# ~OLSINELLI 1515Wynkoop, Suite 600, Denver, 

### C0 1 80202 • 303.572.9300 August 7, 2015

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VIAFED EX ONLY (TRACKING#774239266680) U.S. Department ofTransportation, Docket Operations West Building GroundFloor, Room w12-140 1200New JerseyAve., SE Washington, DC 20590 Ramsey Ammar 303-582-8229 rammar@polsinelli.com

Re: Petition ofAutonomous MediaLLC for Exemption Pursuant to Section 333 oftheFAA Modernization andReformActof 2012 Dear SirorMadam: Pursuant to Section 333 ofthe FAA Modernization andReformActof2012 ("FMRA") and 14 C.P.R. Part 11, Autonomous Media LLC ("Autonomous Media"), operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography, aerial videography and other aerial data collection services, hereby applies for an exemption from the below listed Federal Aviation Administration Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein, in accord withthe enclosed Autonomous Media Operations Manual ("Flight Operations Manual"), in compliancewiththe sUAS Operator's Handbook and all manufacturers' operations and/or instructions manuals ("Operator's Handbook") 1

, and in strict compliance any and all rules, regulations, and practices as may be established by the Federal Aviation Administration ("FAA") for the operation ofa sUAS. 

### ILEGAL AUTHORITY AND OVERVIEW

1. Legal and Regulatory Framework

1 The Flight Operations Manual and Operator's Handbook both contain confidential, trade secret and proprietary informationthatF4D Studio has not and will not share with others. Petitioner submits the Flight OperationsManual and Operator's Handbook and all information containedtherein as proprietary and confidential informationpursuant to 14 C.F.R. § 11.35(b). The Flight Operations Manual and Operator's Handbook contain operating conditions and proceduresthat are not available to the public and are protectedfrom release under the FreedomofInformationAct, 5U.S.C. § 552 etseq. polsinelli.com Atlanta Chicago Dallas Denver Kansas City Los Angeles Nashville New York Phoenix San Francisco St. Louis Washington, DC Wilmington Polsinelli PC, Polsinelli LLP in CaliforniaUS Department ofTransportation August 7, 2015 Page2 The FMRA provides that "the Secretary ofTransportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system

