## LOW SEA PRODUCTIONS, INC. 333 Exemption Request

Sept. 24, 2015

Low Sea Productions, Inc.

1126 Hollywood Blvd.

Hollywood, FL

33019

Roger@LowSeaProductions.com

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act),

Low Sea Productions, Inc, (LSP) and owner Roger E. Lohse hereby apply for an exemption from

Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of small

unmanned aerial systems for the primary purpose of aerial photography and video.

LSP will offer safe, low altitude, and cost effective aerial imaging to the comm unities we serve.

A variety of industries will benefit; Home Real Estate, Commercial Real Estate, Marketing, Land

Development, Construction, and Property Inspections.

LSP will operate a DJI Inspire 1, a small unmanned aerial system (sUAS) equipped with

ad vanced flight control systems, high definition camera and gimbal, and advanced safety features.

The sUAV will be operated by a responsible PIC (pilot in command) and VO (visual operator), in

turn offering a safe and valuable experience to our clients.

1. The DJI Inspire 1 has a maximum takeoff weight of less than 6.5 pounds and thus offers a

light weight, small and compact video platform compared to manned aircraft.

2. The DJI Inspire 1 offers significant safety, noise, emission, security and environmental benefits

not available to larger manned aircraft.

3. The DJI Inspire 1 has numerous safety f eatures such as failsafe mode, automatic landing

should signal between PIC and UAS be interrupted, GPS based altitude and distance locks, flight

limiting features and low battery warnings.

4. Dual controllers provide the PIC (pilot in command) to focus on operating the sUAS while a

second individual operates the camera.

5. Inspire 1 safety features are addressed in more detail in the attached Inspire 1 user manual.

The safe operation of the UAS will be the first priority before, during and after every op eration.

1. All sUAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 200

feet AGL.

## LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request

Sept. 24, 2015

2. No sUAS operations will be conducted within 5 NM of an airport and will be in FAA class G

airspace.

3. No sUAS operations will occur directly over densely populated areas, un

- approved government

buildings, power lines, or major roads.

4. All sUAS operations will take place during daylight hours under conditions equival ent to

Visual Flight Rules (VFR) with the UAS no more than 1000 ft from the PIC.

5. All sUAS operations will have a PIC and VO present and all operations will be within visual

line of sight (VLOS) of both the PIC and VO.

6. PIC and VO will be able to ver bally communicate at all times.

7. The UAS will yield to all manned aircraft at all times.

8. All required permits and permissions will be obtained from local and state government should

they be required.

9. A pre

- flight inspection by the PIC will be pe rformed prior to each flight to assure that the UAS

is safe for flight. A post

- flight inspection will also be performed as an added level of safety.

10. Full aircraft inspections will be completed in accordance with manufactures instructions.

11. At no t ime shall the UAS be operated with missing or manufacturer unapproved parts, or in

any condition that could pose a hazard to any other aircraft or structure or person on the ground.

12. The sUAS will not be operated at a battery level below 20%.

13. Prio r to all UAS operations a pre

- flight meeting will be held by the PIC to determine the

parameters of flight in a given location, any hazards present, weather conditions, safety

procedures at the specific location and approximate duration and route of flight

.

14. The PIC will have a minimum of 10hrs flying time and operated atleast 50 individual flights

of similar sUAS multirotor aircrafts. It is my belief that small unmanned aerial systems, used by

experienced and responsible operators, following the polici es outlined above, operating in privacy

conscious way; will in turn offer aerial imaging to the general public in ways that are more cost

effective, safe, and efficient than the traditional methods of manned aircraft.

I respectfully request the FAA to gra nt an exemption to Low Sea Productions, INC, for

commercial UAS aerial photography operations under the Reform Act of 2012. If any of

procedures, policies, or content of this request do not meet the requirements of an exemption, it	isLow	Sea	Productions, Inc.’s		intention	to	adjust	its	policies	in	accordance	to	the	FAA’s

re quirements outlined in the granted exemption.

Sincerely,

Roger E. Lohse , President, Low Sea Productions, Inc.

1126 Hollywood Blvd.

Hollywood, FL

754

- 581

- 2678

Roger@LowSeaProductions.c om

## LOW SEA PRODUCTIONS, INC. 333 Exemption Request

Sept. 24, 2105

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Low Sea Productions Inc. (LSP) requests an exemption from the following regulations as well as

any additional regulations	that	apply	to	the	operation	of	DJI	Inspire	1	or	similar	sUAS’s	for

the	purpose	of	a erial photography and video.

