# Section 333 

# Exen1ption

**]~equest** PerspectiveAerial Productions,LLC

10/13/2015 Perspective Aerial Productions, LLC Marsh, DavidS.

## TableofContents David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14



## Introduction, Exemptionfor Use ofUAS for BusinessApplications Introduction, Exemption for Use of UAS for Business Applications .............................................................1 UAS #1 DJIInspire 1 Quad................................................................................................................4 UAS #2 DJI Phantom 2......................................................................................................................4 UAS #3 DJI S1000 Octocopter..........................................................................................................4 I. Petitioner's Contact Information: ....................................................................................................6 II. The Specific Sections ofTitle 14 ofthe Code of Federal Regulations From Which David Marsh Requests Exemption are: ..........................................................................................................................7 Ill. The Extentofrelief David Marsh seeks and the Reason He Seeks Such Relief: ..............................7 IV. How David Marsh's Request Will Benefitthe Public as aWhole:....................................................9 V. Reasons Why David Marsh's Exemption Will NotAdversely Affect Safety or Howthe Exemption Will Provide a Level ofSafetyAt least Equal to Existing Rule: ................................................................10 VI. ASummarythe FAA May Publish in the Federal Register: ............................................................11 APPENDIX A.............................................................................................................................................15 Sample Flight Screen with Live Data (Inspire 1 UAS) ............................................................:........ 15 UAS #1 DJIInspire 1Quad..............................................................................................................15 APPENDIX 6.............................................................................................................................................16 Sample flightScreen with Live Data (DJI Phantom 2Quad UAS)...................................................16 UAS #2 DJI Phantom 2....................................................................................................................16 APPENDIX C.............................................................................................................................................17 Sample flightScreen with Live Data (DJI S1000 Octocopter UAS) .................................................17 UAS #3 DJI S1000 Octocopter ........................................................................................................17 APPENDIX D.............................................................................................................................................18 Operational Policies forall Unmanned Aircraft Systems...............................................................18 APPENDIX E.............................................................................................................................................22 DJIInspire 1Operators Manual .....................................................................................................22 Appendix F ...............................................................................................................................................23 DJI Phantom 2 Operators Manual..................................................................................................23 Appendix G..............................................................................................................................................24 DJI S1000 Operators Manual .........................................................................................................24

Page 1 of25

### David Marsh PerspectiveAerial Productions, LLC Requestfor Exemptionfor Use ofUAS Under Section 333,Title 14 Perspective Aerial Productions, LLC PO Box 8178 Williston, ND 58803 USA Email: info@PerspectiveAP.com Phone: 701.609.8334

UAS Integration Office-Special Rules Coordinator FederalAviation Administration U.S. DepartmentofTransportation Docket Operations, M-30 WestBuildingGround Floor RoomW12-140 1200 NewJerseyAve., SE, Washington, DC 20590
RE: 

## Introduction,ExemptionforUse ofUAS forBusinessApplications
October 13, 2015 To whom itmay concern: I, David Marsh, dba "Perspective Aerial Productions, LLC," am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, David Marsh, am owner and operatorofsmall unmanned aircraft, be exemptedfrom the Federal Aviation Regulations (FARs) listed below so that I, David Marsh, may operate my small ultralightweight unmanned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). As described herein I, David Marsh, am a licensed commercial pilot, certificate number: 3319982, having obtained my certificate in 1994. Iam experienced in flying hobby aircraftfor recreational purposes and have been flying RC fixed wing and rotor aircraft since I have 2010. I have added two state-of-art professional grade quad-copter UAS vehicles from well-known manufacturer (DJI) to my inventory equipped with factory installed high resolution gimbaled camera systems with intent for aerial photos, videography/cinematography. Ihave also added a state ofthe art professional grade octocopter from the same manufacturer (DJI) with a gimbaled camera for aerial photos, videography/cinematography. The purpose of these equipment additions will be to enhance academic community awareness for those individuals and companiesunfamiliar with UAVs in thegeographical layout ofthe areas Iserve, to provide small businesses and individuals with video production services targeting marketing, construction progress,towerinspection, insurance assessments, real estate, search and rescue, event videography including but limited to wedding, sports, public/private events, weather, etc., following the exemption and approval for my operations while also reducing risk and liability from manned aircraft alternatives.