..." prior to final completion oftherequired ReformActplan and the subsequentrule-making. § 333(a). In makingthis determination, the Secretary ofTransportation shall determine, at aminimum- (1) Which types ofunmanned aircraft systems, if any, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line of sight do not create a hazard to users ofthe national airspace system orthe public orpose athreat to national security; and (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identifiedunderparagraph (1). §333(b) (1)-(2). Finally, §333 provides that "[i]fthe Secretarydetermines under this sectionthat certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system." §333(c). The FAA has promulgated guidance for UAS users that wish to obtain a Section 333 exemption. TheFAAhas recommendedthat an applicant discuss the following items: 1. The safe operation of a UAS to minimize risk to the National Airspace ("NAS"), including the operational characteristic for the type ofUAS intended for use, operating procedures, and aircraft loadinginformation; 2. Operational procedures, includingpre-flightinspections, maintenance, and repair; 3. Radio Frequency ("RF") spectrumused for control ofthe UAS and associated equipment that is part of the UAS and whether it complies with Federal Communications Commission ("FCC") or other appropriate government oversightrequirements; 4. A description ofthe Pilot in Command ("PIC") directly responsible for the operation of the UAS, including the level ofairman certificate held, any applicable training related to the operation, and anyminimumhours offlight experiencerequiredbythe PIC, bothtotal flight time and the time with theparticularUAS; 5. The medical standards and certification ofthe PIC directly responsible for the operation ofthe UAS; 6. The intended UAS operations, including how the operation would not adversely affect safety, orhowtheywouldprovide a level ofsafety at least equivalent to thatprovidedby the rule from which exemptionis sought; 7. The proposed maximum operating speed and altitude, and describe the minimum flight visibility and distance from clouds for their intended operations, including any potential hazards and safetymitigations associated with these proposed conditions; 8. The characteristics ofthe area ofintended operation and the associated potential hazards and proximityto populated areas; 9. Theproximityto airports; 10. A description ofhow the application intends to operate the UAS within visual line-ofsight ("VLOS");US Department ofTransportation August 7, 2015 Page 3 11. Anyprocedures to conduct apreflight safetyrisk assessmentto determine that theUAS is in a condition for safe flight and thattheplanned operation canbe completed safely; 12. To the extent the activity involves operations that have existing requirements, such as motion picture and television filming, or pipeline and power line control, how the applicationintends to complywith suchregulations; and 13. The applicant's intent to obtain a Certificate ofWaiver ofAuthorization ("COA'') from theFAAAirTraffic Organization. Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 44701(±) (permitting exemptions from §§ 44701(a), (b) and §§ 44702- 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) wouldbenefit thepublic as a whole, and (2) would not adversely affect safety (or how itwould provide a level ofsafety at least equal to the existing rules). See 14 C.P.R. § 11.81 (petitions for exemption). 2. Autonomous MediaMeets and Exceeds the Legal and Regulatory Requirements As will be shownherein, Autonomous Mediameets and exceeds the stated §333 requirements as well as the guidance promulgated by the FAA. The proposed operations in this petition for exemption qualify for expedited approval under §333 ofthe FMRA. Each ofthe statutory criteria and otherrelevant factors are satisfied. The proposed operations permit the use of small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access; and that ( 4) provides an increased level ofsafetybeyond that existing when fixed orrotor wing aircraft areusedto accomplishthe samepurpose. Autonomous Media sUAS are multi-rotor sUAS, weighing 55 or fewer pounds, including payload. They operate, under normal conditions, at low speed and have the capability to hover and move in the vertical and horizontal plane. Autonomous Media UASs will operate in line of sight, orpursuant to the prevailing FAA regulations and guidance, and will only operate within those areas describedinthe enclosed Flight Operations Manual. Given the small size ofthe sUASs involved and the restricted environment within which they will operate, the comprehensive safety and operational parameters usedby Autonomous Media, and Autonomous Media commitmentto compliancewiththe FAA'sregulations now andinto the future, this petition exemption falls within the equivalent level of safety that Congress desired the FAA to permit commercial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size ofthe sUASs and the restricted area in which the sUASs will operate, approval ofthe applicationpresents no national securityissue. Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger, (2) improving operations USES and decreasing operating costs, and (3) providing an environmentally conscientious way of producing aerial photography, aerial videography and other aerial data collection services operations.US Department ofTransportation August 7, 2015 Page4 Consideringthe clear direction in §333 oftheReformAct, the authority contained inthe Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant ofthe requested exemptions is also in the public interest. Accordingly, Autonomous Media respectfully requests the FAA grant the requested exemptionwithout delay. 

# IMEET AUTONOMOUS MEDIA LLC

Autonomous Media is a Colorado limited liability corporation that operates Small Unmanned Aircraft Systems equipped to conduct aerial photography, aerial videography and other aerial data collection services. Autonomous Media works with clients across many industries, includingboththeprivate and public sector, to provide the clientimages, videos and dataneeded to support and grow their business. The Autonomous Media team has extensive experience in both safelypiloting sUASs and providing aerial photography, aerial videography and other aerial datacollection services. Contactfor Autonomous MediaLLC: Autonomous MediaLLC Attn: HarryDe LaCruz 3516 S. Mason St., Suite 1 Fort Collins, CO 80525 

