~OLSINELLI 1515 Wynkoop, Suite 600, Denver, C01 80202 • 303.572.9300 

August 7, 2015 

. ' .,:.1 , / .. 

VIA FED EX ONLY (TRACKING# 774239266680) 

U.S. Department ofTransportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Ramsey Ammar 

303-582-8229 

rammar@polsinelli.com 

Re: Petition of Autonomous Media LLC for Exemption Pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 ("FMRA") and 14 

C.P.R. Part 11, Autonomous Media LLC ("Autonomous Media"), operator of Small 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 with the enclosed Autonomous Media Operations Manual ("Flight Operations 

Manual"), in compliance with the 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 of a sUAS. 

I LEGAL AUTHORITY AND OVERVIEW 

1. Legal and Regulatory Framework 

1 The Flight Operations Manual and Operator's Handbook both contain confidential, trade secret and proprietary 

information that F4D Studio has not and will not share with others. Petitioner submits the Flight Operations Manual 

and Operator's Handbook and all information contained therein as proprietary and confidential information pursuant 

to 14 C.F.R. § 11.35(b). The Flight Operations Manual and Operator's Handbook contain operating conditions and 

procedures that are not available to the public and are protected from release under the Freedom of Information Act, 

5 U.S.C. § 552 et seq. 

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 California 
US Department ofTransportation 

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The FMRA provides that "the Secretary of Transportation shall determine if certain unmanned 

aircraft systems may operate safely in the national airspace system ... " prior to final completion 

ofthe required Reform Act plan and the subsequent rule-making. § 333(a). 

In making this determination, the Secretary of Transportation shall determine, at a minimum-

(1) Which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace 

system or the public or pose a threat to national security; and 

(2) Whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

§333(b) (1)-(2). Finally, §333 provides that "[i]fthe Secretary determines under this section that 

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. 

The FAA has recommended that 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 of UAS intended for use, operating 

procedures, and aircraft loading information; 

2. Operational procedures, including pre-flight inspections, maintenance, and repair; 

3. Radio Frequency ("RF") spectrum used for control of the UAS and associated equipment 

that is part of the UAS and whether it complies with Federal Communications 

Commission ("FCC") or other appropriate government oversight requirements; 

4. A description of the Pilot in Command ("PIC") directly responsible for the operation of 

the UAS, including the level of airman certificate held, any applicable training related to 

the operation, and any minimum hours of flight experience required by the PIC, both total 

flight time and the time with the particular UAS; 

5. The medical standards and certification of the PIC directly responsible for the operation 

of the UAS; 

6. The intended UAS operations, including how the operation would not adversely affect 

safety, or how they would provide a level of safety at least equivalent to that provided by 

the rule from which exemption is 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 safety mitigations associated with these proposed conditions; 

8. The characteristics of the area of intended operation and the associated potential hazards 

and proximity to populated areas; 

9. The proximity to airports; 

10. A description of how the application intends to operate the UAS within visual line-ofsight ("VLOS"); 
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Page 3 

11. Any procedures to conduct a preflight safety risk assessment to determine that the UAS is 

in a condition for safe flight and that the planned operation can be 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 

application intends to comply with such regulations; and 

13. The applicant's intent to obtain a Certificate of Waiver of Authorization ("COA'') from 

the FAA Air Traffic 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) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.P.R. § 11.81 

(petitions for exemption). 

2. Autonomous Media Meets and Exceeds the Legal and Regulatory Requirements 

As will be shown herein, Autonomous Media meets 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 of the FMRA. Each of the statutory criteria 

and other relevant 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 of safety beyond that existing when fixed or rotor 

wing aircraft are used to accomplish the same purpose. 

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, or pursuant to the prevailing FAA regulations and guidance, and will only operate within 

those areas described in the enclosed Flight Operations Manual. 

Given the small size of the sUASs involved and the restricted environment within which they 

will operate, the comprehensive safety and operational parameters used by Autonomous Media, 

and Autonomous Media commitment to compliance with the FAA's regulations now and into 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 of the sUASs and the restricted area in which the sUASs will 

operate, approval of the application presents no national security issue. 

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. 
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Considering the clear direction in §333 ofthe Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, 

and the significant public benefit, the grant of the requested exemptions is also in the public 

interest. Accordingly, Autonomous Media respectfully requests the FAA grant the requested 

exemption without delay. 

I MEET 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, 

including both the private and public sector, to provide the client images, videos and data needed 

to support and grow their business. The Autonomous Media team has extensive experience in 

both safely piloting sUASs and providing aerial photography, aerial videography and other aerial 

data collection services. 

Contact for Autonomous Media LLC: 

Autonomous Media LLC 

Attn: Harry De La Cruz 

3516 S. Mason St., Suite 1 

Fort Collins, CO 80525 

I PROPOSED 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 of Autonomous Media's 

proposed sUAS operations, below is a summary of operational limitations and conditions, which 

will ensure an equivalent or higher level of safety to operations conducted under current 

regulatory guidelines: 

1. The sUAS will weigh less than 55 pounds. 

2. Flights will be operated within line of sight of the Operator. 

3. Maximum total flight time for each operational flight will be limited to the 

amount oftime the sUAS can 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 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, or people not associated with the 

operation or who have not signed a waiver in advance ofthe operation. 