Page 2of25

### David Marsh PerspectiveAerial Productions, LLC Requestfor Exemptionfor Use ofUAS Under Section 333, Title 14

Iam also a member ofthe AMA, Academy ofModel Aeronautics, and have flown small radio controlled (RC) electric aircraftfor overfive (5) yearswithout incident. Ihave beenflying RC gasoline poweredfixed wing aircraft since 2010, also without incident. Committed to safety with each flight, my exemption request would permit operation of light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in areas away from general public, airports, heliports, and vehicular traffic. My general purpose for the use of the UAS will be to produce community videos; videos of commercial, industrial, and residential properties for sale or rent and within property boundaries for individual homeowner, insurance assessments, real estate listing videos/photos; small business videos; construction progress and tower inspection; and eventvideography including by not limited towedding, sports, public/private parties, etc. Currently, similar lightweight, remote controlled UASs are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I have personally designed and implemented safety protocols and controls to prevent publichazard and mitigate risk significantly overthe alternative manned aircrafthazards/catastrophe. In addition, services performed by the UAS will allow for video which cannot be safely shot from conventional manned aircraft alternatives. Additionally, Iwill notify any persons present in the operational area by posting temporary safety signs notifying all persons that aerial drone videography operations are taking place and to be alert to the presence ofthe UAS aircraft. Signs will beposted up to 30 minutes beforeflight operationsand continue until all UAS operations are concluded at each site. This will act to further safety protocols exclusive to lightweight UAS's specific to video and photography usage as I, David Marsh, record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reportstoassistwithfuture protocol and safetyregulation Granting my, David Marsh, requestcomportswith theSecretaryofTransportations (FAAAdministrators) responsibilities and authority to not only integrate UAS's into the national airspace system, but to also establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes and othersmall business applications. Further Iwill conductmy operations in compliance with the protocolsdescribed herein oras otherwise established by the FAA.
Forthe reasons stated below I, David Marsh, respectfully requestthegrantofanexemption allowing me to operate ultra-light weight, remote controlled UASs for academic community awareness to benefit/stimulate attraction to the areas of operation in the United States and its surrounding communities to enhance videos for businesses and private individuals who cannot afford expensive, high-risk manned aircraft for the same purpose. My activities will promote local economic growth through increased employmentand increased tax base, the provision ofnew services and enhancement of producing a more efficient and more comprehensive photographic and cinematography system, allowing consumersto better determine the value ofthe specific projects using enhanced online video capabilities. Furthermore, by using my UAS system as an alternative to heavier manned aircraft containingcombustiblefuel that posespotentialpublic hazard, Iwill also be contributing tothe safetyof the local communitiesserved. Page 3 of25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14

I have attached detailed information on the three UAS proposed. The following is 

### a short summary of each system: 

### UAS #1 Djllnspire 1 Quad Manufacturer: DJI Model: Inspire 1T600 Weight: 2935 g

## I 6.47 Pounds Passenger Capacity: 0 (unmanned) Size (dimensions): 438x451x301 mm (17.24x17.76x11.85 inches) MaxSpeed: 

### 22 mps (72.18 fps

## I49.21 mph) Max FlightTime: 18-25 mins Max Ceiling (software limited): 400ftAGL Operations: Line ofSight Controller: Dedicated Commercial Controllerwith 2 km maximum rated operating distance



### UAS #Z DJI Phantom2 Manufacturer: DJI Model: Phantom 2 Weight: 1000 g

## I 2.2 Pounds Passenger Capacity: 0 (unmanned) Size (dimensions): 406.4x406.4x203.2mm(16x16x8 inches) MaxSpeed: 15 mps (49.12 fps

## I 33.55mph) Max FlightTime: 18-25 mins Max Ceiling (software limited):400ftAGL Operations: Line ofSight Controller: Dedicated Commercial Controllerwith 1 maximum rated operating distance



### UAS #3

### DJI S1000 Octocopter Manufacturer: DJI Model: SpreadingWings51000 Weight: 4.2 kg (9.26 pounds) Passenger Capacity: 0 (unmanned) Size (dimensions): 1093.5x1093.5x610mm (43.05x43.05x24 inches) MaxSpeed: 22 mps (72.18fps

## I49.21 mph) Max FlightTime: -30 mins Max Ceiling (software limited): 400ftAGL Operations: Line ofSight Controller: Dedicated Commercial Controllerwith 2 km maximum rated operating distance

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### Specifically, each UAS is: David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14

A lightweight(<25 lb grossweightwith all on-board equipment), battery operated 4- motor rotorcraft in the form ofaquadcopteroroctocopterthattakes offand landsvertically, manufactured by DJI, each withthe following equipment: -An on-board flight computer with GPS navigation and location ability that receives signals for flight controlsfrom aground-based transmitter/controller;
-An on-board camera capable ofcapturing imagery in the form offull color, high definition still photos and video; -An on-board telemetry system that delivers flight data from the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site;
-An integrated 5.8GHz on-board radio transmitter that transmits live video from the on-board
camera plus all the flight data from the telemetrysystem described above.
The Ground Station Includes:

