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– ADV Exemption Request April 16, 2015 April 16, 2015
Mina Ghabriall Archangel Drone Services, LLC 11649 Hemlock Street El Monte, CA 91732 (323) 844

- 2278 info@archangeldronevideography.com
**Petition of Archangel Drone**  **Videography, LLC For**  **Exemp tion Pursuant to Section 333**  **Of the FAA Moder** **nization and Reform Act of 2012** To Whom It May Concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Archangel Drone Videography, LLC ( ADV ), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system ( i.e. , sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, and any other requirements established by the FAA pursuant to Section 333 of the Reform Act. This exemption would permit commercial operation by ADV, which uses DJI Phantoms, 550S Flame Wheels, Inspire 1, 3DR Solos, and S1000 to conduct s UAS flig ht training, education, real estate photography, and videography, film and movi e production, and demonstration flights. ADV’s operation under the exemption will be subject to strict operating requirements and conditions to ensure an equivale nt level of safety to currently authorized operations using manned aircraft and under c onditions as may be modified by the FAA as required by Section 333.
ADV will be operated under controlled VFR conditions a t low altitude in airspace that is permitted in accordance wi th ADV’s approved Cert ificate of Authorization (COA). They will operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements . Finally, the FAA ATC wil l approve the airspace in which the sUAS will operate in advance. Archangel Drone Videography respectfully submits this request for an exemption because it operates sUAS's . The FAA can have confidence that the operations will b e conducted at an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secreta ry of Transportation’s (the FAA Administrator’s) responsibilities2 | Page

– ADV Exemption Request April 16, 2015 under Section 333(c) of the Reform Act to “estab lish requirements for the safe operation of such aircraft systems in the national airspace system.” For your convenience, ADV has organized this Exemption request as follows: I. Petitioner's Description II. Relevant Statutory Authority III. Qualifications for Approval Under Section 33 3 of the Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested VI. Public Interest VII. Privacy VIII. Federal Registry Summary IX. Conclusion
**I. Petitioner's Description:**  Archangel Drone Videography, LLC, headquartered in El Monte , California, is a company that provides sUAS support to news services, real estate photography, film and movie production, education, and demonstration flights in a compliant and safe environment. ADV plans on providing a wide range of services as the sUAS market expands.
ADV 's goal is to operate in an accident

-free environment by:
• Demonstrating a commitment by management and all employee’s to operator in a compliant manner.
• Identify hazard and risk while eliminating or controlling all these risk.
• They will use steps to intervene and report when unsafe work practices appear to exist.
• Train all employees involved in flight operations to operate at the highest standard level. The contact information for Petitioner is as follows: Archangel Drone Videography, LLC 11649 Hemlock Street El Monte, CA 91732 Member Managers: Mina Ghabriall Office: (323) 844

- 2278 Email: info@archangeldronevideography.com
**II. Relevant Statutory Authority:**  This petition for exemption is submitted to fulfill Co ngress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned3 | Page

– ADV Exemption Request April 16, 2015 aircraft systems may operate safely in the National Airspace ("NAS") before completion of the form al UAS rulemaking, based on the following considerations:
• The UAS's size, weight, speed, and operational capability;
• Operation of the UAS in close proximity to airports and populated areas; and
• Operation of the UAS within the visual line of sight of the operator. 1 If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish require ments for the safe operation of such aircraft in the National Airspace System". Additionally, the FAA Administrator has general authority to grant exemptions from i ts safety regulations and minimum standards when the Ad ministrator decides a requested exemption is in the public interest. A party requestin g an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would n ot adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civ il aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: **The Administ rator may grant an exemption from a requirement** 

**of a regulation prescribed unde r subsection (a) or (b) of this**  **section or any of sections.**
**III. Qualifications for Approval Under Section 333 of the Reform Act**  The proposed operations in this petition for exempti on qualify for expedited approval under Section 333 of the Reform Act. Each of the statut ory criteria and other relevant factors are satisfied. The proposed operations would permit ADV the us e of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) co ntrolled as to access; and that (3) provides an increased level of safety beyond that ex isting when fixed or rotor wing aircraft are used to accomplish the same purpose.
ADV uses UASs that are multirotor, weighing less th an 25 pou nds including payload. They operate, under normal conditions, at speeds not to exceed 45 mph and have the capability to hover, and move in the vertical and horizontal plane. ADV’s UASs will operate in line of sight, during daylight hours, and wil l only operate within a sterile area. ADV will operate at or below 400 feet AGL and will file a NOTAM for each flight opera ted in controlled airspace. All required