14 C.F.R. 61.113(a) and (b) LSP will use specially trained staff to conduct the sUAS operations.

While these individuals will not hold commercial pilot licenses, they will have at least 10hrs of

flying time, have conducted at least 50 individual flights and read sUAS manufactures manuals

and operating procedures. In addition each PIC and VO will be required to sign a document

confirming the understanding of LSP operating and safety policies and the granted LSP

exemption.

The s UAS will not carry property for compensation or hire since they will be used solely to

provide our clients with aerial imaging. Without an exemption, the pilot would be required to

hold a commercial pilot certificate under §61.133. However, the risk associ ated with the

contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at

altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other

aircraft, and within a geographical envelo pe under the sole control of LSP clients.

Requiring a commercial pilot certificate would provide no appreciable safety benefit and would

needlessly impose additional cost on LSP. Because the contemplated operations would not

comply with §61.113(b)(1) and n one of the other exceptions to paragraph (a) apply, relief is

needed from both paragraphs (a) and (b).

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate.

While the F AA continues to work to develop airworthiness standards for UAS, we request an

experimental certificate be issued for the UAS operated by the applicant under either or both of

the following provisions:

21 .191 Experimental certificates.

Experimental certif icates are issued for the following purposes:

Research and development. Testing new aircraft design concepts, new aircraft equipment, new

aircraft installations, new aircraft operating techniques, or new uses for aircraft.

Showing compliance with regulatio ns. Conducting flight tests and other operations to show

compliance with the airworthiness regulations including flights to show compliance for issuance

of type and supplemental type certificates, flights to substantiate major design changes, and

## LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request

Sept. 24, 2015

flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market survey s,

sales demonstrations, and customer crew training, we would expect that an experimental

certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property and will only fly under strict operational

requirements.	As LSP’s sUAS	also	carries	no	combustible	fuel,	weighs	less	than	6.5	pounds

and is constructed primarily of plastics and composites, we propose the UAS is at least as safe, if

not significantly safer than conventionally certified aircraft used within similar parameters.

If an experimental airworthiness certificate is not appropriate for this application, then we

request an exemption of 14 CFR Part21, Subpart H, and the requirement for an airworthiness

certificate in general, citing the equivalent level of saf ety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned

to the aircraft and a registration certificate must be aboard the aircraft.

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the

cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.”

As the sUAS is too small to carry documentation, does not have an entrance and does not carry

a crew, we propose the following in order to meet the intent of 91.203 and provide an

equivalent level of safety. All documents deemed appropriate by the FAA for this aircraft will be

located at the operational ground station for each flight in proximity to the PIC and VO and will

be available for inspection on request. In order to identify the aircraft, we propose to use the

manufacturer’s	model	and	production	codes	located	on	the	aircraft	as	well	as	a	RentaSky

logo affixed t o the aircraft as well.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. The intent of this requireme nt is to ensure that flight manual

information is available to the aircrew while operating the aircraft.

LSP requests an exemption to this requirement as the UAS cannot, given its size, carry the

flight manual. To meet an equivalent level of safety, we pro pose to have the current

manufacturer’s	flight	manual	and	the	LSP	flight	manual	at	the	operational	grou nd station of

each flight, available to both the PIC and VO.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated

closer than 500 feet to any person, vessel, system, or structure. Since the UAS will be operating

at a maximum 200 feet AGL, we cannot comply with this requirement and thus ask for an

exemption. In order to p rovide an equivalent level of safety, we propose the following.

The UAS will only be operated within VLOS of the PIC and VO at a maximum range of 1000

feet from the ground station.

## LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request

Sept. 24, 2015

A pr eflight safety risk assessment will be completed prior to each flight to ensure the UAS is in a

condition for safe flight and that the planned operation can be compl eted	safely.		LSP’s

Flight Manual and Pre

- Flight Checklist is included as Appendix A and Ap pendix B.

The UAS will not be operated within 5 NM of any airport and will only be operated with the

consent of property manager and/or owner.

14 CFR 91.121 Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by r eference to an

altimeter setting available within 100 nautical miles of the aircraft.

The UAV will always be flying below 200 feet AGL within VLOS of the PIC and VO that will

provide separation from terrain, structures and other aircraft. Also, the UAS wil l continually

transmit an AGL reading back to the controller at the ground station and the AGL lock in the

UAS’s	software	will	be	set	to	400	feet,	providing	an equivalent level of safety.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

- VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. The UAS is smart battery powered and cont inually transmits battery

charge information back to the ground station to be evaluated by the PIC who will return the UAS

back to the ground station prior to the battery showing 20% remaining capacity. We feel that this

combined with the fact that the UAS will have a maximum range of 1000 feet from the ground

station provides an equivalent level of safety.

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b)

Maintenance, Preventive Maintenance, and Alterations.