6. The sUAS Pilot with Pilot in Command responsibilities for the flight will be the 
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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 of the safety perimeter be present for this 

briefing. 

9. The Operator will have been trained in operations of sUAS generally and received 

up-to-date information on the particular sUAS to be operated as required in the 

Flight Operation Manual. 

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. If the sUAS loses transmission signal, the sUAS will have the capability to return 

to a pre-determined location and land. 

13. Contingency plans will be in place to safely terminate flight if there is a loss of 

transmitter communications or a loss of GPS signal. 

14. The sUAS will have the capability to abort a flight m case of unpredicted 

obstacles or emergencies. 

I REQUESTED EXEMPTIONS 

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, including sUASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. 

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 Petitioner has established which will ensure a level of safety better than or equal 

to the rules from which exemption is 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 the 
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August 7, 2015 

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procedural requirements for the issuance of airworthiness and registration certificates as required 

by 14 C.P.R. Given the size and limited operating area associated with the sUAS to be utilized 

by the Petitioner, an exemption from Part 21, Subpart H, meets the requirements of an equivalent 

level of safety under Part 11 and §333 of the FMRA. 

The Federal Aviation Act and §333 of the 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 of these 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 certificate without restrictions and conditions of the proposed sUAS operations. 

Equivalent Level of Safety 

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 of safety 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 of these same criteria 

demonstrates that there is no credible threat to national security posed by the sUAS, due to its 

size, speed of operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external load. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F .R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

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 same reasons Identified in the exemption request from 14 C.F .R. Part 21, Subpart H. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations 

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 of requiring a second-class medical certificate. This provision limits private pilots to noncommercial operations. 
US Department ofTransportation 

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Equivalent Level of Safety 

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. The risks associated with the operation of the sUASs are so 

diminished from the level of risk associated with commercial operations contemplated by part 61 

when drafted, that allowing operations as requested with a private pilot in the ground crew 

exceeds the present level of safety achieved by 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 

third persons when production 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 Media request that this exemption be 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 of this 

chapter." 

Equivalent Level of Safety 

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 by having the sUAS marked 

on its fuselage as required by § 45.29(f). In addition, Autonomous Media LLC is aware of 

Exemption No. 11333, which required the sUAS's markings to be "as large as practicable." The 

FAA has previously issued the following related exemptions to the aircraft marking requirements 

of§ 45.23(b): Exemption Nos. 10700, 10167 and 10167A. 
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E. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in 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 person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this 

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 the physical 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 simply no room or capacity to carry such an item on the aircraft. 

Equivalent Level of Safety 

The safety related purpose of this manual requirement can be equally satisfied by maintaining the 

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 ofthe UAS any time the aircraft is operating.") 

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

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 of Safety 

The Inspire 1 and Phantom 2 Vision Plus have a stellar safety record, demonstrating that the 

sUAS is airworthy. Further, given the size of the sUAS and the requirements contained in the 

Flight Operation Manual for maintenance and pre-flight safety check lists, an equivalent level of 

safety will be provided. 

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. 
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G. 14 C.F.R. § 91.103: Preflight Action 

Autonomous Media seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information contained in 

the FAA-approved flight manual on board the aircraft. While the Operator will be familiar with 

all information necessary to safely conduct the flight, an exemption is requested to the extent that 

an FAA-approved flight manual is required on board the aircraft. 

Equivalent Level of Safety 

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 takeoff distance, and aircraft performance data - before initiation of 

flight. The Operator's Handbook will be kept 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 the highest standards for safety within the industry. 

H. 14 C.F.R. § 91.105 Flight Crew Members at Stations 

Petitioner seeks an exemption from 14 C.F.R. 91.105, which provides that "each required flight 

crewmember shall be at the crewmember station ... keep the safety belt fastened ... [and] keep his 

or her shoulder harness fastened while at his or her assigned duty station. 

Equivalent Level of Safety 

In general, § 91.105 requires pilot and crew to be at their duty stations and harnessed during 

flight. Petitioner seeks exemption from Section 91.105 because the sUAS in the instant petition 

is by definition an unmanned aircraft, having neither pilot nor crew so as to be stationed or 

harnessed as required by the regulation. An equivalent or even higher level of safety can be 

provided instead by using an unmanned aircraft controlled by a PIC who at all times is located at 

and controls the sUAS from the ground control system. 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

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 of Safety 

Given the size and speed ofthe sUAS, an equivalent level of safe training can still be performed 

without dual controls because no pilot or passengers are aboard the sUAS, and all persons will be 

a safe distance away in the event that the sUAS experiences any difficulties during flight 

instruction. Flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight 
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Page 10 

training without fully functional dual controls for a number of aircraft and for flight instruction 

in experimental aircraft. See, Exemption Nos. 5778K & 9862A. The equivalent level of safety 

is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. Enhancing this safety is the technology inherent in the remote 

controls utilizing digital communications that are paired to the sUAS, making it nearly 

impossible to unintentionally or intentionally have the control communications interrupted. 

