March	15,	2016

U.S.	Department	of Transportation Docket	Management	System 1200	New Jersey	Ave.,	SE West	Build ing	Ground	Floor,	Room	W12

- 140 Washington,	DC	20590 Re:	Request	for	Exemption	under	Section	333	of the FAA	Modernization	and	Reform	Act and	Part 11	of the	Federal	Aviation	Regulations	f rom	14	C.F.R.	61.23(a)	and	(c); 61.101(e)(4)	and	(5);	61.113(a);	61.315(a);	91.119(c);	91.121;	91.15 1(a)(1);	91.405(a); 91.407(a)(1 );	91.409(a)(1)	and	(2);	91.417(a)	&	(b).

**PETITION	FOR	SUMMARY	EXEMPTION**
To	Whom	I t	May	Concern :
Pursuant	to	Section	333	of the	FAA	Modernization	and	Reform	Act	of 2012	(the	Reform Act)	and	14	C.F.R.	Part	11, Sky	Bandit	Pictures ,	LLC (Petitioner) ,	an	operator	of	Small Unmanned	Aircraft	(UA)	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation Regulations	("FARs")	to	allow	commercial	operation	of	its	UA. Petitioner is	eligible	for	a summary	exemption	for	aerial	data	collection	and	closed	set/scripted	filming;	please reference	exemptions	#11440	and	#11482. **QUICK REFERENCE	SUM**  **MARY** Type of UA to	be	flown: Rotary

- Wing	(Electric	Multi

- Rotor)
Models: DJI Inspire	One	( 6.5	lbs), DJI Phantom	2	(2.8	lbs)
UA	Operations	will	be	for Aerial	Data	Collection & Closed	Set/Scripted	Filming:	Surveying, Inspections,	Aerial	Cinematography.

Petitioner	will	operate	under	the	restrictions	listed	below	and	those	in	the	confidentially submitted	operating	manuals	and	MPTOM. Petitioner	agrees	to	all restriction s	in	Exemption#	11784 listed	below. **SKY	BANDIT	PICTURES,	LLC	REQUESTS	THAT PUBLICATION	AND**  **COMMENT PROCEDURES	BE	WAIVED	IN	AC**  **CORDANCE	WITH	14	C.F.R.	§	11.87** §	11.87	Are there	circumstances	in	which	FAA	may	decide	not	to	publish	a	summary o f	my petition	for	exemption?
The	FAA	may	not	publish	a	summary o f	your	petition	for	exemption	and	request comments if you	present	or	we	find	good	cause	why	we	should	not	delay	action	on	your	petition.	The factors	we	consider	in	deciding	not	to	request	comment	include:(a)	Whether	granting	your petition	would	set	a	precedent.

(b)	Whether	the	relief	requested	i s	identical	to exemptions	granted	previously. (c)	Whether	our	delaying	action	on	your	petition	would	affect	you	adver sely. (d)	Whether	you	filed	your	petition	in	a	timely	manner. Corresponding	to	the	above	sub

- sections, Petitioner has	good	cause	to	reques t	the	FAA	to waive	the	comment	period	and	not	delay	action	on	the	petition	because: (a) Petitioner would	not	set	any	precedent. Petitioner agrees	to	the	SAME	exact	l imitations as	Exemption#	11784. (b)	The	relief requested	is	identical	to	that	granted,	without	publication	for comment,	in Exemption	#	11784. (c)	Delaying	the	granting	of this	petition	would	adversely	affect	the	public,	the	FAA,	and Petitioner. The	public,	as	well	as	the	FAA, would	be	better	served	by	the FAA	quickly granting	this	petition	and thereby	freeing	up	limited	FAA	resources	and	allowing	FAA inspectors	to	dedicate	their	time	and	attention	to higher	priorities.	Moreover, Petitioner is adversely	affected	b y	the	below	listed	regulations. (d)	The	petition	has	been	filed	in	a	timely	manner.

