U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

 Prepared by:

Adam Margaros

Lead Engineer, Closed Circuit TV Masters, Inc.

1651 East 4th Street, Suite 150

Santa Ana, CA 92701

657.247.4847

Closed Circuit TV Masters, Inc. Section 333 Petition to Operate Small Unmanned Aerial System

July 9, 2015 

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. section 44701 (f), Closed Circuit TV Masters, Inc.

("Petitioner")

hereby petitions for exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates),

14 C.F.R. Part 27 (Airworthiness Standards: Normal Category Rotorcraft), 14 C.F.R sections

61.113(a)-(b), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2},

and 91.417(a)-(b).
The proposed exemption, if granted, would allow Petitioner to conduct commercial operations

of small unmanned aircraft systems ("UAS") meeting or exceeding all of the operational and

safety requirements Congress has set forth in Section 333.

Petitioner is a technology / security integration firm that plans to exploit the capabilities of

Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote UAS Security Patrols (Commercial Properties)

- Telecommunications

- Aerial Site Mapping

- Aerial filmmaking and photography

- Energy systems inspections and asset management

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

- Assist with search and rescue operations

Statutory Authority

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS.

Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the (comprehensive) plan

and rulemaking required by section 332(b}(1) of this Act or the guidance required by section

334 of this Act." In Section 332(b}(1), Congress made it clear that Section 333 provides a

mechanism for "expedited operation authorization" if several factors are met. Petitioner meets

all requirements to permit FAA approval of commercial UAS operations.
The Petitioner Requests Relief From the Following:

Section 61.113(a) and (b) prescribes that-

(a) 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; nor may that person, for

compensation or hire, act as pilot in command 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.

Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before

beginning a flight, become familiar with all available information concerning that flight, to

include-

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed,

and any known traffic delays of which the pilot in command has been advised by ATC;

(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 and landing distance data is required, the takeoff and landing distance data contained

therein; 

(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.
Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue

hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a

horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over

open water or sparsely populated areas. In those cases, the aircraft may not be operated

closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is

conducted without hazard to persons 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 for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the

minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, 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."

Section 91.151 (a) prescribes that 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; or (2) At night, to fly after that for at least 45

minutes. [emphasis added]
Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that

aircraft inspected as prescribed in subpart E of the same part and shall, between required

inspections, except as provided in paragraph (c) of the same section, have discrepancies

repaired as prescribed in part 43 of the chapter. 

date. 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 other 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 owner 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.

The Petitioner has Supplied the Following Additional Information:

DJI Inspire 1 Safety Guidelines and DJI Inspire 1 User Manual.

Unmanned Aircraft System

The petitioner states that the unmanned aircraft (UA) to be operated under this request is less

than 55 lbs. fully loaded, flies at a speed of no more than 50 knots, carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the user manual. The craft is the Inspire 1

manufactured by DJ I.
The quadcopter has 4 motors, GPS, full autonomous autopilot

capabilities, telemetry and manual ground control.

In addition, the craft has integrated safety features built into the design of the UAS, as

described in the Pilot Training Guide, to ensure the safety of persons and property within and

surrounding the limited operating area. The petitioner further describes that, in the event the

UAS loses communications or its GPS signal, the UA will have the capability to return to a

pre-determined location within the Security Perimeter and land. It will also have the capability

to abort a flight in the event of unpredicted obstacles or emergencies.

Petitioner's UAS will be identified by serial number, registered in accordance with 14 C.F.R.

Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45,

Subpart C. Markings will be as large as practicable.

Pre-flight Inspection, Maintenance

Before each flight the PIC will perform a series of pre-flight and takeoff checks as defined by

the Pilot Training Guide supplied. After each 60 minutes of airtime, the craft will undergo a

thorough inspection of all aircraft components, including, but not limited to:

a. Actuators I Servos

b. Motors, wiring and connectors

c. Propellers, smooth, no chips

d. Electronic speed controller, wiring and connectors e. Batteries, wiring and connectors

f. Remote command and control

g. Ground control station
UAS Operating Parameters

The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot,

in daytime VFR flight conditions and all operations will be conducted with the assistance of a

second spotter/observer. The UAS flights will be limited to a maximum altitude of 400 feet

AGL. Altitude is accurately measured by GPS. The petitioner further states that an operator

will ensure that only consenting production personnel will be allowed within 100 feet of the UAS

while in operation, and UAS will be kept at least 100' from any inhabited structure. Generally the

petitioner's UAS will be operated in rural or suburban areas that will permit significantly larger

safety zones.

Flight Standards District Offices (FSDOs) will be notified as required prior to operations to

describe intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic

Organization ("ATO") issued Certificate of Waiver or Authorization ("COA") prior to conducting

any operations under this grant of exemption. In fulfilling its requirements under the COA,

Petitioner will be required to request a NOT AM not more than 72 hours in advance, but not

less than 48 hours prior to the operation.

Petitioner's UAS will remain clear and yield the right of way to all manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, and hangliders). Petitioner will not conduct UAS operations within 5

nautical miles of the geographic center of a non-towered airport unless a letter of agreement

with that airport's management is obtained and the operation is conducted in accordance with

a Notice to Airmen ("NOT AM"). 
Pilot in Command (PIC)

Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply

with the other applicable procedures and requirements stated in§ 91.1 03(a) and (b).

Specifically, the PIC will take all actions including reviewing weather, flight battery

requirements, aircraft performance data, and landing and takeoff distances before initiation of

a flight. The PIC will also account for all relevant site-specific conditions in their preflight

procedures. Risks presented by sun glare will be mitigated by the PIC's and VO's ability to

see other air traffic and initiate a return-to-home sequence if needed.

Radio Frequencies

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle

control in unlicensed frequency bands. All devices used will comply with FCC usage and

emissions regulations.

Safety and Benefits of the UAS

The petitioner will be using the UAS in a variety of applications that generally require

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer

many benefits over the use of full-sized manned aircraft for electric power line inspection,

oil/gas pipeline inspection, advanced agriculture, and film and still photography. Replacing

significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying

no passengers or crew creates a much greater margin of safety for the pilots and crew.

By granting Petitioner's requested exemptions, the FAA will help drive development of safe

and successful commercial UAS operations and will advance the public knowledge base for

such operations. Petitioner is committed to promoting the UAS research efforts of

policymakers including the FAA, NASA, DOD and DARPA by sharing data from its

commercial UAS operations and serving as a resource for future UAS research operations.

Thus, the FAA has good cause to grant this Petition.
Conclusion

For the foregoing reasons, the exemptions requested herein should be granted and Petitioner

should be permitted to conduct small UAS operations in accordance with its manuals and all

other operating parameters deemed necessary and appropriate by the FAA.

Adam Margaros

Lead Engineer, Closed Circuit TV Masters, Inc.