Mr. Donald Panarisi South Georgia Drone Training and Services 92 Lake Cove Approach Newnan GA, 30265
December 20, 2015
U. S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington DC 20590 '
.**~**

Re: FOR A SUMMARY GRANT EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART HAND SECTIONS, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.9(b)(2), 91.103, 91.119(c), 91.121,91.203 (a) and (b), 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2) AND 91.417(a) and (b) CONCERNING COMMERCIAL OPERATION OF ALL DJI PHANTOM 2 AND PHANTOM 3 MODELS, DJI S1 000, DJI S900, AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 11295)


### 1. SUMMARY
Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, South Georgia Drone Training and Services an operator of Unmanned Aircraft Systems ("UASs") for aerial data collection and flight training, hereby applies for an exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation of its UASs.
South Georgia Drone Training and Services request, as described in greater detail below, the requested exemption would permit the operation of a sUAS at or below 400 feet AGL, under controlled conditions in airspace that (1) is limited; (2) is predetermined; (3) is controlled as to access; and (4) provides safe operations. No operations will be conducted over restricted airspace or over congested areas. Approval ofthis exemption would enhance safety, promote industry growth and fair competition through increased affordability of aerial photography and videography, and would fulfill the Secretary ofTransportation's responsibilities to establish requirements for the safe operation of such aircraft systems in the NAS pursuant to Section 333 of FMRA.


### 2. INTRODUCTION
The name and address ofthe applicant is:
South Georgia Drone Training and Services Mr. Donald Panarisi 92 Lake Cove Approach Newnan GA, 30265 dapanarisi@yahoo.com

### (901 )853-6566
South Georgia Drone Training and Services objective,is to collectaeria.Ldata,and flight. demonstrations by conducting aerial ,photography and videograph¥ ino.r:der to provide high, quality digital imaging and video:content to its clients, and to, promotethesafe use ofs,UAS's by, being an educatocon the subject. More speoifically,.the purpose ofthis exemption wqulcl b,eto ·, allow South Georgia, Drone Training ,and Services to provide commercial aerialvideo and

-- , photography operationsin the following afeas: Aerial photographx and**videographyforth~** 

### advertising industry, Aerial photography and videography ofre_sidential/commercial buildings for the real estate industry, Aerial photography and videography for industrial/construction sites, Aerial photography and videography for the agricultural and farming industry, and flight -.: demonstrations to new users. Increase public knowledge ofsUAS and promote safe sUAS operations
This exemption application is expressly submitted to,fulfill Congress' goal in**~assing** 

### Section 333(a) through (c) oftiJe,Reform_Act. , . This law directs the Secretary ofTransportation to considerwhether certain unmanned ·aircraft

. systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe-Reform Act In making this determination; the Secretary is requiredto determine which types otUASs do: n.otcreate a hazard to users.ofthe

. NAS orthe public or pose a threat to national security in light ofthe following:
The UAS's size, weight, speed, and operational capability; Operation ofthe UAS in close proximity to airports and populated areas; and;Operation ofthe .IJAS witlilin visual line·ofsight of the operator.- The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as·the term iS: defined under §401 01 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have.a current airworthiness certificate, : , · e.,, 

### UASs operated by South Georgia Drone Training and Services weigh less than 55 pounds, including the payload (i.e. camera, lens, ·and:gimbal): They operate:at speeds of no more than. 50 knots, can hover, and can simultaneously move vertically and horizontally. South Georgia Drone Training and Services will only operate its UASs.in

.. lineofsightand will operate only.· within the sterile area. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system·orthe**.pubHc.~·** 

### South Georgia Drone Training and Services seeks an exemption to operate the DJI Phantom 2, DJI Phantom 2 Visiont, and all Phantom3 models, The DJI S1000, S900 an!:}DJIInspire 1 .· model UAS for compensation or hire within the NAS.
Each UAS operated by South Georgia Drone Training and Services will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and markedjn accordance with l4·C.F.R. Part 45, Identification and Registration Marking. 