- A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAS while in the air;
-A 100mW, 2.4GHz radio transmitter/controller operated bythe PIC to control the UAS while in flight; -A radio receiver receiving live video and flight data from the on-board camera and computer projects itall togetherontoascreen forthe PIC toview duringflight.
Thankyou for reviewing my request

David Marsh Perspective Aerial Productions, LLC Commercial Pilot, Drone Pilot

Page 5of25 David Marsh

### David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS , Under Section 333, Title 14 Perspective Aerial Productions, LLC PO Box 8178 Williston, ND 58803 USA Email: info@PerspectiveAP.com Phone: 701.609.8334

UAS Integration Office- Special Rules Coordinator Federal Aviation Administration U.S. Department ofTransportation Docket Operations, M-30 West Building Ground Floor Room W12-140 1200 NewJerseyAve., SE, Washington, DC 20590
RE: 

## Introduction,ExemptionforUse ofUAS for BusinessApplications
October 13, 2015 To whom it may concern: I, David Marsh, dba "Perspective Aerial Productions, LLC," am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, David Marsh, am owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) listed below so that I, David Marsh, may operate my small ultralightweight unmanned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). As described herein I, David Marsh, am a licensed commercial pilot, certificate number: 3319982, having obtained my certificate in 1994. I am experienced in flying hobby aircraft for recreational purposes and have been flying RC fixed wing and rotor aircraft since I have 2010. I have added two state-of-art professional grade quad-copter UAS vehicles from well-known manufacturer (DJI) to my inventory equipped with factory installed high resolution gimbaled camera systems with intent for aerial photos, videography/cinematography. I have also

**~dded** 

### a state of the art professional grade octocopter from the same manufacturer (DJI) with a gimbaled camera for aerial photos, videography/cinematography. The purpose of these equipment additions will be to enhance academic community awareness for those individuals and companies unfamiliarwith UAVs in the geographical layoutofthe areas I serve, to provide small businesses and individuals with video production services targeting marketing, construction progress, tower inspection, insurance assessments, real estate, search and rescue, event videography including but limited to wedding, sports, public/private events, weather, etc., following the exemption and approval for my operations while also reducing risk and liability from manned aircraft alternatives.

Page 2of25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14


## II. The Specific Sections ofTitle 14ofthe Code ofFederal Regulations From Which David Marsh Requests Exemption are:
14CFR 21; 14CFR 45.23(b); 14CFR 61.113(a)&(b); 14CFR 91, et seq.; 14CFR 407(a)(1);14CFR 409{a)(2); and 14CFR 417(a)&(b).


## III. 

## The ExtentofreliefDavid MarshseeksandtheReason He SeeksSuch Relief:

Page 

### 7of25 I, David Marsh, am a licensed Private Pilot, certificate number 3319982, having obtained my license in 1995. I, David Marsh, submit this application in accordance with the Reform Act, 112PL 95§§ 331- 334, seeking relief from any currently applicable FARs operating to prevent me, David Marsh, contemplated commercial cinematic, academic and other flight operations within the national airspace system.
The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. David Marsh's ultra-light weight UAS is expressly contemplated by the Reform Act. Iwould like to operate my ultra-light weight UAS priorto the time period by which the Reform Act requires the FAA to promulgate. rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography.
The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed, and overall capabilities ofthe UAS's; whether the UAS will be operated near airports or heavily populated areas; and, whetherthe UAS will be operated by line ofsight. 112PL 95 §333{a). Each ofthese items reflects in favor ofan exemption for me. My UAS aircraft utilize four (4)
or eight (8) counter-rotating propellers for balance, control and stability. My UA's are equipped with GPS and auto return safety technology. My UA Maximum Takeoff Weight is less than twenty-five (25) pounds (far below the maximum 55 pounds limit); including camera with gimbal and any other payload. Each would be classified as an ultra-light UAS aircraft.
I consider safety as foremost with each flight. My small unmanned aircraft are designed to hover in place via GPS and operate in less than a 24 knot (20.8 mph) wind. For safety, stability and fear offinancial loss, Iwill not fly in winds exceeding24 kph (20.8 mph). Built in safety systems include aGPS modethat allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode* (See manufacturer's Operating Manual) for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost the UA is designed slowly return and descend to point oftakeoff. Ido not operate my UAS near airports, hospital or police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions, and weather.