**PUBLIC	BENEFIT** This	exemption	will	allow	commercial	operations	of UA's	that	will	enhance	safety	by reducing	risk.	The	alternative	to	using	a	UA	is	to	use	a	jet	or	piston	power ed aircraft carrying	large	amounts	of Jet	A or	100 LL fuel .	Not	only	are	these	alternative operation s dangerous	at location,	the	aircraft	must	fly	to	the	location	and	back	to	the	home	airport. The	UA	weigh s less	than	55	lbs.	and is powered	by batteries.	This eliminates	most	of the risk	because no	highly	flammable	fuel	is involved.	There	are	no	pilots	on	board	the	UA	and due	to	the	small	size	of the	UA,	there	is	less	risk	posed	to	the	public	on	the	ground	in	case	of an	emergency. Manned	airplanes	and	helicopters	produce	a	large	amount	of noise	pollution	when operating	at low	altitudes	that	disrupts	the	quiet	enjoyment	of	the	public	on	the	ground.	UA
are significantly quieter	and	will	not	disrupt	the	public	as	much	as	manned	aircraft;	thus, the	public	will	benefit	from	their	use.	Additionally,	the	UA	has	multiple	motors,	pr oviding redundancy,	while	most	manned	aircraft	have	only	one	engine.	The	operations	of the	UA listed	under	the	restrictions	proposed	herein	will	provide	an	equivalent	level	of	safety	as the	Federal	Aviation	Regulations.
**PETITIONER'S	CONTACT	INFO:** Sky	Ban dit	Pictures ,	LLC Attn: Dan	Coplan Email: fly@skybanditpictures.com Address: 5767	Saint	Clair	Ave,	Valley	Village,	CA	91607**REGULATIONS	FROM	WHICH	THE	EXEMPTION	IS	REQUESTED**

14	C.F.R.	§	61.23(a)	and	(c) 1 4	C.F.R.	§	61.101(e)(4)	and	(5) 14	C.F.R.	§	61.1 13(a) 14	C.F.R.	§	61.315(a) 14	C.F.R.	§	91.7(a) 14	C.F.R.	§	91.119(c) 14	C.F.R.	§	91.121 14	C.F.R.	§	91.15l(a)(1) 14	C.F.R.	§	91.405(a) 14	C.F.R.	§	91.407(a)(1) 14	C.F.R.	§	91.409(a)(1 ) & (2) 14	C.F.R.	§	91.417(a) & (b)

**OPERATING	DOCUMENTS** Petitioner will operate	only	within	the	limitations	below	and	the	limitations	listed	in	the confidentially	submitted	operating	manuals	and	MPTOM.	The	limitations	below,	from	the previously	granted	exemption,	will	be	followed	if	there	is	a	conflict	with	the	operating
manu al.

**STATUTORY	AUTHORITY	TO	GRANT	THIS	PETITION** The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	exemptions.	This statutory	authority	by	its	terms	includes	exempting	civil	aircraft,	as	the term	is	defined under§	40101	of the	Act	that	includes	UAS's,	from	the	requirement	that	all	civil	aircraft must	have	a	current	airworthiness	certificate.	"The	Administrator	may	grant	an	exemption from	a	requirement	of a	regulation	prescribed	under	subsection	(a)	or	(b)	of this	section	or any	section s	44702