### 3. BASIS· FOR PETITION
Given the small size of South Georgia Drone Training and Services 'UASs and the restricted sterile environment within which they will operate, South Georgia Drone Training and Services UAS operations adhere to the Reform Act's safety requirements. Additionally, due to the size ofthe UASs and the limited areas in which they will operate, approval ofthis application presents no national security issues. Each of South Georgia Drone Training and Services sUASs, including payload,· is**fartbelow~the:** 55 pound sU'AS classification ·requirement; and one is also below 

### tti:e 4A pound requirementdeyeloped·by-.the proposed 14 C.F.R. Part 107 that creates the**"mi'crotJAS'~:subclass** 

### -<Df·s:UAS. Based.nn-the sub'stantiallevel of safety surrounding the proposed-operations;· and <the**~ignificant** public benefit (enhanced safety), reduction in environmenta1 impacts (reduced emissions and·'noise), the grant ofthe requested exemption is in the public'interest

. .According,ly,-South Georgia-Drone Training and Services respectfully requests'thatthe FAA grant:the re(luested::exemptionwithout delay.·
Aircraft and**equ~ivalent** 

### tevet ofsafetY

..

.-

### .. -:. ..'( ,., "" ' The applicant proposes that the exemption requested apply to civil aircraft that have the characteristics and that operate with the limitations listed. These limitations provide for at least an equivalentor even higher tevet**of~**safetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the already safe aerial photography and aerial filming for movie and television filming operations conducted with conventional aircraft. ',, ,, ' ·... ' "· ' '' '

. ,, .

,,.... ',_. These limitati<l>ns andconditions to·which Sowth Georgia Drone·Training and Services·agrees to be bound when conducting commercial operations under an FAA issued exemption indude:
:**~-** The sUAS will weigh less than 55 lbs.

·" .!**~--~** .... ·t;\**~** ·,-t, .1.-';: Flights will be operated within lineofsight

..ofa:·pilotand/orobserver.

• ·:· 1 /:.

.**-~ :~:,r:J** **~** 't. Q**-~·~ ··;-~**  ,·; Maximum total flighttirne for**ea~h:operational** flightwill be.30'minutes::

..... •'**~~'** '**~**·: ; . j ' Flights will be terminated at 25% battery power reserve··should that occur prior to·the 30 minute limit. Flights will be operated at an altitude ofn6 more·than 400 feet AGL·
Minimum crew for each operation

### will corisist ofthe sUAS Pilot, the Visual Observer.

'·:; l'' sUAS pilot will be an FAA licensed airman with at·!east a private pilot's certificate and third class medical. '' 

## '' The sUAS Pilot assume all duties and responsibilities asPilot in Command (PIC).

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 ofthe safety perimeter be present for this briefing.
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 ofthe flight operation, and this radius may bereduced 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.
The operator will submit a written Plan ofActivities to the FSDO three days before the pr9posed shoot.

'
-

## ... Pilot and observerwill have been trained in operatiorr of UAS. generally and received Upto date. information on the particular UAS to be operated.
ALL crew members will at all times be able to communicate by ONLYvoice communications as ·· to ensure all crew members maintain a visual contact with the UAS at ALL TIME.

. · · · '

.. Written and/or oral permission from the relevant property holders will be obtained.
All required permissions and permits will be obtained from territorial, state, county orcity jurisdictions, including local law enforcement, fire, or other appropriate governmental agenci.es.**~** Ifthe sUAS loses communications or loses its GPS signal, the UAS,wilt have capability to returri to a predetermined location within the Security Perimeter and land.
The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.



### The Plan ofActivities
The Plan ofActivities must include the following:
Dates and times for all flights; ·**'<~.--·:'-.:'** •' • : .,..· ,:.::·· Name and phone number ofthe person responsible forthe photography 

### Ifilming event;

·-·.. ' i. f., Name and phone number ofthe person··responsible'forthe. aircraft; Make, model and serial number and/or registration number of all UAS t to be used;**~**..-. Name and certificate number, if applicable;.of all,crewmembers.to be utili.zed in the·event including copies of FAA Medical Certificates and endorsements;
A statement that the Waiver Holder has obtained permission from property owners and/or local governmental officials to conduct the event; Signature ofWaiver Holder or representative;
A description ofthe 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

### South Georgia Drone Training and Services and the event representative will conduct a verbal and written briefing for the members involved, including emergency; if applicable, andsecurity personnel. This briefing will be conducted prior to each day's UAS activities and will include the following.items,' -": · :. ·.·. ·... ,,.. 