1 A DV’s submission places a duty on the Administrator to not only process applications for exemptions un der Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for t he safe operation of the sUAS. A DV welc omes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may rais e that they believe may require modification

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– ADV Exemption Request April 16, 2015 permissions and permits would be obtained fro m territorial, state, county or city jurisdicti ons, including local law enforcem ent, fire, or other appropriate governmental agencies prior to operating a sUAS. Given the small size of the sUAS’s involved and the restricted sterile environment within which they will operate, this ADV’s exemption falls within the zone of safety and demonstrate an equivalent level of safety, in wh ich Congress desired the FAA to permit commercial UAS operations by exemption pe nding completion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will operate, approval of the application presents no hazard in the NAS. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significa nt public benefit, the grant of the requested exemptions is also in the public interest.
**IV. Description of Proposed Operations**  To assist the FAA in its safety assessment of ADV 's proposed sUAS operations, below is a summary of operational limitations and conditions that will ensure an equivalent or highe r level of safety to operations conducted under current regulatory guidelines: 1. The sUAS will weigh less than 25 pounds. 2. Flights will be operated within lin e of sight of the PIC and observer. 3. Maximum total flight time for each ope rational flight will be limited to the amount of time the sUAS ca n be flown and still maintain a reserve battery power of no less than 25%. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Flights will be operated at a lateral dist ance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not si gned a waiver in advance of the operation. 6. Minimum crew for each ope ration will consist of the sUAS Pilot in Command an d a Visual Observer. Additional crewmembers consist of a Pilot and a Camera Operator. 7. The sUAS Pilot in Command will have undergone comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements

. 8. ADV will designate a Pilot in Command ("PIC") for each mission. 9. The sUAS will operate only with in a confined "Sterile Area". 10. Prior to the operations at a particular l ocation, a site inspection will have been conducted. On the da y of the mission the management person with operational con trol and the PIC will concur on dispatching of the mission. 11. A briefing will be conducted in regard to the planned sUAS operations prior to each d ay's missions. It will be mandatory that all personne l who will be performing duties within the boundaries of the sterile area be present for this briefing. 12. ADV crew will use the checkli st and callouts required in the Operations Manual.5 | Page

– ADV Exemption Request April 16, 2015 13. All sUAS’s will be maintained in acc ordance with inspection program specified in the manufacturer’s guidelines. 14. In the event of an accident involving an ADV sUAS, they will cease operations and report the accident to the NTSB and AFS

-80. 15. Pilot in Command and Visua l Observer will at all times be able to communicate by voice. 16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will have been trained and tested in accordance to FAA, NTSB, and AFS

- 80 best practices

. 17. All required permissions and permits would be obtained from territorial, state, county or city jur isdictions, including local law enforcement, fire or other appropriate governmental agencies. 18. ADV management will submit a written “Plan of Activities” to the local Flight Standards Dist rict Office (FSDO) having jurisdiction over the area of propos ed filming three days in advanced of operations during film or movie productions. 19. If the sUAS loses communications signal, the sUAS will have the capability to return to a pre - determined l ocatio n within the Sterile Area and land. 20. Contingency plans will be in place to s afely terminate flight if there is a loss of communication between the pilot and the observer. 21. The sUAS has the capabili ty to abort a flight in case of unpredicted obstacles or emergencies. 22. ADV, by following FAA, NTSB, and AFS

-80 best practices, will assure no individuals’ privacy is violated. 23. Procedures have been established in ADV’s Operations Manual to contact ATC prior to operating in airspace other than G.
**V. Regulations From**  **Which Exemption is Requested**

**A. 14 CFR § 91.103: Preflight Action**  **B. 14 CFR § 91.113: Right** 
**- of** 
**- Way Rules**  **C. 14 CFR § 91.119 (c): Minimum Safe Altitudes**  **D. 14 CFR § 91.121: Altimeter Settings**  **E. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR**  **Conditions F.**  **14 CFR § 9 1.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):**  **Maintenance Inspections**
**A. 14 CFR § 91.103: Preflight Action**  ADV requests an exemption from the prefl ight actions requirements of 14 CFR 91.113 that prescribes the preflight actions un der which aircraft may operate: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives availab le if the6 | Page