- 44716	of this	title	if the	Administrator	finds	the	exemption	in	the public	interest."	49	U.S.C.	§	44701(f).	See	also	49	U.S.C.	§	44711(b). This	exemption	petition	is	expressly	submitted	to	fulfill	Congress'	goal	in	passing	Section 333(a)	through	( c)	of the	FAA	Modernization	and	Reform	Act	of 2012.	This	law	directs	the Secretary	of	Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may operate	safely	in	the	national	airspace	system	(NAS)	before	completion	of	the	rulemaking required under	Section	332	of the	FAA	Modernization	and	Reform	Act.	In	making	this determination,	the	Secretary	is	required	to	determine	which	types	of UA	do	not	create	a hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat to	national	security	in	light	o f	th e following: •	The	UA's	size,	weight,	spe ed,	and	operational	capability •	Operation	of the	UA	in	close	proximity	to	airports	and	populated	areas;	and, •	Operation of the UA within visual line of sight of the operator (VLOS). If	the	Secretary	determines	that	such	vehicles	"may	operate	safely	in	the	national	airspace system,	the	Secretary	shall	establish	requirements	for	the	safe	operation	of such	aircraft	in the	national	airspace	system."	Id.	§	333(c)	(emphasis	added).The	FAA	has	already	established	requ irements	for	summary	grants	that	will	be	further

discussed	below.	Applicant	interprets	this	provision	to	place	the	duty	on	the	Administrator to	not	only	process	applications	for	exemptions	under	section	333,	but	for	the Administrator	to	craft	conditions	fo r	the	safe	operation	of	the	UAS,	if	it	should	be determined	that	the	conditions	set	forth	herein	do	not	fulfill	the	statutory	requirements	for approval. **EQUIV ALENT	LEVEL	OF	SAFETY**  The	applicant	proposes	that	the	exemption	requested	herein	applies	to	civil aircraft	that have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	These limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to	operations under	the	current	regulatory	structure.
These	limitations	and	co nditions	are	identical	to	Exemption	#	11784	except	for	the difference	in	aircraft. Petitioner agrees	to	be	bound	when	conducting	commercial	UA operations.	The	list	of limitations	and	conditions	include	the	following: 1.	Operations	authorized	by	this	grant	of	exemption	are	limited	to	the DJI	Inspire	One and DJI	Phantom	2;	both	o f	which	weigh	less	than	55	pounds	including payload.	Proposed operations	o f	any	other	aircraft	will	require	a	new	petition	or	a	petition	to	amen d	this exemption. 2.	Operations	for	the	purpose	of closed

- set	motion	picture	and	television	filming	are permitted	as	specified	in	the	MPTOM. 3.	The	UA	may	not	be	operated	at	a	speed	exceeding	87	knots	(100	miles	per	hour).	The exemption	holder	may	use	either	groundspeed	or	calibrated	airspeed	to	determine compliance	with	the	87	knot	speed	restriction.	In	no	case	will	the	UA	be	operated	at airspeeds	greater	than	the	maximum	UA	operating	airspeed	recommended	by	the	aircraft manufacturer.
4.	The	UA	must	be operated	at	an	altitude	of no	more	than	400	feet	above	ground	level (AGL).	Altitude	must	be	reported	in	feet	AGL. 5.	The	UA	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all	times.	This requires	the	PIC	to	be	able	to	use	human	vision	u naided	by	any	device	other	than	corrective lenses,	as	specified	on	the	PIC's	FAA

- issued	airman	medical	certificate	or	U.S.	driver's license. 6.	All	operations	must	utilize	a	visual	observer	(VO).	The	UA	must	be	operated	within	the visual	line	of sight	(VL OS)	of the	PIC	and	VO	at	all	times.	The	VO	may	be	used	to	satisfy	the VLOS	requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and	PIC must	be	able	to	communicate	verbally	at	all	times;	electronic	messaging	or	texting	is	not permitted	d uring	flight	operations.	The	PIC	must	be	designated	before	the	flight	and	cannot transfer	his	or	her	designation	for	the	duration	of the	flight.	The	PIC	must	ensure	that	the VO	can	perform	the	duties	required	of the	VO.7.	This	exemption	and	all	documents needed	to	operate	the	UAS	and	conduct	its	operations