### Page 

### 8 of

### 25 David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 

### 333,Title 

### 14

Horizontal Ground Speed for most drone videography requirements are typically less than 7- 

### 10 miles per hour which further adds to safety. Maneuvers are limited in scope and gently performed (as opposed to more radical recreational use) due to the need to keep the camera steady for video purposes. Flight paths are planned out in advance, as opposed to recreational flight and therefore safer than many recreational flights since speed, maneuvers and flight paths are very conservative and preplanned. During any planned operation of the UAS, I first scout the area and flight path; determine what obstacles, ifany, are present, where to post warning signs notifying persons that aerial drone photography is taking place and any other conditions from lighting, line ofsight issues and power lines that Ishould be aware ofto conduct safe operations. Iclearly markthe area ofthe flight path with warning signs indicating that the UAS will be in operation 

### 30 minutes priortotheflight and until all flight operations have ceased.
I maintain a second observer at all times who remains within 

### 10 yards ofthe PIC position and who is responsible for spotting obstacles, people, vehicles, and manned aircraft, as well
as keeping track ofthe UAS position.
I am constantly alert for any manned aircraft (Police/Medical helicopters, private and commercial aircraft of any type, model aircraft, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line ofsight, as the remote control pilot (PIC). Utilizing battery power rather than combustible fuels, flights generally last between three {3) 

### to fifteen (15) 

### minutes, with an altitude under 400 

### feet. I utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eighteen (18) 

### to twenty-five (25) 

### minutes as specified bythe manufacturers and consistently twenty-one (21) 

### to twenty-five (25 

### minutes as tested. My flight equipment provides for the monitoring of battery levels during flight. I do not operate my UAS at or below manufacture recommended minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are on hand with each event to insure replacement for
asufficient safe level of operation. I do not believe in taking risks that may cause a crash, that could create a hazard to the public, public or private property, or manned aircraft and 

### have no desireto lose myvery substantial investment in my UAS equipment.
As of this time, I 

### have completed 

### over 200 

### practice flights with 

### over 40 

### hours of UAS airborne operations as a hobbyist simulated fights for future commercial use to gain familiarization with the characteristics of my specific UAS models' operations and performance under different temperature and weather conditions. I also practice regular weekly computerized simulated flights to maintain adequate skills and response reflex time, all this forthe sake of safety. I

### have no less than (5) five hours offlight time logged in each model proposed herein within the past 

### 90day period.David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14

I, David Marsh, am extremely cautious when operating my UAS/ultra-light weight aircraft and will not "create a hazard to users of the national airspace system or the public." 112PL 95§ 333(b). Given the small size and weight of my UAS it falls well within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. David Marsh's UASs, used in hobby flight, has ademonstrated safety record and does not pose any threat to the general public or national security. The UAS aircraft used are modern model units manufactured by leading manufacturers (brand names) in the industry: DJI. They have extensive experience in Unmanned Aerial Video flight Systems and provide extensive software, flight manuals, operational information, specifications, and customer support on their products.



## IV. How David Marsh's RequestWill BenefitthePublicasaWhole:

Aerial videography forgeographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense ofsuch aerial videography is cost prohibitive. Only large companies and high-end realtors or luxury homeowners can afford to absorb such expense, depriving non-luxury homeowners and lower budget realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash, each having the potential result of loss of life, damage to property and substantial cost involved in responding to, handling the emergency and the subsequent investigation and clean up. Each such manned aircraft event also involves combustible fuel that in the Past has exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My, David Marsh's, UAS pose no such threatsince size and lack ofcombustible fuel alleviates almost all potentialthreattothe public. Congress has already proclaimed that it is in the public's interest to integrate commercially flown UAS's into the national airspace system, hence the passing ofthe Reform Act. Granting my, David Marsh's, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the United States. My ultra-light UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra-lightweight UAS crashing is far less than a full sized helicopter or fixed wing aircraft; which are manned, heavy, contain combustible fuel and can cause catastrophic devastation tothe public.
The public's interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra-light UAS's. Permitting me, David Marsh, to immediatelyfly within national airspace furthers economic growth. Granting my exemption request substantially furthers the economic impact for the North Dakota and surrounding communities and cities for companies looking to relocate for career advancement through academic and geographical awareness; both ofwhich serve as astimulus tothe communities involved.

