the operating ceiling of the sUAS to altitudes well below any conflicting manned aircraft traffic (no higher than 200 feet). This assur es de

- confliction with all other traffic and specifically traffic within the Class B airspace. Additionally, the sUAS will remain clear of the Los Angeles International Class B airspace at all times. Larry Welk

, will periodically report to the

FSDO on operations and risk management issues.

CFR 91.145 (b) Management of aircraft operations in the vicinity of aerial demonstrations and major sporting events.

CFR 91.145 states:In deciding whether a temporary flight restriction is necessary for an ae rial demonstration or major sporting event not listed in paragraph (a) of this section, the FAA considers the following factors:

(1) Area where the event will be held. (2) Effect flight restrictions will have on known aircraft operations. (3) Any existi ng ATC airspace traffic management restrictions. (4) Estimated duration of the event. (5) Degree of public interest. (6) Number of spectators. (7) Provisions for spectator safety. (8) Number and types of participating aircraft. (9) Use of mixed high and lo w performance aircraft. (10) Impact on non

- participating aircraft. (11) Weather minimums. (12) Emergency procedures that will be in effect.

If KNBC, or KTLA , or various other news outlets intends to use the sUAS to cover sporting events from the outside of the activity, coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of any other unmanned activities. Flight activity will be conducted using the same operations plan as with any other ENG activity with part icular attention to the avoidance of over flight of large concentrations of people. All of the concerns in the above twelve subparagraphs have been or will be addressed in other portions of this exemption application. However, specific relief from this reg ulation is still necessary to ensure compliance with FARs.

CFR 91.151 (b) Fuel requirements for flight in VFR conditions.

CFR 91.151(b) states:

No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecas t 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 batteries t hat power the DJI S100 and Intuitive Aerial Aerigon have a m ission

li fe of approximately 30 minutes. To meet the 20 minute reserve requirement, the

airborne mission woul d be limited to approximately 10 minutes. Given the limitation of the proposed flight area during any ENG, a more liberal flight time is a reasonable

reques t. The aircraft would never be further than 150 feet from the recovery area, literally representing seconds to land. In no case would the aircra ft be operated with less than 20 % battery life remaining.No night time operations are currently planned.

C FR 91.203 (a) & (b) Civil Aircraft: Certifications required

CFR 91.203 (a) & (b) states:

(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. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under § 21.197(c) of this chapter, appropriate sections of the air carrier ma nual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21.197(c)

, or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter . However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identifica tion number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31(c) , or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragrap h (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 sUAS to be employed has no cockpit or pilot and therefore has no ability to

carr y onboard any certification or registration documentation.

The equivalent level of safety will be achieved by keeping these documents with the pilot/team on the ground at the event. Previous precedence is resident in Exemptions 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A and 10700.

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 417 (a) & (b) Maintenance

These CFRs state: Each owner or operator of an aircraft

— (a) 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 ;

Operation after maintenance, preventive maintenance, rebuilding, or alteration.(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter; and

(2) The maintenance record entry requ ired by § 43.9 or § 43.11 , as applicable, of this chapter has been made.

Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—

(2) An inspection for the issu ance of an airworthiness certificate in accordance with part 21 of this chapter

.

operator shall keep the following records for the periods specified in paragraph (b) of this

section:

(1) Records of the maintenance, preventive maintenance, and alteratio n and records of the

100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance

of an aircraft. The records must include

—

(i) A de scription (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for

return to service.

(2 ) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspectio n program under which the aircraft and its appliances

are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number andrevision d ate. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a) (1) of this section shall be retained until the work is repeated or superseded by ot her work or for 1 year after the work is performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered own er or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.

These FARs only concern aircraft with an airworthiness certificate and therefore would not apply in this sit uation. All maintenance and inspections will be conducted IAW the maintenance manual and operations manual. The ability for an almost immediate safe recovery and landing if a malfunction occurs and the multi engine configuration with the ability to fly wit h loss of thrust on 2 engines provides a comfortable operating envelope and ensures an equivalent level of safety.

The reasons why granting Larry Welk

, request would be in the public interest; that is, how it would benefit the public as a whole:

Granting the exemption to Larry Welk

, would allow the public to safely view breaking news from a dynamic and unprecedented aerial perspective. Larry Welk has created a unique way to view news events that benefits the general public socially and economically. Larry Welk

, sets the industry standard in using purpose built Small Unmanned Aircraft Systems (sUAS) with multiple redundant features that enhance safety. Larry Welk

, operates its DJI S1000 and Intuitive Aerial Aerigon platform wi th dual electronic motherboards and flight control systems, multi high

- capacity batteries rated between 10,000 mAh and 22 ,000 mAh each, and the ability to maintain controlled flight with the loss of 2 engines.

In addition, enhanced safety is achieved by using an unmanned aircraft that does not carry passengers or crew and does not carry flammable fuel.

IAW 14 CFR Part 11.81, the following summary is provided for publication in the Federal Register, should it be deemed necessary:Applicant seeks relie f from the following rules:

14 CFR Part 21, Subpart H

– Airworthiness Certificates, 14 CFR 45.23 (b),14 CFR 61.113, (a) & (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14

CFR 91.103 (b), 14 CFR 109, 14 CFR 91.119, 14 CFR 91.113, 14 CFR 91.121, 1 4 CFR 91.131 (a) (1) (c) (2) (d) (1), 14 CFR 91.145 (b), 14 CFR 91.151, 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b), 14 CFR 407, 14 CFR 409, 14 CFR 417,

NOTAM 9/5151

The unparalleled operational and testing capabilities created by the partnership

between Larry Welk

, and Intuitive Aerial will enable the Federal Aviation Administration to allow for the introduction of sUASs into environments not previously allowed with an acceptable level of safety. This is an opportunity to use highly dependable, multi

redundant unmanned aircraft in a major metropolitan area, but to do so with stringent controls, pervasive risk management and detailed mitigation strategies to ensure that the public is not at any time exposed to unsafe conditions. Extensive range testing, “dry

- run” testing under benign conditions and simulated emergencies will demonstrate that this activity can be accomplished without hazard to the general public. The rotorcraft being

prop osed for this operation has redundancy in every conceivable area: thrust, communications, and electrical power for both the aircraft itself and the supporting
syst em. Eight engines powered by multiple separate ba tteries power ranging between

10 ,000 mAh and 22 ,000 mAh and a data link system with “fly home” capability ensure that at no time will the aircraft not be able to land safely should that need arise. Pre

plotted waypoints using Geographic Instrument System coordinates and auto

- pilot “fly

to” commands provide extremely precise navigation. A Safety Management System will be employed and will address such issues as environmental impact (noise and hazardous material) and coordination with local Emergency Services/Incident Management personnel to include:

• Fire fighting

• Medical Response

• Incident investigation

These capabilities, in total, provide a level of safety that should be satisfactory to the FAA and general public.

In view of the beneficial advantages to public safety, we respectfully submit our Section 333 exemption request.