### t".:. ·_;,_ Authorization UAS flight operations, Plan ofActivities, special provisions and any additional provisions issuedby the,Fiighl:Standards District Office having jurisdiction over the photo 

### I filming area. Radio communications:· Takeoff procedures. Aviation activities to be conducted during the event. Approach and landing: procedt:1res. Alternate landing zone in the event of emergency or security breach Recall procedures. -:; Emergency procedures. Possible risk to personnel that are involved. Control of n<Dnparticipatir'lg persons, Location of boundaries or deadlines, manmade or natural, readily visible to the participants.
Local governmental limitations, restrictions, or any special circumstances, such as noise sensitive areas, time ofday restrictions or changes in operating procedures.
Security


### The 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 South Georgia Drone Training and Services.

t '' • ·.·"':• 

### South Georgia Drone Training and Services ortheir designated representative will halt flight operations in the event unauthorized·persons,'vehicles or aircraft enterthe flight: operations area. A predetermined abort signal will be used to halt flight operations should a breach of perimeter security occur;"-or for any other reason··in the interestofsafety

.. Alternate UAS landing sites will be made available prior to the start ofthe event. Regulations from which the exemption is requested:
14 CFR Part 21 14 CFR 45.23(b) 14 CFR61.113 (a) and (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 ·;,,. ';:·14 CFR 91.151 (a) 14 CFR 91.203 {a) and (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) and (b) 

### .., ' ·-**\.~.**



### .. 3. EXTENT OF RELIEF AND REASONS SOUTH GEORGIA DRONE TRAINING and SERVICES**SEE~~** 

### REI.-IEF

. ) ,.. 14 C.F.R Part 21, Subpart 

### H:·**Airworthin~ss** C.ertificates 14 C.F.R. §91:203 (a) 

### (1). ··

..**~** - ..**~** Subpart H, entitled Airworth_iness Certificates, establishes the procedural requirements for·the issuance ofairwpr,thiness certificates 9l5 requiredby**fA~** §91.203 (a) (1}. G_iven the size and r limited operating area associated with the aircraft to be utilized by the Applicant, an exemption. from Part 21 Su.bpart 

### H meetsthe**requirement~** ofan equivalent level ofsafety underPart t1 and Section**3~3** 

### ofthe Reform Act.The Federal Avjatiqn Act (49 U.S.C.§44701 (f)) aDd Section 333 of the Reform Aqt both al!thorize the FAA to exempt airGr:aft frornthe requirement for**~n** . airworthineps certiticate, upcm,consideration

..ofJhe·size, weight, speed, oper.:ati.onal capability, •. and proximity to airports and populated areas ofthe particular UAS.**~n** all cases, a(l.analysis of · these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposecJwi!l be aHeast:as safe;· or safer,tban a conventional aircraft (fixed wing ,or rotorcraft),PP.Elf?tif:lg with an airworthiness**certificat~,** without the**res~[ictions** af1d conditio11s**propo_s~d.** 

### TI:Je**s~JAS** to be pperated-hereuncter is less than 55 lbs. fully loaded, carries neither a**piJot-no~** passenger; carries no explosive materials orr. flammable liquid**fu~ls,** anq OP;?rates exclusivelywithin a**secL~red** ar;ea as $et out·in the Manual.· Unlike other civiLaircraft,**operations:~nder** ttl.i$ exE!mption will be)ightly controlled and

. monitored by both the operator,**pur~uant** tothe Manuars requirements; ·and unQl3r-·the · .. requirements and in compliance with local_public 