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### David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14


## V. ReasonsWhyDavid Marsh's ExemptionWill NotAdverselyAffectSafetyor Howthe ExemptionWill Providea Level ofSafetyAtleastEqualto Existing Rule: My, David Marsh's, exemption will not adversely affect safety. Quite the contrary, for the reasons stated, permitting me, David Marsh, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for realtors that can be embraced by the NAR, AAR, and TAR fordevelopment in cooperation with the FAA, In addition I, David Marsh, submit the following representations of enhancements to current aerial videography and photography for real estate: My UAS aircraft weigh less than 25 pounds complete with a small ultra-lightweight high quality factory installed gimbaled high definition camera; I only operate my UAS below 400 feet (within in the 400 foot permissible ceiling set by the FAA Modernization and Reform·Act of2012); my UAS only operates for 3-15 minutes average per flight; I land my UAS significantly prior to manufacturer recommended minimum level of battery power which my flight systems monitor throughout the flight; I pilot my UAS through remote control only by line ofsight; My UAS has GPS aflight safety feature whereby it hovers and then returns to the point of takeoff. Then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports, and actively populated areas; I conduct extensive pre-flight inspections and protocol according to all manufacturers recommendations as well as that of the AMA (Academy of Model Aeronautics), during which safety carries primary importance; I always obtain all necessary permissions prior to operation; and , I have procedures in place to abort flights in the event of safety breaches or any potential danger. My, David Marsh's, safety protocols provide a level ofsafety equalto orexceeding existing rules. It is important to note that absent the integration of commercial UAS into our_nation airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate While the safety record of such helicopters is remarkably astounding there have been incidents involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra-lightweight UAS.

Page 

### 10of25 First, the potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific areas awayfrom mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS allows me to remotely pilot away fromthe avoidable hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close tothe objects they are focused on through the technology and use ofpost editing software allowing pan, tilt, and zoom.David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14

Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.



## VI. ASummarytheFAA MayPublishintheFederal Register:

A. 14CFR 21 and 14CFR 91: Airworthiness Certificates, Manuals, and Similar.
14 CFR 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR§91.203(a)(1). The size, weight, and enclosed operational area of my UAS aircrafts permit exemption from Part 21 because my UAS aircrafts meet (and exceed) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC§44701(f)) and Section 333 of the Reform Act. Both pieces of legislation permitthe FAA to exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Mycurrent and projected UAS's meet or exceed each of the elements.
14 CFR §91.7(a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.
14 CFR § 91.9 (b) (2) requires an aircraft fight manual in the aircraft. As there are no on-board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas ofwhere safety can be defined. The FAA has previously issued exemption tothis regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9656B, 10167, 10167A, 10602, 10700, and 32827.
14 CFR § 91.121 regarding altimeter setting is inapplicable insofar as my UAS utilizes electronic global positioning systems with abarometricsensor.
14 CFR § 91.203(a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level ofsafety will be achieved by maintainingany such required certifications and registrations by me and any proposed PICs ofthe UAS proposed.
14CFR §45.23: Marking ofthe Aircraft Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications My UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit, or pilotstation on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft with dimensions smaller than minimal lettering requirement.

Page 11 of25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14 Regardless, I propose that each UA will carry its appropriate "N" number if one is issued by the FAA, in such size as can reasonably fit upon the sides ofthe aircraft in at least two locations on the booms or fuselage. If an "N" number is not obtained from the FAA, I will mark the related UAS in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14 CFR § 45.29(f) so that I, the pilot, or anyone assisting me as aspotter with the UA will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A, and 10700.
14 CFR § 61.113: Private Pilot Privileges and Limitations: PIC
Pursuant to 14 CFR §§ 61.113(a) & (b), private pilots are limited to non-commercial operations. The FAA has previously ruled in its exemption that a Private Pilot's Certificate is required for flight ofthe UAS for commercial purposes. I, David Marsh, am a licensed commercial pilot and will assure that all PIC's proposed to operate any of the UAS aircraft also have at minimum a Private Pilot's certificate and current Class Three medical. My UAS's do not carry any pilots or passengers. The risks attended tothe operation ofmy UAS is far less than the risk levels inherent in the commercial activities outlines in 14 CFR § 61, et seq. Thus, allowing me and any other Private Pilot certified PIC to operate the proposed UAS's to meet and exceed currentsafety levels in relations to 14 CFR § 61.133(a)&(b).
14 CFR 91.119: Minimum Safe Altitudes.
14 CFR 91.119 p,rescribes safe altitudes forthe operation of civil aircraft. It allows helicopters to operate at lower altitudes in certain conditions. My UAS will never operate at an altitude at greater than 400 AGL; the safety standard set by FAA. I will however operate my UAS's in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofmy UAS, an equivalent or higher level ofsafetywill be achieved.
14 CFR 91.40S(a); 497(a)(1); 409(a)(2); 417(a)&(b): Maintenance Inspections The above-cited Regulation require, amongst other things, aircraft owners and operators to "have [the] aircraft inspected and prescribed in Subpart Eofthis part and shall between required inspection, except as provided in paragraph ( c ) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