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. Exemptions include: Nos. 

5778K and 9862A. 

J. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

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 or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the 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 of the 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 of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 55 pounds 

proposed herein, and given the lack of flammable fuel, any 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 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 will be well aware of the planned flight operations as set forth in the Flight Operation 

Manual. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft 

that are subject to the minimum safe altitude regulations. Finally, the successful safety record of 

the Inspire 1 and Phantom 2 Vision Plus demonstrate that the sUAS can be safely used at these 

lower altitudes and closer operating environments. 
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K. 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 by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because the 

sUAS does not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in the 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): Fuel Requirements for Flight in VFR Conditions 

Autonomous Media requests an exemption from 14 C.P.R. § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states: 

(a) No person may begin 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. 

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 of its proposed operations within a predetermined area, a safety margin based on 

a reserve amount of battery life is needed. Petitioner will not be conducting any sUAS flights at 

night. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the sUAS. All flights will be planned to be terminated with no 

less than 25% reserve battery power still available. This restriction would be more 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 of the sUAS 

with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) 

was intended to alleviate given the size and speed of the small UAS, and the proximity of the 

flight operation to the landing zone. 

This request for exemption falls within the scope of prior exemptions, including Exemption Nos. 

10673, 2689F, 5745,10673, 10808 and 11333. 
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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 of 14 C.F.R. § 91.203(a) and (b). The regulation states in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate ... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is 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 could be displayed; and (3) 

there are no passengers or crew for whom the certificates need to be displayed. 

Equivalent Level of Safety 

To the extent these regulations are applicable to the proposed sUAS operations, an equivalent 

level of safety will be achieved by keeping these documents at the ground control point where 

the Operator will have immediate access to them. 

The FAA has issued numerous exemptions to this regulation, including: Exemption Nos. 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 of this part and shall between required ions 

... 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. 

Equivalent Level of Safety 

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 in the Flight Operation Manual, the operator will ensure that the sUAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. The operator is the person most familiar with the aircraft and best suited 
US Department ofTransportation 

August 7, 2015 

Page 13 

to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

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 of time 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 of UAS into the national airspace in 

controlled, safe working environments such as those propose in this petition. In addition, 

maintaining industrial safety has been a priority of state 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 of an unforeseen incident, a sUAS causes 

far less disruption than traditional aircraft. 

In addition, conducting aerial photography, aerial videography and other aerial data collection 

services with the sUAS, instead of manned aircraft, meets another common public concern in the 

noise and pollution caused by traditional aircraft. The use of a 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-off phase, and cannot be 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 property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of aircrew members located onboard the aircraft, 

the minimal size and weight of a 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 greatly diminished. 

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 services 
US Department of Transportation 

August 7, 2015 

Page 14 

operations. The UAS in question is very light weight and does not carry any flammable fuel, 

further reducing the risk from any potential accident. 

L-1 P_R_IV_A_C_Y _______________________________________ _ ----------------------------------------------------------

All ofthe proposed flights and videography will be only conducted after obtaining any individual 

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. The proposed 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, should it be determined that publication is 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 by reducing risk to Autonomous Media, 

the general public and property owners. 

The The Inspire 1 and Phantom 2 Vision Plus sUAS, weighing less than 55 pounds, with 

payload, and powered by batteries, eliminates virtually all of that risk given the reduced mass 

and lack of combustible fuel carried on board. 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 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 

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 or helicopters. 

I CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 
US Department ofTransportation 

August 7, 2015 

Page 15 

visual line of sight and national security-provides more than adequate justification for the grant 

ofthe requested exemptions to permit Autonomous Media to operate sUASs in support of aerial 

photography, aerial videography and other aerial data collection services operations in 

accordance with the 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, 

Ramsey Ammar 

Encls: Flight Operations Manual (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

sUAS Operator's Handbook (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

Exhibit A, Inspire 1 User Manual 

Exhibit B, Inspire 1 Charging Hub User Manual 

Exhibit C, Inspire 1 Maintenance Manual 

Exhibit D, Inspire 1 Quick Start Guide 

Exhibit E, 345s Quick-Release Propellers for the Inspire 1 

Exhibit F, Inspire 1 Release Notes 

Exhibit G, Inspire 1 Safety Guidelines 

Exhibit H, Intelligent Flight Battery Safety Guidelines 
US Department ofTransportation 

August 7, 2015 

Page 16 

Encls: Flight Operations Manual (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

sUAS Operator's Handbook (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

Exhibit A, Phantom 2 Vision Plus User Manual 

Exhibit B, 1 7 Aurora 9 Manual 

Exhibit C, 35 Optima 679 Manual 

Exhibit D, Ground Station User Manual 

Exhibit E, Checklist 

Exhibit F, Phantom 2 Vision Plus Disclaimer 

Exhibit G, Phantom 2 Vision Plus Pilot Training Guidelines 

Exhibit H, Phantom 2 Vision Plus Quick Start Guide 

Exhibit I, Phantom 2 Vision Plus Release Notes 

Exhibit J, Phantom 2 Vision Plus Smart Flight Battery safety Guidelines