### IPROPOSED OPERATIONS

The enclosed Manuals describe, in detail, the policies and procedures for Autonomous Media's proposed sUAS operations. To assist the FAA in its safety assessment ofAutonomous Media's proposed sUAS operations, below is a summary ofoperational limitations and conditions, which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines: 1. The sUAS will weighless than 55 pounds. 2. Flights willbeoperatedwithin line ofsight ofthe Operator. 3. Maximum total flight time for each operational flight will be limited to the amount oftimethe sUAS canbe flown and still maintain a reserve batterypower ofno less than 25%. 4. Flights will be operated at an altitude ofno more than 500 feet Above Ground Level ("AGL"). 5. Flights will be operated at a safe lateral and vertical distance from and above any inhabited structures, buildings, vehicles, vessels, orpeople not associated with the operation orwho havenot signed a waiverin advance oftheoperation. 6. The sUAS Pilot with Pilot in Command responsibilities for the flight will be theUS Department ofTransportation August 7, 2015 Page 5 designated Operator ("Operator"). 7. The sUAS will operate only within a confined area as described in the Flight Operations Manual. 8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safetyperimeterbepresentfor this briefing. 9. The Operatorwill havebeentrained in operations ofsUAS generally and received up-to-date information on the particular sUAS to be operated as required in the Flight OperationManual. 10. Written and/or oral permission from the relevant property holders will be obtained. 11. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 12. Ifthe sUAS loses transmission signal, the sUAS will have the capability to return to apre-determined location and land. 13. Contingency plans will be in place to safely terminate flight ifthere is a loss of transmitter communications or aloss ofGPS signal. 14. The sUAS will have the capability to abort a flight m case of unpredicted obstacles or emergencies. 

# IREQUESTED EXEMPTIONS

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, byits terms, includes exempting civil aircraft, as the term is defined under § 40101 ofthe Act, including sUASs, from its safetyregulations and minimum standards when the Administrator decides arequested exemptionis inthe publicinterest. Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 for purposes of conducting aerial photography, aerial videography and other aerial data collection services, and other aerial data collection services. Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards that Petitionerhas established which will ensure a level ofsafetybetterthan or equal to the rules from which exemptionis sought. A. 14 C.F.R. Part 21, Subpart H - Airworthiness Certificates and 14 C.F.R. 

### § 91.203(a) and (b) Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes theUS Department ofTransportation August 7, 2015 Page6 procedural requirements for the issuance ofairworthiness and registration certificates as required by 14 C.P.R. Given the size and limited operating area associated with the sUAS to be utilized bythe Petitioner, an exemption from Part 21, SubpartH, meets the requirements ofan equivalent level ofsafetyunderPart 11 and §333 ofthe FMRA. The Federal Aviation Act and §333 ofthe FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness or registration certificate, in the restricted environment and under the conditions proposed, will be at least as safe as, or safer than, a conventional rotorcraft operating with an airworthiness certificatewithoutrestrictions and conditions ofthe proposed sUAS operations. Equivalent Level ofSafety The sUAS to be operated hereunder, Inspire 1 and Phantom 2 Vision Plus, both are multi-rotor sUAS, which weigh less than 55 pounds with payload, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and sterile area. Unlike other civil aircraft, the proposed operations will be controlled and monitored by the Operator pursuant to the Flight Operations Manual's requirements, as attached. These safety enhancements, which already apply to civil aircraft operated in connection with existing aerial photography, aerial videography and other aerial data collection services operations, provide a greater degree ofsafety to Autonomous Media's employees, members of the public, and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load. B. 14 C.F.R. Part27 Airworthiness Standards: Normal Category Rotorcraft 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification ofnormal category rotorcraft. To the extent Autonomous Media would otherwise require certification under Part 27, Autonomous Media seeks an exemption from Part 27's airworthiness standards for the samereasons Identified inthe exemptionrequest from 14 C.F.R. Part21, Subpart H. C. 14 C.F.R. § 61.113: Private Pilot Privileges AndLimitations Petitioner seeks an additional exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also have the effect ofrequiring a second-class medical certificate. This provision limits private pilots to noncommercial operations.US Department ofTransportation August 7, 2015 Page 7 Equivalent Level ofSafety Because the sUASs will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring a ground crew member to have a private pilot's license rather than