..."
These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my proposed UAS's. However, as safety precaution I require the PIC to perform a comprehensive pre-flight and post-flight inspection of the UAS, adhering to the manufacturers' recommendations and checking all flight systems, power systems, rotors, and electronics including battery levels. The UAS has significant self-diagnostic software and systems checks built into its operations. Any system not reporting correctly and fully functional shall result in an aborted flight until the problem is identified and solved and the systems once again report 100%functional and operational.
A Summary the FAA My Publish in the Federal Register: A. 14 CFR 21 and 14 CFR 91: Airworthiness Certificates, Manuals, and similar. 14 CFR 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates fn Page 

### 12of

### 25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14
relations to FAR § 9J..203(a)(1). The size, weight, and enclosed operational area of my UAS's permits exemption from Part 21 because my proposed UAS's meets an equivalent level ofsafety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft form the airworthiness certificate requirement under both the Act (49 USC§ 44701(f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS's both meets orexceeds each ofthe elements.
14 CFR 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 CFR § 91.19(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures forany damaged hardware. Therefore, an equivalent level ofsafetywill be achieved.
In summary, David Marsh seeks an exemptionfrom the following Regulations:
14CFR 21, subpart H; 14CFR 45.23(b); 14CFR §§ 61.113(a)&(b); 14CFR § 91.7(a); 14CFR § 91.9 (b) (2); 14CFR 91.103(b); 14CFR 91.109; 14CFR § 91.119; 14CFR § 91.121; 14CFR §91.151(a); 14CFR §§91.203(a) and (b); 14CFR § 91.405(a); 14CFR § 91.407(a)(1); 14CFR §91.409(a)(2); and 14CFR §91.417(a)&(b) to commercially operate my three small, ultra-light weight, unmanned aircraft vehicles (UAV's) to community awareness for the public good and for real estate to enhance operations and small business operations, to develop economic platforms for real estate to enhance the experience ofthose seeking to relocate to any such area 

### served. Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel, posing potential risk to the public. Granting my request forexemption will reduce current risk level and thereby enhance safety. My UAS aircraft do not contain potentially explosive fuel. They are far smaller, lighter, and more maneuverable than conventional real estate video and photographic aircraft with much less flight time and do not require transit to and from the "shoot" location to an airport, resulting in far less required time airborne and therefore exposure & Liability. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airports and operations take place well below pattern altitudes. All ofmy operations are conducted with a pre-flight aircraft inspection, flight path inspection, and actual flights are normally conducted at 

### very low altitudes and speed with conservative maneuvers necessary for video cinematography. I, David Marsh, have been informally analyzing flight information and will compile safety protocols and implementation of a flight operations manual for real estate and similar small business usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols forcomplying with the FAA Modernization and Reform Act of2012.
Page 13 of25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14 There are no personnel on board my UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My operation of UAS's, weighing less than twenty-five (25) pounds and travelling at far lower speeds within limited areas will provide an equivalent level of safety as that achieved undercurrent FI>.Rs. Accordingly, I respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefitthe FAA, safety ofmanned aircraft, and the general public at large.



### """""'



# ~d,

David Marsh Commercial Pilot UAS Pilot in Command, Cinematographer

Page 14of25

## APPENDIX A SampleFlightScreenwithLive Data (Inspire 

### 1 UAS) Specifications Overview



### UAS #1DJIInspire 1 Quad Manufacturer: DJI Model: Inspire 1T600 Weight: 2935 g

## I 6.47 Pounds Passenger Capacity: 0 (unmanned) Size (dimensions): 438x451x301 mm (17.24xl7.76x11.85 inches) MaxSpeed: 22 mps (72.18 fps

## I 49.21 mph) Max FlightTime: 18-25 mins MaxCeiling (software limited): 400ftAGL Operations: Line ofSight David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14

Controller: Dedicated Commercial Controllerwith 2 km maximum rated operating distance

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### 15 

### of25

## APPENDIX B David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14

Sampleflight

### ScreenwithLive Data 

### (DJI Phantom 2 Quad UAS) Specifications Overview



### UAS#2 Djl Phantom2 Manufacturer: DJI Model: Phantom 2 Weight: 1000g

## I 2.2 Pounds Passenger Capacity: 0 (unmanned) Size (dimensions): 406.4x406.4x203.2mm(16x16x8 inches) MaxSpeed: 15 mps (49.12 fps

## I 33.55mph) Max FlightTime: 18-25 mins MaxCeiling (software limited): 400ftAGL Operations: Line ofSight Controller: Dedicated Commercial Controllerwith 1 maximum rated operating distance

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### 16

### of25

## APPENDIX C David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14

SampleflightScreenwith 

### Live Data (D)J 

### SlOOO Octocopter

### UAS) Specifications Overview



### UAS #3 DJI S1000 Octocopter Manufacturer: DJI Model: Spreading Wings S1000 Weight: 4.2 kg (9.26 pounds) Passenger Capacity: 0 (unmanned) Size (dimensions): 1093.5x1093.5x610mm (43.05x43.05x24 inches) MaxSpeed: 22 mps (72.18 fps 