### &afe_ty**r~q!Jirem~nts;** to provide securityfor the area ofoperation as is now done with conventiona!filming.1The FAAwil.l have advance notice of all operations. These safety enhancements, wh.ich already applyto civil airc;;raft operated in connection with motion picture and television produGtion, provide a greater degree ofsafetyto the public and property owners than conventional.qperc;itiom; conducted with e3irworthiness certificates issued under 14 C. F.**R,~** Part 2

### t, S.ubpart 

### 1-L.Lastly, application ofthese same criteria demonstrates that there is no credible threat to nationalsecurity posed by the UAS, due to its size, speed ofoperation, location ofoperation,,Jaokof·explosivematerials orflammable liquid. fuels, and inability to carry a substantial external load.
14 C.F.R. § 45.23 (b). Marking ofthe Aircraft· The regulation requires:

' ' ''·· 

### ... ,.,

When marks include only the Roman**capitallett?r~'N"** and the registration number is displayed· on limited, restricted or lightsport category <,:!jq:;mftor experimentalor provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station,'in letters notless tha.D-2 inches .oor more than 6 inches high, the words "limited," "restricted," "lightsport," "e,xperimental," or "provisional," as**applicabl~.** 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 ofthe sUAS, two inch lettering will be impossible. ·· The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).

### ! 

# I I 

# I The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. · 14 C.F.R. § 61._113 (a) and(b): Private_ Pilo!**_Priv~leges** and Limi!ations: Pilot in**Com~and** 'c**·-~ ~**  ' . ' ':. t •.**-~** r - iv •..\ • t ' )

.... - '

...... Sections 61.113 (a) and (b) limit private pilots to noncommercial**operations~** Because the UAS ,: will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations--by requiring**thl~f:PIC operat~ng**  the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this small UAS. Unlike a conventional aircraftthat carries the-pilot and passengers,·tne··sUAS is remotely'Controlled \vith ·no living thing on board. The area ofoperation is controlled and restricted, and all'flights are planned and coordinated'in advance as setforth.ii"l'lhe 

### Mc:friLiaL The level of safety'provide·exceeds that provided by a single· individual holding a**-corrimercia~'pHot's** certificate operating a conventional aircraft. The risks'·a·ssocJated with' the,operation dfthe sUAS. are·sodiministfed from the level 

## of risk associatedwith ·cemmercial operations contemplated'by Part·61 when draffed, that allowing oper:atic;ms ofthe .SUAS as·-req'l&ested with 

# a private pilotas·the PIG'exceeds the present level of safety achieved by:14·0.F.R. §61!11-3.(8) and(b): ··' ···· '

•1 ._ .•**~-_:,', ~:-;·r·.;_~,·r:·**  ....**:~--~~r-t' _.·~-**  14 <>F.R: §91 :?(a): Civil air:craft'air"Worthiness: ·· · The,,regulation·requires that-no' perscwrmay'0per-ate'a Civiraircraftunless ifis 'in ainlvorthy condition. Asthere'will-be·no-airWorthiness cE}rtificate' issued forthe aircraft; -should·this exemption be grahted,;·no·FAA regul'atory·-stahda'rd

# win exist for determining airiNorthiness. Given the size;ofthe:aircraft and'tiierequirements·cdhtained rn the Manufacturer's Operating Manual**formair:~tenance-and** use'of'§afety:cfleck lists priortcieach night, an,equivarent level of safety and operating -crl!teria 

## dan· be :f0untt·at

# tF-iefollowing links: Requested•exemptionAircraft Operatriig l;Jsefls 

## Manuars**http,//www.,ctjl.cbm/produd/phantom3/downt6aa~** http:/lw\Nw.dji.com/productlphantom27-d6Whloacf''· · ,. http:I/www.dji.com/procfUctlinspire1/downl0ad- 

### r·. " .·. · , http://www.dji.com/productlspread'ingwinlgss900Ydbwnload http;//www.dji.com/product!spreadingWfngss1:oooplus/download
14 G.F.R. 

### § 91-.9 (b) {2)dSivH AircraftFlight Mahliat iii 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 ofthis chapter, unless there is available in the aircraft a curre'ntapprovecf airplane or Rotorcraft Fligt:lt Manual, approved manual material, markings, and platah:ts:, 'or**an~t·combination** thereof.