## a commercials pilot's license to operation this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. Therisks associated withthe operation ofthe sUASs are so diminished from the level ofrisk associated with commercial operations contemplatedbypart 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds thepresentlevel ofsafety achievedby 14 C.F.R. Sec. 61.113(a) and (b). In addition, in Grant of Exemption No. 11062 to Astraeus Aerial ("Astraeus"), the FAA determined that an Operator with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Additionally, as previously determined by the Secretary of Transportation, the requirement to have an airman certificate ameliorates security concerns over civil UAS operations conducted in accordance with §333. The aerial data collection conducted by Autonomous Media will be conducted in areas where access to the public is limited and controlled. As such, the operations will have no substantial impact on any third persons not involved in the production. Autonomous Media also has a policy to conduct its operations, when possible, during times when third persons not involved in the production are expected to be limited and to the extent possible, to provide notice to affected thirdpersons whenproduction and operations will occur. Because Autonomous Media will operate in controlled areas and under controlled parameters, the sUAS will be flown based on visual line-of-sight at altitudes below 500' AGL. Accordingly, Autonomous Mediarequest thatthis exemptionbe granted. D. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Petitioner seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that "[n]o person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter." Equivalent Level ofSafety The equivalent level of safety for exemptions to the aircraft marking and identification requirements of§§ 91.9(c), 45.23(b) and 45.27(a) will be provided byhaving the sUAS marked on its fuselage as required by § 45.29(f). In addition, Autonomous Media LLC is aware of ExemptionNo. 11333, which required the sUAS's markings to be "as large as practicable." The FAAhas previouslyissuedthe following related exemptions to the aircraftmarkingrequirements of§ 45.23(b): ExemptionNos. 10700, 10167 and 10167A.US Department ofTransportation August 7, 2015 Page 8 E. 14 C.F.R. § 91.9(b)(2): CivilAircraftFlightManualin the Aircraft Autonomous Media seeks an exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(2), which states: (b) No personmayoperate aU.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings and placards, or any combination thereof. Given thephysical dimensions ofthe sUAS, configuration and load capacity, the sUASs have no ability to carry such a manual on the aircraft, not only because there is no pilot on board, but because there is simplyno room or capacityto carry such an item onthe aircraft. Equivalent Level ofSafety The safetyrelatedpurpose ofthis manual requirement canbe equally satisfiedbymaintainingthe sUAS flight manual at the ground control point where the Operator will have immediate access to it. Accordingly, Autonomous Media requests an exemption from 91.9(b)(2)'s flight manual requirements, on the condition that the sUAS flight manual be available at the control point during each operation. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700, and 11333 ("documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station oftheUAS anytime the aircraftis operating.") F. 14 C.F.R. §91.7(a): CivilAircraftAirworthiness Autonomous Media seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the sUAS, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Equivalent Level ofSafety The Inspire 1 and Phantom 2 Vision Plus have a stellar safety record, demonstrating that the sUAS is airworthy. Further, given the size ofthe sUAS and the requirements contained in the Flight Operation Manual for maintenance and pre-flight safety check lists, an equivalent level of safetywillbeprovided. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738,9299,9299A,9565,9565B, 10167, 10167A, 10602,32827, 10700,and 11333.US Department ofTransportation August 7, 2015 Page 9 G. 14 C.F.R. § 91.103: PreflightAction Autonomous Media seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific informationbefore each flight, including information contained in the FAA-approved flight manual on board the aircraft. While the Operator will be familiar with all informationnecessaryto safely conductthe flight, an exemptionis requested to the extentthat an FAA-approved flight manual is required onboardthe aircraft. Equivalent Level ofSafety An equivalent level of safety will be provided by following the Operator's Handbook. The Operator will take all required preflight actions

- including reviewing weather, flight battery requirements, landing and takeoffdistance, and aircraft performance data

- before initiation of flight. The Operator's Handbook will bekept at the ground station with the operator at all times. Further, Autonomous Media will utilize all safety and manufacturer's manuals to ensure it adheres to thehighest standards for safetywithinthe industry. H. 14 C.F.R. § 91.105 Flight CrewMembers at Stations Petitioner seeks an exemption from 14 C.F.R. 91.105, whichprovides that "eachrequired flight crewmember shall be at the crewmember station