in	accordance	with	the	conditions	and	limitations	stated	in	this	grant	of	exemption,	are hereinafter	referred	to	as	the	operating	documents.	The	operating	documents	must	be accessible	during	UAS	operati ons	and	made	available	to	the	Administrator	upon	request.	If a	discrepancy	exists	between	the	conditions	and	limitations	in	this	exemption	and	the procedures	outlined	in	the	operating	documents,	the	conditions	and	limitations	herein	take precedence	and	mus t	be	followed.	Otherwise,	the	operator	must	follow	the	procedures	as outlined	in	its	operating	documents.	The	operator	may	update	or	revise	its	operating documents. It is	the	operator's	responsibility	to	track	such	revisions	and	present	updated and	revised documents	to	the	Administrator	or	any	law	enforcement	official	upon	request. The	operator	must	also	present	updated	and	revised	documents	if it	petitions	for	extension or	amendment	to	this	grant	of exemption.	If	the	operator	determines	that	any	update	or revision	would	affect	the	basis	upon	which	the	FAA	granted	this	exemption,	then	the operator	must	petition	for	an	amendment	to	its	grant	of exemption.	The	FAA's	UAS Integration	Office	(AFS

- 80)	may	be	contacted	if	questions	arise	regarding	updates	or revis ions	to	the	operating	documents. 8.	Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	operation	or flight	characteristics,	e.g.	replacement	of a	flight	critical	component,	must	undergo	a functional	test	flight	prior	to	conducting	f urther	operations	under	this	exemption. Functional	test	flights	may	only	be	conducted	by	a	PIC	with	a VO	and	must	remain	at	least 500	feet	from	other	people.	The	functional	test	flight	must	be	conducted	in	such	a	manner so	as	to	not	pose	an	undue	hazard	to persons	and	property. 9.	The	operator	is	responsible	for	maintaining	and	inspecting	the	UAS	to	ensure	that it is	in a	condition	for	safe	operation. 10.	Prior	to	each	flight,	the	PIC	must	conduct	a	pre

- flight	inspection	and	determine	the	UAS is	in	a	cond ition	for	safe	flight.	The	pre

- flight	inspection	must	account	for	all	potential discrepancies,	e.g.	inoperable	components,	items,	or	equipment.	If the	inspection	reveals	a condition	that	affects	the	safe	operation	of the	UAS,	the	aircraft	is	prohibited	fro m operating	until	the	necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be in	a	condition	for	safe	flight. 11.	The	operator	must	follow	the	UAS	manufacturer's	maintenance,	overhaul,	replacement, inspection,	and	life	limit	requirements	for	the	aircraft	and	aircraft	components. 12.	Each	UAS	operated	under	this	exemption	must	comply	with	all	manufacturer	safety bulletins. 13.	Under	this	grant	of exemption,	a	PIC	must	hold	either	an	airline	transport,	commercial, private,	recreational,	or	sport	pilot	certificate.	The	PIC	must	also	hold	a	current	FAA	airman medical	certificate	or	a	valid	U.S.	driver's	license	issued by	a	state,	the	District	of	Colu mbia, Puerto	Rico,	a	territory,	a	possession,	or	the	Federal	government.	The	PIC	must	also	meet the flight	review	requirements	specified	in	14	CFR	§	61.56	in	an	aircraft	in	which	the	PIC	is rated	on	his	or	her	pilot	certificate.14.	The	operator	may	not	permit	any	PIC	to	operate	unless	the	PIC	demonstrates	the	ability

to	safely	operate	the	UAS	in	a	man ner	consistent	with	how	the	UAS	will	be	operated	under this	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate distances	from	persons,	vessels,	vehicles	and	structures.	PIC	qualification	flight	hours	and currency	must	be	logge d	in	a	manner	consistent	with	14	CFR	§	61.51(b).	Flights	for	the purposes	of training	the	operator's	PICs	and	VOs	(training,	proficiency,	and	experience

building)	and	determining	the	PIC's	ability	to	safely	operate	the	UAS	in	a	manner	consistent with	how the	UAS	will	be	operated	under	this	exemption	are	permitted	under	the	terms	of this	exemption.	However,	training	operations	may	only	be	conducted	during	dedicated training	sessions.	During	training,	proficiency,	and	experience