– ADV Exemption Request April 16, 2015 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: i. For civil aircraft for which an approve d Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and ii. For civil aircraft other than those s pecified in paragraph (b)(1) of this section, other reliable information appropria te to the aircraft, relating to aircraft performance under expected values of airport elevation an d runway slope, aircraft gross weight, and wind and temperature. ADV will n ot operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. DJI ’s sUAS’s do not have published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data. **Equ ivalent Level of Safety**  In adherence to FAA, NTSB, and AFS

- 80 best practices, the PIC along with the person having operational control must follow to assure that the weath er will be adequate to complete the mission in VFR condition. Since ADV operates in California where the density altitude is never usually above 20 00 feet, UAS performance is not affected. When ADV is allowed to operate in other parts of the United States the UAS used in those locations will be test flown at gross weight to test performanc e limitations prior to conducting commercial operations.
**B. 14 CFR 91.113: Right** 
**- of** 
**- Way Rules**  ADV request an exemption from 14 CFR 91.11 3 Right

- of

-way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear. Archangel Drone Videography operates small pilotless UAS’s and cannot comply with these rules as they have been written. **Equivalent Level of Safety** ADV operates sUAS’s at or below an altitude of 400 feet AGL, well below the normal operating altitude of other aircraft. ADV management require that a Pilot in Command with experience will oversee each mission and has knowledge of the avoid rules. A Visual Observer will assist the PIC in looking for a ircraft entering the operations area. It’s the responsibility of the PIC to cease operatio ns and land the UAS immediately whenever and aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until the threat is clear.7 | Page

– ADV Exemption Request April 16, 2015 **C. 14 CFR. § 91.119: Minimum Safe Altitudes**  ADV requests an exemption from the minimum s afe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe alt itudes under which aircraft may operate:
• Over any congested area of a city, town, or s ettlement, or over any open air assembly of persons, an altitude of 1,000 feet ab ove the hi ghest obstacle within a horizontal radius of 2,000 feet of the aircraft.
• Over other than congested areas at an altitude of 500 feet above the surface , except over open water or sparsely populated area s. In those cases, the aircraft may not be operated clos er than 500 feet to any person, vessel, vehicle, or structure. Section 91.119 (d) allows for a helicopter to ope rate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each p erson operating the heli copter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." To provide the intended operations, the sUAS is n ormally operated below 400 feet AGL. Additionally, due to the nature of the pro posed operations, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation. **Equivalent Level of Safety** Compared to flight normal aircraft, ADV’ s multi

- rotor aircraft weigh a maximum of 25 pounds, and given the lack of flammable fuel, a ny risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As s et forth in the FAA, NTSB, and AFS

-80 best practices, the sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

o btained consent. Because of the advance notice to the property owners and participants, all affe cted individuals will be well aware of the planned flight operations prior to commencement of operations. Furthermore, by operating at such lower altitudes, t he sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulatio ns. Finally, the successful safety record of the DJI sUAS’s demonstra tes that the sUAS can be safely used at these lower altitudes and closer operating environments.
**D. 14 C.F.R. § 91.121: Altimeter Settings**  ADV seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barom etric pressure. An exemption is required because the sUAS does not have a baromet ric altimeter, but rather a GPS altitude read out.8 | Page

– ADV Exemption Request April 16, 2015 **Equivalent Level of Safety** An equivalent level of safety will be achieved by follow ing the procedures set forth in the FAA, NTSB, and AFS

- 80 best practices

. ADV will confirm the altit ude of the launch site shown on the GPS altitude indicator before flight. Moreover, th e PIC will use the GPS altitude indicator to constantly monitor the s UAS's height, thus ensuring operation at safe altitudes.
**E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions**  ADV requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states:

a. No person may begin a flight in a n airplane under VFR conditions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

– i. During the day, to fly after that for at least 25 minutes; or ii. At night, to fly after that for at least 45 minutes. The batteries powering ADV’s UAS’s provide approximately 10