## I 49.21 mph) Max Flight Time: N30 mins Max Ceiling (software limited): 400ftAGL Operations: Line ofSight Controller: Dedicated Commercial Controllerwith 2 km maximum rated operating distance

Page 

### 17 of25

## APPENDIX D David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS Under Section 333, Title 14



### OperationalPoliciesforall UnmannedAircraftSystems Perspective Aerial Productions, LLC David Marsh

1. The unmanned aircraftsystem (UAS) willweigh less than 25 pounds, including energy source(s) and equipment and shall not be loadedwith any unauthorized payloads. 2. The UAS will not be flown at agroundspeed exceeding 35 mph. 3. Flights will be operated at an altitude ofno morethan 400 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported toATC muST be in feetAGL. 4. The UASwill be operatedwithin visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses. 5. All operationswill utilize avisual observer (VO). The VO may be used to satisfytheVLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicateverballyat all times. 6. Priorto each flight the PIC will inspectthe UAS to ensure it is in aconditional forsafe flight. Ifthe inspection reveals acondition that affects thesafe operation ofthe UAS, the aircraft is prohibitedfrom operating until the necessary maintenance has been performed and the UAS is found to be in acondition forsafe flight. All maintenance and alterationswill be properly documented in the aircraft records.



### Pre-FlightProtocol:
1. Check batteries to insure fully charged and ready for use. Inspect batteriesfordamage or leakage that may affect properoperation. 2. Inspect propellers forcracks, chips, ordamage that may cause sudden loss ofpropulsion or unmanageable/uncontrolledflight. 3. Checkweatherforecasts forwind advisory orotherconditions that may impactflight. Consult five (5) mile radius forairportvicinity. 4. Contact respective airportto advise ofestimatedflight time, estimatedflight duration, estimated elevation offlight, and any other pertinent information as may be required by distance. a. Inspectflight area for:

Page 18of

### 25 i. Vicinity ofpublic safety helipads/heliports ii. Vicinity ofmedical helipads/heliports iii. Vicinity oflight poles iv. Vicinity ofutilitywires v. Vicinity oftrees orany otherobstacles vi. Flocks ofbirds that may cause interference and potentialflight impact vii. Vicinity ofany elevated obstruction that may pose potentialflight hazardDavid Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14
viii. Vicinity of roadways with moderateto heavy trafficthat can be distracting /distracted. ix. Publicgatherings that may attractviewers x. Optional point ofcontrol for best visual site of UAS while in flight, takeoff, and landing b. Inspect area for best and safest point oftakeoffand landing 5. Ifin asubdivision orarea that is within 150feet ofaresidential street, post warning sign(s)/stand(s): Attention Aerial Photography in Progress-Stay Back 150 Feet" 

### FlightProtocol:
Takeoffand land from same location whenever possible. 

### 1. Remain alertto birds, sound oraircraft, curious public, and approachingvehicles. 2. Do not allow anyone toengage in conversation ordistractthe remote control Pilot (PIC) restrict flight to minimal elevation sufficientto acquire desired results. 3. Remain prepared foremergency landing at all times; payattention toflighttime. 4. Ifpossible set atimeras asafety alert. 5. Land UAS and shut down propulsion immediatelyfollowing landing.



### PostFlightProtocol:
1. Disconnect batteryto prevent accidental activation or propulsion system 2. Secure UAS in asafe location 3. Remove all warning signs from public access areas 

### EmergencyorSuspectedHazardProtocol: Immediately land UAS atsafest and closest location in the event: • Manned aircraft is heard orseen in vicinity offlight. • There is apublicgatheringwithin established safety boundarywantingto observe flight. • Pilot is being distracted from focusing on flight and safety • Sudden change in weather (wind bursts) • Sudden increase in vehicular traffic in vicinity offlight • Birds enter into proximityofflight

7. Ifthe UAS has undergone maintenance oralterationsthataffect the UAS operation orflight characteristics, e.g., replacement ofaflight critical component will undergo afunctional test flight in accordance with the operator's manual. The PIC who conducts the functional testflightwill make an entry in the UAS aircraft records oftheflight. The requirements and procedures forafunctional test flight and aircraft record entrywill be added tothe operator's manual. 8. The operatorwill followthe manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirement will be

Page 19of25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use of UAS UnderSection 333, Title 14
established and identified in the operator's manual. At aminimum, requirements forthe following will be included in the operator's manual: a. Actuators/Servos; b. Transmission (single rotor) c. Power Plants (motors); d. Propellers; e. Electronic speed controller; f. Batteries; g. Mechanical dynamic components (single rotor); h. Remote command and control; 