- building	flights,	all	persons not	essential	for	flight	operations	are	considered	nonparticipants,	and	the	PIC	must	operate the	UA	with	appropriate	distance	from	nonparticipants	in	accordance	with	14	CFR	§ 91.119. 15.	UAS	operations	may	not	be	conducted	during	night,	as	defined	in	14 CFR	§	1.1.	All operations	must	be	conducted	under	visual	meteorological	conditions	(VMC).	Flights	under special	visual	flight	rules	(SVFR)	are	not	authorized. 16.	The	UA	may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	(ARP)	as denote d	in	the	current	FAA	Airport/Facility	Dire ctory	(AFD)	or	for	airports	not denoted with	an ARP,	the	center	of	the	airp ort	symbol	as	denoted	on	the	current	FAA	published aeronautical	chart,	unless	a	letter	of agreement	with	that	airport's	management	is	obtai ned or	otherwise	permitted	by	a	COA	issued	to	the	exemption	holder.	The	letter	of	agreement with	the	airport	management	must	be	made	available	to	the	Administrator	or	any	law enforcement	official	upon	request.
17.The UA may not be operated less than 500 f eet below or less than 2,000 feet horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.
18.	If the	UA loses	communications	or	loses	its	GPS	signal,	the	UA	must	return	to	a predetermined	location	within	the	private	or	controlled

- access	property. 19.	The	PIC	must	abort	the	flight	in	the	event	of unpredicted	obstacles	or	emergencies. 20.	The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast weather	conditions)	there	is	enough	available	power	fo r	the	UA	to	conduct	the	intended operation	and	to	operate	after	that	for	at	least	five	minutes	or	with	the	reserve	power recommended	by	the	manufacturer	if	greater. 21.	Air	Traffic	Organization	(ATO)	Certificate	of	Waiver	or	Authorization	(COA).	All operations	shall	be	co nducted	in	accordance	with	an	ATO

- issued	COA.	The	exemption holder	may	apply	for	a	new	or	amended	COA	if	it	intends	to	conduct	operations	that	cannot be	conducted	under	the	terms	o f	the	attached	COA.22.	All	aircraft	operated	in	accord ance	with	this	exemption	must	be	identified	by	serial

number,	registered	in	accordance	with	14	CFR	part	47,	and	have	identification	(N	Number) markings	in	accordance	with	14	CFR	part	45, Subpart	C.	Markings	must	be	as large	as practicable.

23.	Documents used	by	the	operator	to	ensure	the	safe	operation	and	flight	of the	UAS	and any	documents	required	under	14	CFR	§§	91.9	and	91.203	must be available	to	the	PIC	at the	Ground	Control	Station	of the	UAS	any	time	the	aircraft	is	operating.	These	documents
mus t	be	made	available	to	the	Administrator	or	any	law	enforcement	official	upon	request. 24.	The	UA	must	remain	clear	and	give	way	to	all	manned	aviation	operations	and	activities at	all	times. 25.	The	UA	may	not	be	operated	by	the	PIC	from	any	moving	devi ce	or	vehicle. 26.	All	Flight	operations	must	be	conducted	at	least	500	feet	from	all	nonparticipating persons,	vessels,	vehicles,	and	structures	unless: (a) Barriers	or	structures	are	present	that	sufficiently	protect	nonparticipating	persons from	the	UA and/or	debris	in	the	event	of an	accident.	The	operator	must	ensure	that nonparticipating	persons	remain	under	such	protection.	If	a	situation	arises	where nonparticipating	persons	leave	such	protection	and	are	within	500	feet	of	the UA,	flight operations must	cease	immediately	in a	manner	ensuring	the	safety	o f	nonparticipating persons;	and (b ) The	owner/controller	of any	vessels,	vehicles , or	structures	has	granted	permission	for operating	closer	to	those	objects	and	the	PIC	has	made	a	safety	assessment of the	risk	of operating	closer	to	those	objects	and	determined	that	it	does	not	present	an	undue	hazard. The	PIC,	VO,	operator	trainees	or	essential	persons	are	not	considered	nonparticipating persons	under	this	exemption. 27.	All	operations	shall	be	con ducted	over	private	or	controlled

- access	property	with permission	from	the	property	owner/controller	or	authorized	representative.	Permission from	property	owner/controller	or	authorized	representative	will	be	obtained	for	each flight	to	be	conducted.

28. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical boundaries	of the	operational	area	as	defined	by	the	applicable	COA	must	be	reported	to the	FAA's	UAS	Integration	Office	(AFS

- 80)	within	24	hours.	Accidents	must	be	repo rted	to the	National	Transportation	Safety	Board	(NTSB)	per	instructions	contained	on	the	NTSB Web	site:	www.ntsb.gov.
Petitioner’s UA	are rotorcraft,	weighing less than	55	lbs. including	payload.	They	operate, under	normal	conditions	at	a	speed	of no more	than	50	knots	and	they	have	the	capability to	hover,	and	move	in	the	vertical	and	horizontal	plane	simultaneously.	They	will	operate only	within	VLOS	and	only	within	the	restrictions	above	and	the	confidentially	submitted manual.	Such	operations	will insure	that	the	UA	will	"not	create	a	hazard	to	users	of the national	airspace	system	or	the	public."Given	the	small	size	o f	the	UA	involved	and	the	restricted	sterile	environment	within	which

they	will	operate,	the	applicant	falls	squarely	within	that	z one	o f	safety	(an	equivalent	level
o f	safety)	in	which Congress	envisioned	that	the	FAA	must,	by	exemption,	allow commercial	operations	of UA	to	commence	immediately.	Also,	due	to	the	size	of the	UA	and the	restricted	areas	in	which	the	relevant	UA	will	op erate,	approval	o f	the	application presents	no	national	security	issue. Since	the	UA	fully	loaded	weighs	no	more	than	55lbs.	and	is	operated	without	an	onboard pilot,	there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or	to dis play	them	on	the	unmanned	aircraft.	An	equivalent	level	of	safety	will	be	achieved	by keeping	these	documents	at	the	ground	control	poi nt	where	the	pilot	flying	the	UA	will have	immediate	access to	them.	Also,	given	the	size	o f	the	unmanned	aircraft,	the	FAA registration	number	will	be	displayed	on	the	airframe	in	as	large	a	font	as	possible.

**REGULATIONS FROM	WHICH	EXEMPTION	IS	NEEDED**  **14	C.F.R.	§	61.23(a) &**  **(c):	Medical	Certificates** Exemption#	11221,	#	11284,	and	many	others	have	provided	that	a	U.S.	driver's	license may be	used	in	lieu	of a medical	certificate in	providing	an	equivalent	level	of	safety.
**14	C.F.R.	§	61.101(e)(4) &**  **(5):	Recreational	Pilot	Privileges	and	Limitations &**  **14 C.F.R.	§	61.315(a):	Sport	Pilot	Limitatio**  **ns** Exemption#	11221,	#	11284,	and	many	others	have	declared	that	there	is	an	equivalent level	of	safety	as	the	FAR's	by	requiring	the	PIC	to	"hold	either	an	airline	transport, commercial,	private,	recreational,	o r	sport	pilot	certificate."	Likewise, Petitioner is	also performing	commercial	UAS	work	and	is	asking	for	the	same	restrictions	which	have	been previously	deemed	to	provide	an	equivalent	level	o f	safety	as	the	burdensome	regulations. **14	C.F.R.	§	61.113	(a ):	Private	Pilot	Privileges	and	Limitations:**  **Pilot	In	Command** Sub