### .**~.** ' . '(_' '
..**~** ·( . ' ' The sUAS, given its size and configuration has n6 abi:lit'y 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 atthe ground control pointwhere the pilot flying the sUAS will have immediate access to it. The FAA hasissued the following exemptions to this regulation: Exemption Nos. 86Q7, 8737, 8738, 9299, 9299A, 9565,95658,10167, 10167A, 10602,32827, and 10700.
14 C.F.R. 

### § 91:.,103':Preflight acUon ' ''. ' .. ' 

## . [**~**

### ..**·~:-** ·f·

:

.**~** ., i-:" <;. Thisregulation requires each pilot in**comm~md** to;take certain actions. before:flightto insure the safety offlight. As 

### F:AA approved rotorcraft Hight m:anuals_willnot· be provided forthe aircraft an exemption will be needed_, The PIC will take all. actions,including reviewingweather, flight battery requirements, landing

.. and takeoffdistances·and:aircraft performance data**b~fore** initiation offlight.,· .--:,_

.. 14 C. F.R. §91.1 09; Flight instruction;
Section 91.103 provides th_at-ao- persoo may operate. a civil aircraft (except a manned.free balloon) that is being used for flight im?truetion unless that aircraft hasfully functioning dual**oon~~- -~** 

_, ;.·•' • ,., ,., f"''·. :'

. ,. - ;' • ;- sUASs and

### remot~ly,~piloted ajrcraft, by their design dQ

### n~t have fullyJunctional duaJ.controls. · Flight control is accomplished through the use ofa control box that communicates with the aircraft via**radio·-communications~** The FAAhasapproved- exemptionsJorfiighttraining without·· fully functional dual controls for a number of:aircr:aftand forflignt,instruction**jr~** ex:pefJmental· aircraft. See Exe,m.ption Nqs5778K and 

### 98.62A. The.eqt.!ivalent;levelof'Safety can be.achieved as neither a pilot norppssengers

### wi.ll be·carried·ln the air;craft iru3ddition to,tbe small sizeand

.. lowspeedoftheaircraft. ;:'<,

__ .. •••.:•.c ·-·•::: ··.::-··· ,. 14 C.F.R. §91.1 19·: Minimum safe altitudes .· : 

### e<· ,,,,. ,i

.. ·.' ·; ···
-,}o_.',c**·.;~** ';,**~-~~.** "' <**,~,·::** ...**~-~** ',**·:~** ••' ,,0 <:' I;,: Section

## ~1.119 establishes

## ~afe altitudes for

## opera,tj~·!J**~t~ivii** aircraft.

## Sectio~ 9,t;119 (d) allows helicopters to**b~** operated,at less,than**the-J'ninimum:~ pxescrib~d.**  providedtbe·person operating the helicopter-complies with any. route or**(llltitt~;des,Ji>resc~ib.edc:for** helicopters by·the FM.As this exemptionisfor:. a sUAS that,is a h,elicopter and tb.e !3Xern!';!tion**.req!J~~ts** authority·to, operate at · altitudes up to ,400 AGL, or- notm-ore than 200**apove~·at'J** elevated**p~atform** fromwhich filming is, planned, an exemption may be needed to 

### allow s-uch·**op_er:~tions.** As."setforth .herein, .except foro the limited conditions stated in the Manual, the UAS will never operate at higherthan 400 AGL. It will however be operated in a.restrictedsarea**with~-security·** perimeter,·where·**build~ngs** and. people will not qe exposed to ope(ations**witho~:~t** thetrpre-obtained con;;ent· ) "• PL.':: ;:·:.. A •• I The equivalent level of safety will be achieved given the size,weight; speedofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local·officia,ls. Because ofthe advance .raotice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack.:qfflamm.at.l;>Je f,uel, a,ny risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low altitude operations ofthe-sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section**91~**1**H~·.** 

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

. . \ This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set"