...keep the safetybelt fastened

... [and] keep his orher shoulderharness fastened while athis orher assigned duty station. Equivalent Level ofSafety In general, § 91.105 requires pilot and crew to be attheir duty stations and harnessed during flight. Petitioner seeks exemption from Section 91.105 because the sUAS inthe instantpetition is bydefinition an unmanned aircraft, havingneitherpilotnor crew so as to be stationed or harnessed as requiredbytheregulation. An equivalent orevenhigherlevel ofsafetycanbe provided insteadbyusing an unmanned aircraft controlledbyaPIC who at all times is located at and controls the sUAS from the ground control system. I. 14 C.F.R. § 91.109(a): FlightInstruction Autonomous Media seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." sUASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a box that communicates with the aircraft via radio communications. Equivalent Level ofSafety Given the size and speed ofthe sUAS, an equivalent level ofsafe training can still beperformed without dual controlsbecauseno pilot orpassengers are aboard the sUAS, and all persons willbe a safe distance away in the event that the sUAS experiences any difficulties during flight instruction. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flightUS Department ofTransportation August 7, 2015 Page 10 training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See, ExemptionNos. 5778K & 9862A. The equivalent level ofsafety is providedbythe fact that neither apilotnor passengers will be carried in the aircraft andbythe size and speed ofthe aircraft. Enhancing this safety is the technology inherent in the remote controls utilizing digital communications that are paired to the sUAS, making it nearly impossibleto unintentionally orintentionallyhave the control communications interrupted. TheFAAhas approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. Exemptions include: Nos. 5778K and 9862A. J. 14 C.F.R. §91.119: Minimum SafeAltitudes Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons orproperty onthe surface," providedthat "eachperson operatingthehelicopter complies with anyroutes or altitudes specificallyprescribed for helicoptersbythe FAA." To provide the intended aerial photography, aerial videography and other aerial data collection services operations, the sUAS is normally operated below 500 feet AGL. Additionally, due the nature ofthe proposed operations, the sUAS will maintain a safe lateral and vertical distance from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation. Equivalent Level ofSafety Compared to flight operations with rotorcraft weighing far more than the maximum 55 pounds proposed herein, and given the lack offlammable fuel, anyrisk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe UAS, as well as the location where itis operated. As set forth in the Flight Operation Manual, the sUAS will be operated in a confined area, where buildings and people will not be exposed to operations without their pre-obtained consent. Because of the advance notice to the property owners and participants, all affected individuals willbewell aware oftheplanned flight operations as set forth inthe Flight Operation Manual. Furthermore, byoperating at such lower altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safetyrecord of the Inspire 1 and Phantom 2 Vision Plus demonstrate that the sUAS can be safely used at these lower altitudes and closeroperating environments.US Department ofTransportation August 7, 2015 Page 11K. 14 C.F.R. § 91.121: Altimeter Settings This petition seeks an exemption from 14 C.P.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level byreference to an altimeter that is set to the elevation ofthe departure airport or barometric pressure. An exemption is required because the sUAS does nothave abarometric altimeter, butrather a GPS altitude read out. Equivalent Level ofSafety An equivalent level ofsafety will be achieved byfollowing the procedures set forth inthe Flight Operation Manual. As prescribed in the Flight Operation Manual, the operator will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the Operator will use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe altitudes. L. 14 C.F.R. § 91.151(a): FuelRequirements for Flightin VFR Conditions Autonomous Media requests an exemption from 14 C.P.R. § 91.151(a)'s fuel requirements for flight inVFR conditions. Section 91.151 states: (a) No person maybegin 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 ofintended landing and, assuming normal cruising speed