- sections	61.113(a)	limit	private	pilots	to	non

- commercial	operations.	Because	the	UA will	not	carry	a	pilot	or	passengers,	the	proposed	operations	can achieve	the	equivalent level	of	safety o f	current	operations	by	requiring	the	PIC	operating	the	aircraft	to	have	a sport	pilot	license	rather	than	a	commercial pilot's	license	to	operate small	UAS.	Unlike	a conventional	aircraft	that	carries	the	pilot	and	passengers,	the	UA	is	remotely	controll ed with	no	living	thing	on	board. **14	C.F.R.	§	91.7(a ):	Civil	Aircraft	Airworthiness**  As	there	will	be	no	airworthiness	certificate	issued	for	the	unmanned	aircraft,	and	no	FAA regulatory	standard	will	exist	for	determining	airworthiness	of the	UA,	the	requ irements contained	in	the	confidentially	submitted	manual	and	the	restrictions	already	agreed	to will	provide	an	equivalent	level	of	safety. **14	C.F.R.	§	91.119:	Minimum	Safe	Altitudes** Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircra ft.	Section	91.119	(d) allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	provided	the person	operating	the	helicopter	complies	with	any	route	or	altitudes	prescribed	forhelicopters	by	the	FAA.	Because	of the	lack	of flammable	fuel,	a ny	risk	associated	with

these	operations	is	far	less	than	those	presently	presented	with	conventional	aircraft operating	at	or	below	500	AGL.	In	addition,	the	low

- altitude	operations	of the	UAS	will ensure	separation	between	these	small	UAS operations	and the	operations	o f	conventional aircraft	that	must	comply	with	Section	91.119. **14	C.F.R.	§	91.121:	Altimeter	Settings** This	regulation	requires	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."	As	the	UAS	may	not	have	a barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may	be	needed. An equivalent	level	of	safety	will	be	achieved	by	the	operator,	pursuant	to	following	the confidentially	submitted	manual.	Furthermore,	many	other	petitions	have	been	granted allowing	GPS	to	be	used	in	lieu	of an	altimeter	setting. **14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Cond itions**  Section	91.151	(a)	prohibits	an	individual	from	beginning	"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." Applicant	believes	that	an	equivalent	level	of safety	can	be	achieved	by	re stricting operations	to	"the	intended	operation	and	to	operate	after	that	for	at	least	five	minutes	or with	the	reserve	power	recommended	by	the	manufacturer	if	greater."	Exemption#	11284, at	page	5. **14	C.F.R.	§	91.405	(a);	§	91.407	(a)	(1);	§	91.409	(a) (2);	§	91.417(a)	&	(b):**  **Maintenance	Inspections** These	regulations	require	that	an	aircraft	operator	or	owner	"shall	have	that	aircraft inspected	as	prescribed	in	subpart	E	of this	part	and	shall	between	required	inspections, except	as	provided	in	paragraph (c)	of this	section,	have	discrepancies	repa ired	as prescribed	in	part	43	and shall	inspect	or	maintain	the	aircraft	in	compliance	with	Part	43. ” Given	that	these	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness certificate,	these	section s	will	not	apply	to	the	applicant. An equivalent	level	of safety	will be	achieved	because	these	small	UAS's	are	very	limited	in	size	and	will	carry	a	small payload	and	operate	only	in	restricted	areas	for	limited	periods	of time.	Moreover,	the operator	is the	person	most	familiar	with	the	aircraft	and	best	suited	to	maintain	the aircraft	in	an	airworthy	condition	to	provide	the	equivalent	level	of	safety.	Lastly,	the petitioner	will	operate	in	accordance	with	the	confidentially	submitted	manual	that	will pr ovide	an	equivalent	level	o	f	safety	as	the	burdensome	regulations.**CONCLUSION**

The	operation	of Petitioner’s small	UAS,	weighing	less	than	55lbs.,	conducted	under	the proposed	restrictions	outlined	above	as	well	as	the	confidentially	submitted	manuals ,	will provide	an	equivalent	level	of	safety	supporting	the	grant	of	the	exemptions	requested herein. Respectfully	yours,

Dan	Coplan Sky	Bandit	Pictures,	LLC