...to the elevation ofthe departure airport or an-appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, bufinsteadia· GPS altitUde read out, an -exemption· may be needed. An equivalent level of safety wiU be achieved by the operator, pursuantto the Manual and Safety Check list,.by receiving altitude !nfo'rmation via a digitally encoded telemethc data feed, which downlinks from tlrle aircraft to aground based··onscreendisplay,:This altitude information will'h>e generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, orany combination thereof. Priorto each flight, a zero altityde initiation point will be established and confirmed for accuracy:by the 

### pilot.' ·· 14 C.F:R. § 91:151(a): Fuel Requfrements,for.Fiight inNFRConditio"ns Section 91.151**~a)** prohibits:ari individual frorr.fbegirtning 

## "a flight in an airplane U:hder 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 afterthaMor at least;30 minutes; or(2) At night, to fly afterthat for at least45 minutes."

•l ·:r::.·

..'**~ -~:.** **•!'.~_,...;, ··,~.** **~** The battery powering the sUAS' provides·approximately 40 minutes ofpowered flight To· meet the 30 mi:nuteresef'lle requirement

..in 14 CFR §91.151, sUASflights would be limited to· appl'idximately 10 minutes in length. Glven·theFifmitatioris O'n-tht.r UAS's propdsecf.flight area and the location'of its proposed operatlons'Withirr·a pre·determided areaFa,ionger time frame for flight in daylight or night VFR conditions is reasonable. · · .. · · South Georgia Drone Training and Services believes that ari exerrfption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. 

### See Exemption 10673 (allowing Lockheed Martin Corporation to**~Yper'afewithout** cdmplia'rilce With· FAR91t151 (a));·Operatingthe small UAS, in a tightly:cot"ltrolled area where

### 'only people and'property owners or official · representatives·wh.o have signed waivers

## wm be allowed;'with,less•than 3Q .minutes of· reserve fuel, aces not engender. thl3:type of:tiskst.h'at Section 91.151 (:a) wa$ :intended'to alleVIate given

. the size·and speed ofthe small UAS<**Additic:ihally;·l~niiting** sUAS flights to 10 minutes would greatly reduce the uti:lity forwhich the exemptioitwill·be·-granted': ' '

.. -, ,**~**

., ) South:Georgia Drorre Training and Services'betieves··thalan equivalent level ofsafety can be achieved by limiting flights

### to 30 mir:tlitesor 25% ofb'Sttery powerwhicheverhappens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anYwhere in'its 'limitedoperating area. - . . - · "
Similar exemptions have been granted to other operations, i'ncluding Exemptions 2689F, 5745, 10673, and 10808. '. · . .. ·

. ··r

. •! 14C.F.R. §91.203 (a) and {b): Carrying**CiviiAirct~'ftlCertification** 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:
An appropriate and current airworthiness certificate.No person may operate a civil aircraft unless the airworthiness certificate required by.paragraph (a) ofthis section or a special flight authorization issued under·§9.1>.715 is· displayed at the cabin or cockpitentrance sothat it-is legible to passengers.-or crew. - ;-t'·r

- - ,

.;
..

:**~** -:: :' ! :. :;
.c:-·.: The UAS fully loaded weighs no more than 55 lbs: and' is operates·.without anonboafd piloLAs·: such, there is no ability or place to carry certification and**registration-doct~memts orto~display**  · them on the sUAS.

__ . - ·· An equivalent level of safety will be achieved by keeping tbese documents- at·ti:Je ground control point where the pilot flying the sUASwill have-immediate**access~to:them,** 

### to:the extentthey areapplicable to the sUAS. The_ FAA has issued -numerous ex(ilmptions to this regulation; 

### A

- . repres.entative sample ofotherexceptions--includes-Exemption·Nos. 9565;,·9665, .9789, :9789A, 9797,: 9797A, 9816A, and 10100.**-~** ,

. (" "}._ 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) and (b): Maintenance Inspections
These regulations-require-that an aircraft operatororowner "shaiL:have-**that~**aircraft inspected as prescribed in subpart E ofthis. part and shall between.re.qurr:ed in_spectibns, exceptas. pr.ovided in paragraph (c) ofthis section, have discrepancies·repaired:astprescribed inpart .43 ofthis 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 wiJLbe. a9complished by the operator(;, pursuanUo the flight manwaland)•operating handbook.**As~the·manufacturer** does r:mt provide specific maintenance instructions, maintenaAc_ewill be**!~en.conditiorCfor** all-aircraft and each. aircraft will have a maintenance log.