- (1) Duringthe day, to fly afterthat for at least 30 minutes; or (2) Atnight, to fly afterthat for at least 45 minutes. Here, the battery powering the Inspire 1 and Phantom 2 Vision Plus provides approximately 15 minutes ofpowered flight. To meet the 30 minutes reserve requirement in 14 C.P.R.§ 91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location ofits proposed operations within apredetermined area, a safetymarginbased on a reserve amount ofbattery life is needed. Petitioner will not be conducting any sUAS flights at night. Equivalent Level ofSafety An equivalent level ofsafety will be achieved because the operations will be conducted on-site without significant transit timebythe sUAS. All flights will beplanned to be terminated with no less than 25% reservebatterypower still available. This restriction wouldbemore than adequate to return the sUAS safely to the ground and its planned landing zone from anywhere in its limited operating area even in the event of an unexpected occurrence. Operation ofthe sUAS with less than 30 minutes ofreserve fuel does not includethe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS, and the proximity ofthe flight operationto the landing zone. This request for exemption falls within the scope ofprior exemptions, including Exemption Nos. 10673, 2689F, 5745,10673, 10808 and 11333.US Department ofTransportation August 7, 2015 Page 12 M. 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration Autonomous Media seeks an exemption from civil aircraft certification and registration requirements of14 C.F.R. § 91.203(a) and (b). Theregulation states inpertinentpart: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that itis legible to passengers or crew. An exemption to this regulation is necessary because: (1) the sUAS's configuration, load capacity and size does not allow it to carry certification and registration documents; (2) the sUAS does not have a cabin or cockpit entrance at which documents couldbe displayed; and (3) there are no passengers or crew for whomthe certificates need to be displayed. Equivalent Level ofSafety To the extent these regulations are applicable to the proposed sUAS operations, an equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the Operatorwill have immediate access to them. The FAAhas issuednumerous exemptions to this regulation, including: ExemptionNos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. M. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections Autonomous Media also seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired ions

...have discrepancies repaired as prescribed in part 43 ofthis chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, whichthe sUAS will nothave. Equivalent Level ofSafety An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Operator's Handbook as referenced in the Flight Operation Manual. As provided inthe Flight OperationManual, the operator will ensurethatthe sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenanceperformed. The operatoris the personmost familiar withthe aircraft andbest suitedUS Department ofTransportation August 7, 2015 Page 13

to maintainthe aircraft in an airworthy conditionto providethe equivalentlevel ofsafety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will only take place in restricted areas for limited periods oftime during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation. 

### I**PUBLI~** INTEREST

Granting Autonomous Media's exemption furthers the public interest on numerous levels. National policy set by Congress favors early integration ofUAS into the national airspace in controlled, safe working environments such as those propose in this petition. In addition, maintainingindustrial safetyhas been apriorityofstate and local governments for decades. Autonomous Media also believes that the use of sUASs for aerial photography, aerial videography and other aerial data collection services serve a valuable public interest and addresses a common public concern: safety. The use of sUAS's in a controlled and safe manner, as described herein. In addition, in the event ofan unforeseen incident, a sUAS causes far less disruptionthantraditional aircraft. In addition, conducting aerial photography, aerial videography and other aerial data collection services with the sUAS, instead ofmanned aircraft, meets another commonpublic concerninthe noise and pollution caused by traditional aircraft. The use ofa sUAS significantly reduces the levels of air and noise pollution generated during traditional aerial photography, aerial videography and other aerial data collection services operations. By using battery power and electric motors, the sUAS produces no air pollution, and is the most viable environmentally conscious alternative to piston or turbine powered rotorcraft. The sUAS, while reducing the carbon footprint of [LIST OF USES], also eliminates noise pollution as its battery powered electric motors are barely audible during the take-offphase, and cannotbe heard when operating more than 100 feet above ground level. By using the sUAS to perform aerial photography, aerial videography and other aerial data collection services, the substantial risk to life and propertyinthe air and on the ground, which is usually associated withtraditional manned aircraft flight operations, will be substantiallyreduced or completely eliminated. Aside from the lack ofaircrew members located onboard the aircraft, the minimal size and weight ofa sUAS creates less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial photography, aerial videography and other aerial data collection services. Relatedly, the sUAS contains no reactive or combustible materials on board and thus the potential for fire or explosions is greatlydiminished. In addition, granting the exception will help advance the knowledge base for conducting commercial UAS operations. This additional data will help the FAA set future rules regarding UAS flight operations, maintenance, and crew qualifications. The public also has an interest in reducing the hazards and emissions associated with alternate use of helicopters to conduct similar aerial photography, aerial videography and other aerial data collection servicesUS Department ofTransportation August 7, 2015 Page 14 operations. The UAS in question is very light weight and does not carry any flammable fuel, further reducingtherisk from anypotential accident.