### i. Ground control station (if used); and 

### j. Any othercomponents as determined by the operator. 9. The Pilot In Command (PIC} will possess at least a private pilot certificate and currentthird class medical certificate and at least avalid driver's license. 10. Priorto operations the PICwill have accumulated and logged, in a manner ofconsistent with 14 CFR §61.51(b), a minimum of200 flight cycles and 25 hours oftotaltime as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilotwith asimilar UAS type (single blade or multirotor). Prior documentedflight experience that was obtained in compliance with applicable regulations may satisfythis requirement. Training, proficiency, and experience-buildingflights can also be conducted toaccomplish the required flight cycles and flight time. 11. Priorto operationsthe Picwill have accumulated and logged, in a manner consistent with 14CFR§a minimum offive hours as UAS pilot operatingthe make and model ofUAS to be utilized for operations and three take-offs and three landings in the preceding 90 days. Training, proficiency, experience-building, and take-off and landing currencyflights can be conducted to accomplish the required flight cycles and flight time. 12. The UAS may not be operated directly over any person, except authorized and consenting personnel, below an altitudethat is hazardous to persons orpropertyon thesurface in the event ofa UAS failure or emergency. 13. The operatorwill request all non-authorized and consenting persons to remain clear ofthe operational area by not less than 100feet. 14. The UAS will abortthefight in the event ofunpredicted obstacles oremergencies in accordance with the operator's manual. 15. Each UAS operation will be completed within 15 minutes maximum flighttime orwith 25% battery power remaining, whichever occurs first. 16. Ifthe operational area is within 5 miles ofany airport, the PIC will obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) priorto conducting any operations. This COAwill also require the operatorto request a Notice ofAirman (NOTAM) not morethan 72 hours in advance, but not less than 48 hours priorto operation. 17. All aircraft operated in accordance will be identified byserial number, registered in accordance with 14CFR part47, and have identification (N-Number) markings in accordance with 14CFR part45 subpart

### C. Markings must be as large as practicable. Ifthis registration is notavailable from the FAA, then each such aircraftshall be marked "Experimental." 18. Each UAS operated will comply with all manufacturerSafety Bulletins. 19. The radio frequencyspectrum used foroperation and control ofthe UAV will complywith the Federal Communications Commission (FDD) orotherappropriate government oversight agency requirements. 20. Ifoperating within five (5) miles ofthe center ofany airport, at least three days before scheduled flight, the PIC oroperatorwill submitawritten Plan ofActivities tothe local FSDO withjurisdiction Page 20 of25David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use ofUAS UnderSection 333, Title 14

overthe area ofproposed flight area. The 3-day notification may be waived with the concurrence of the FSDO. The plan ofactivities must includethe following: a. Date and times for all flights; b. Name and phone number ofthe operator; c. Make, model, and serial or N-numberof US to be used; d. Name and certificate numberof UAS PIC involved; e. Astatementthat the operator has obtained permission from propertyowners and/or local officials to conduct the flight operations; the list ofthose whogave permission must be made available tothe inspector upon request; f. Signature ofexemption-holderor representative; g. Adescription ofthe flight activity, including maps, diagrams ofany area, city, town, county, and/orstate overwhich theflights will be conducted and the altitudes essential to accomplish the operation. 21. The documents required under 14CFR §§ 91.9 and 91.203 will be available tothe PIC at the Ground control Station ofthe UAS any time the aircraft is operating 22. The UAwill remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralightvehicles, parachute activities, parasailing activities, hang gliders, etc.). 23. UAS operations will not be conducted during night, as defined in 14CFR §1.1. All operations will be conducted undervisual meteorological conditions (VMC). Flights underspecial visual flight rules (SVFR) are not authorized. 24. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhenvisibility is less than 3statute miles from the PIC. 25. The UAS will notoperate in Class B, C, or Dairspace withoutwritten approval from the FAA. The UAS may not operatewithin 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on acurrent FAA-published aeronautical char unless a letterofagreementwith that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required bythe operator's COA. The letterofagreement with the airport management must be made available to the Administrator upon request. 26. Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries ofthe operational areas as defined by the applicable COA will be reportedtothe FAA's UAS Integration Office (AFS-80) within 24 hours.

Page 21 of25

### APPENDIX E DJI fnspire 1 OperatorsManual (See Separate Attachment) File: DJIInspire Operations Manual Inspire 1 User Manual v1.2 en.pdf

Page 22 of25 David Marsh Perspective Aerial Productions, LLC Request for Exemption for Use 

### of UAS UnderSection 333,Title 1.4