- 25 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flights could not be c onducted. Given the limitation s on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve am ount of battery life is needed. ADV will not be conducting any sUAS flights at night. **Equivalent Level of Safety** An equivalent level of safety will be achieved because t he operations will be conducted on - site without significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% reserve battery power st ill available. This restriction would be more than adequate to return the sUAS safely to its planned landing zone from anywhere in its confined area of operation eve n in the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was inten ded to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, operation will be limited to co ntrolled areas where only people and property owners, or official representatives who have signed waivers will be allowed.
**F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):**  **Maintenance Inspections**  ADV also seeks an exemption from the main tenance in spection requirements contained in 14 CFR 91.405(a), 91.407(a ) ( 1), 91.409(a ) ( 2), 91.41 7(a) and (b). These regulations specify maintenance and inspection standards in refe rence to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator of an ai rcraft "shall have the aircraft inspected as prescribed in subpart E of this part and sha ll between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have.9 | Page

– ADV Exemption Request April 16, 2015 **Equivalent Level of Safety** An equivalent level of safety will be achieved beca use maintenance and ins pections will be performed in accordance with FAA, NTSB, and AFS

- 80 best practices. The operator will ensure that the sUAS is in working order prior to initiating flight, pe rform required maintenance, and keep a log of any maintenance performed. The opera tor is the person most familiar with the aircraft and best suited to maintain the aircra ft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying cap acity, and the fact that flight operations will only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional roto rcraft performing the same operation.
**VI. PUBLIC INTEREST**  Granting Archangel Drone Videography, LLC an exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. The one vision of ADV is to help fac ilitate safe integratio n of sUAS’s into mainstream USA in the following areas:
• **Movies and Videography** o Whether the shot requires unique views and expansive panning or extreme altitude with radical views, the UAS is desi gned to hold up under demanding conditions. Because of the autopilot fe ature with pre

- designed mission management and R/C control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD still photos. When working close in on a closed set the hazards to the actors are gre atly reduced due to the size of the sUAS.
• **News Gathering** o Similar to movies and videography, eac h news assignment may require a completely different shot or view of a scen e. With budgets for traditional helicopter use being greatly reduced, the UAS is th e perfect solution to allow for easy news gathering for a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, w hile the traditional helicopter must hover over persons and property increasing the danger to individuals.
• **Real Estate** o The sUAS can be used in all areas of rea l estate, including commercial, residential and industrial properties. Using a sUAS, real estate professionals can create promotional videos, photos and unique s hots that normal camera aspects cannot capture. ADV’s easy

-to
- use video and ph oto platform enables properties to stand out, providing dazzling views that ar e typically shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high

- rise condo in stunning high definition tha t shows your potential customer the actual view from the residence. The remote platform is great for new planning, zoning and large developments. S imple and easy

-to
- use video and photos allow for multiple height p ictures and elevation views.10 | Page

– ADV Exemption Request April 16, 2015 **VII. Privacy**  Archangel Drone Videography is deeply committed to protect ing public privacy. ADV knows that many individual have concerns about privacy from the operations of sUAS’s. ADV has created a privacy notice that informs residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property.
**VIII. Federal Registry Summary**  Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Archangel Drone Videography, LLC seeks an exemption from the following rules: 14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.405(a), 91.407(a ) ( 1), 91.409(a ) ( 2); 91.417(a) and (b). Approval of this exemption request allows ADV to conduct commercial operations with small and lightweight unmanned aerial systems. ADV’s singular vi sion is to enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners. The DJI sUAS, weighing less than 25 pounds and powered by batteries, eliminates virtually all of that risk given the reduced mass and la ck of combustible fuel carried on bard. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The opera tion of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters. If additional information is req uired, or if you have any questions regarding this Petition for Exemption, please contact the undersigned at: With Best Regards, Mina Ghabriall, Director Archangel Drone Videography, LLC Office: (323) 844

- 2278 Email: info@archangeldronevideography.com11 | Page

– ADV Exemption Request April 16, 2015 **IX. Conclusion**  For the foregoing reasons, it is requested that the regulatory exemptions requested herein be respectfully granted , and the Petitioner be permitted to conduct small UAS operations aforementioned purposes

.