L-1

P_R_IV_A_C_Y

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---------------------------------------------------------- All oftheproposed flights and videographywill beonly conducted after obtaining anyindividual subject matter's permission. All flights will occur over public right-of-way or private property with the property owner's prior consent and knowledge. Theproposed operations will not impact privacy concerns beyond those already implicated by manned aircraft aerial data collection operations.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, shoulditbedetermined thatpublicationis needed: Autonomous Media seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 45.27 (a); 14 C.F.R. 61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.9(c); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(l)and (2); 14 CFR 91.417 (a) & (b). Approval of these exemptions allowing commercial operations of small and lightweight unmanned aircraft ("sUAS") to conduct aerial photography, aerial videography and other aerial data collection services operations will enhance safety byreducing risk to Autonomous Media, the general public andpropertyowners. The The Inspire 1 and Phantom 2 Vision Plus sUAS, weighing less than 55 pounds, with payload, and powered by batteries, eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried onboard. The sUAS is transported to the designated survey area set up. It is not flown from an external location to the work-site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofthis small UAS will provide an equivalent level ofsafety, supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground, and in a controlled environment. As a result, they are far safer than conventional aerial photography, aerial videography and other aerial data collection services operations are conducted with fixed wing aircraft orhelicopters.

I CONCLUSION

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012-size, weight, speed, operating capabilities, proximity to airports and populated areas and operation withinUS Department ofTransportation August 7, 2015 Page 15 visual line ofsight and national security-providesmore than adequatejustification for the grant oftherequested exemptions to permit Autonomous Mediato operate sUASs in support ofaerial photography, aerial videography and other aerial data collection services operations in accordance withthe Flight Operation and Operator's Handbook appended hereto. Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger, (2) improving aerial photography, aerial videography and other aerial data collection services operations and decreasing operating costs, and (3) providing an environmentally conscientious way of producing aerial photography, aerial videography and other aerial data collection services operations. Sincerely,

RamseyAmmar

Encls: Flight Operations Manual (CONFIDENTIAL- NOT FORPUBLIC RELEASE) sUAS Operator's Handbook (CONFIDENTIAL- NOT FORPUBLIC RELEASE) ExhibitA, Inspire 1UserManual Exhibit B, Inspire 1ChargingHub UserManual Exhibit C, Inspire 1Maintenance Manual Exhibit D, Inspire 1 Quick Start Guide ExhibitE, 345s Quick-ReleasePropellers for the Inspire 1 ExhibitF, Inspire 1ReleaseNotes Exhibit G, Inspire 1 Safety Guidelines Exhibit H, IntelligentFlightBattery Safety GuidelinesUS Department ofTransportation August7, 2015 Page 16 Encls: Flight Operations Manual (CONFIDENTIAL- NOT FORPUBLIC RELEASE) sUAS Operator's Handbook (CONFIDENTIAL- NOT FORPUBLIC RELEASE) ExhibitA, Phantom2 VisionPlus UserManual ExhibitB, 1 7 Aurora 9 Manual Exhibit C, 35 Optima 679 Manual ExhibitD, Ground StationUserManual Exhibit E, Checklist Exhibit F, Phantom 2 VisionPlus Disclaimer Exhibit G, Phantom2 VisionPlus PilotTraining Guidelines ExhibitH, Phantom2 VisionPlus Quick Start Guide Exhibit I, Phantom2 VisionPlus ReleaseNotes ExhibitJ, Phantom2 VisionPlus SmartFlightBattery safety Guidelines