- -**~** ,_, -::- : --**'~··** !' c. 12 :. , _.;
.r-- ,

-- '**;_r·-,c~,-.:** t·l**~--·· ~-~**  'r. (.**~- ~**  An equivalent le'llel of safety will be achieved be.c.ause:thes·e smaii'UASs arevery lirilited in size and will carry a small payload and operate only in restricted .area's for1imited periods oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual; the. operatopnill:ensure thatthe UASds i.n working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Ifthe operator encounters a maintenance issue which cannot be addressed, the UAS will be returned to the manufacturer or a qualified repair facility where such repairs or maintenance can be performed.

.. : ,- :. Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules:
14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113( a) and (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.2D3(a)and (b); 91.405 (a); 91.407 (a) {1); 91.409 (a) {2); 91.409 (a) (2) and 91.417 (a) and (b) to operate commercially a small unmanned vehicle (551bs or less) in aerial photography and aerial filming operations and flight demonstrations for training purposes

.. Approval of exemptions allowing commercial operations ofsUASs in the aerial photo and film industrywill enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, operate at extremely low altitudes justfeet from the subject being filmed and inextreme proximity to people and structures;'and present the risks associate·d with vehicles that weigh in the neighborhood of 4,'0'001bs., carrying largeamounts ofjet

### Aor otherfuel. Such aircraft must fly to and from the film**location~** In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack of combustible fuel carried onboard. The 

### si:JAS is carried·to the film set and notflown. ThesUAS will carry no.passenger:s.orcrew and; thereforre 1·will not expose them to the-risks associated with manned aircraft flights.
The operation of small UASs, weighing IE)ssthan .55.Jbs:, conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting-the graht ofthe exemptions requested herein, including exemptingthe. applicant from the requirements of Part 21 and allowing commercial operations. These lightWeight akcraft bperate·at slow speeds, close to the ground, and in a sterile environment and, as a result, are far saferthan CCDnventional ope-rations conducted with turbine helicopters operating in close proximity to the ground and people.



### . . . 

### ... Privacy All flights will occur:over private or controlledaccess property with the property owner's prior consent.and ·knowledge. Filming will be ofpeople:who have also-consented'to being filmed or otherwise have agreed to be.in·the ·area wherefilmingwill take place.
4. SUMMARY. Souttl:,Georgia Drone.Trair:1ing and Services· exemption\request should be granted due to the factthat the business will increase competi1!ion·ii:J: 

### the marketplacr:e, ser-ve to benefit the· public good in a safe and notinterfere with· other safe. and effective operations in the National Airspace. Similar exemptions have been granted and have been given.previously to· other operators who the same sUASs, e.g. Exemptions Nos. 11062, 11109, 11112, 11213, 11641, 1163,9, tt240, 11654,11656, :11658, tt659;ct1660, ;11663; 11664,. 11655; 11669., 11670, 

### 11672, 11639, 1·1641·,.:11642,-\11644,**'1t1626.:·~ (~** 

. . ;:·

. • ' '**'t~ ~··**  Ifyoy have any questions or need any.additional information, please'contactthe undersigned at:
.!**.~·** ..**~.** n"' .) ·, dapariarisi@yahoo.com {901 )853-6566 · " < •

'', ,..,. ., '· .. ,. '.!.-\. i \ . Dated: 20 December 2015 Sincerely yours,



# .**(~'** 

# ,,-?

.·_. ' ;

;!) ;:/**~~~. {f./fo~**  ,)· 

### Donald .Panarisi .' P:**~-** · ·.**··-~~l'\** ,. Owner, South GeorgiaDrone Training and SerV-ICes' :'

',!

'**~** .