We propose	that	the	PIC	perform	maintenance	and	inspection	and	“be	authorized	to

approve the	aircraft	for	return	to	service.”	As	provided	for	in	Appendix	A,	the	P IC will

inspect the aircraft prior to every flight to ensure it is in airworthy condition. A mai ntenance

check will also be performed at intervals instructed by the manufacturer, DJI. Any general

maintenance and repair or replacement of components will be completed	by	the	PIC	following

the	manufacturer’s recommendations and documented in accordance w ith 91.417. In any case

where the UAS cannot be returned to service by the PIC, or is suspected to be unsafe, the UAS

will not be operated until returned to all manufacturer specifications. We feel that due to the

simplicity, size, robustness and construct ion of the aircraft, the PIC can assure an equivalent level

of safety.

8900.227 Paragraph 16(cXa) PIG Medical. and Paragraph 16(eX1) Observer Medical

This policy provides that both the PIC and observer must have a valid FAA second

- class medical

certifica te issued under part 67 in order to perform as a pilot or observer. We feel that

requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying

passengers in a large aircraft is an unnecessary burden. Since the UAV is of smal l size,

## LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request

Sept. 24, 2015

unmanned, has an auto return home feature, will be operating at low altitudes, will not operate

over a densely populated area, and required to be in VLOS of the IC and VO at all times, we feel

both the PIC and VO requiring vision corrected to 20/20 and a valid	state	issued	driver’s	license

supports	medical	requirements.

APPENDIX A

Low Sea Productions, Inc. Flight Parameters and Restrictions :

1. All flights will occur in FAA Cl ass G airspace at no more than 2 00 feet AGL and no further

than 1000ft from the PIC.

2. The sUAS will not be flown faster than 40mph or as limited by FAA regulations.

3. All operations will utilize a PIC and VO with the PIC and VO able to communicate ver bally at

all times.

4. All operations will occur only during daylight hours and in weather conditions equivalent to

VFR.

5. All operations will occur at VLOS from the PIC and VO.

6. The PIC and VO will have a pre

- flight meeting at the site of the operat ion just prior to the

flight to assess weather, area of operation, topography, flight time, route, hazard mitigation and

overall operational and safety parameters. Also during this meeting, the pre

- flight aircraft

checklist (see Appendix B) will be impleme nted.

7. PIC is responsible for maintaining an established safe emergency landing plan if at any time

during the operation conditions become unfavorable due to unforeseen hazards, safety

concerns, or weather.

8. All operations will be reviewed prior to f light and conducted with the full permission of the

property owner or manger.

9. Flight planning will include the termination of the flight with 20% battery remaining, as

determined by the data link between the UAS and ground station.

10. The UAV will at all times give way to manned aircraft.

11. Prior to every flight, a highly visible launch banner will be placed at the site of the ground

station to	allow	an	outside	observer	to	determine	the	location	of	the	UAS’s	origin	and

command	point.

12. All permi ts required by state and local governments will be obtained prior to any operations.

13. No flight operations will occur without a successful pre

- flight inspection by the PIC before

## LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request

Sept. 24, 2015

each flight to determine that the UAS is in a condition for safe flight.

14. At the conclusion of each flight a post

- flight inspection will be done to assess the condition of

the UAS.

15. A full aircraft check will be performed in accordance with manufactures instructions.

16. Replacement	of	parts	shall	only	be	done	according	to	manufacturer’s	instructions.

17. All flight operations will be logged in a flight logbook.

18. All mainten ance done and inspections performed will be lodged in a maintenance log.

19. Check for software updates weekly and upload to UAS as needed to continually keep the

UAS software as current as possible.

APPENDIX B

Low Sea Productions, Inc. Pre

- Flight Chec klist :

1. Ensure the area identified for flight is considered FAA Class G airspace, winds conditions are

less than 15mph, and weather conditions are favorable.

2. Identify all potential obstructions and safety hazards in or near the area planned for fligh t.

3. Inspect all propellers for proper tightness and that they are free of cracks, dings, chips and

excessive wear.

4. Inspect all wiring and motors.

5. Inspect the airframe for cracks or damage.

6. Inspect battery voltage of UAS on

- board battery and Remo te Controller/Transmitter battery to

ensure there is sufficient energy in both systems for safe flight.

7. Turn off WiF i wireless on all devices located the person or within 10ft of the PIC and VO.

8. Recalibrate compass according to manufactur er’s	instruc tions.

9. Always turn on Remote Controller/Transmitter before turning on UAS battery.

10. Ensure that a link between Transmitter and UAS is established and that GPS link is

established.

11. Engage throttle, lift aircraft off the ground and verify the aircr aft responds properly to all

inputs and hovers accurately.