James Canale

3003 Ironwood Flat Drive High Point, NC 27265 January 7, 2016 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)
Dear Sir or Madam: I, James Canale, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, James Canale, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, James Canale, may operate my small ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal Aviation Administration (“FAA”). As described herein, I, James Canale, am a licensed Private Pilot and a licensed Airframe and Powerplant Mechanic; experienced in flying hobby fixed wing aircraft and rotary wing aircraft for recreational purposes. Following the exemption and approval by the FAA, I, will be using my professionally built DJI Phantom 3 Professional and DJI Inspire 1 UAS equipped with cameras forthe following commercial applications:

• Aerial photography and videography for public and/or private purposes for real estate listings, land surveying and development, architecture, and other related activities

• Aerial inspection of residential and commercial structures only under contract and permission with any registered owners orwith any local government authority

• Aerial photography and videography for public and/or private use including television, commercial advertising, special events, cinematography, and news gathering.

• Aerial photography and videography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when requested by the local authorities or government by contract or donation.

As described fully below, the requested exemption would permit the operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS’s within in tightly controlled, limitedairspaces, predetermined in areas away from the general public, airports, heliports and

vehicular traffic. Approval ofthis exemption request will comply with the Secretary of Transportation’s (FAAAdministrator’s) instructions to not only integrate UAS's into the national airspace system, but to “...establish requirements forthe safe operation ofsuch aircraft systems [UAS's] in the national airspace system.” Further I, James Canale, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. **I. The**  **contact information**  **of the**  **applicant is:**  James Canale 3003 Ironwood Flat Drive High Point, NC 27265 Phone: 720

-437

-0090 Email: jim.canale@yahoo.com **II. The**  **Specific Sections**  **of Title**  **14 of** **the Code**  **of Federal**  **Regulations from**  **wh ich**  **James Canale**  **Requests Exemption**  **are:** 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).
**I II.**  **The Extent**  **of relief** **James Canale**  **Seeks and**  **the Reason**  **He Seeks**  **Such Relief** 
I, James Canale, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relieffrom any currently applicable FARs operating to prevent my contemplated commercial cinematic, academic and otherflight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My ultra lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period bywhich the Reform Act requires the FAA to implement rules governing such craft. Thereby, providing direct experience and valuable information forformal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS's; Whetherthe UAS will be operated near airports or heavily populated areas; and, Whetherthe UAS will be operated by line of sight. 112 P.L. 95 § 333 (a).
The following items reflect in favor of my requested exemption. My UAS’s utilize four (4) or less rotating propellers for balance, control, and stability. My UAS’s are also equipped with altimeter, attitude indicator, ground speed indicator, magnetic compass, heading indicator, vertical speedindicator, course deviation indicator, radio magnetic indicator, GPS location, battery use

indicator, automatic circle mode, automatic return to launch, and automatic landing technology.
Each UAS weighing less than thirty

-five (35) pounds (far below the maximum 55 pound limit); Including camera(s) with orwithout gimbal (a camera stabilizer). I, James Canale, considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, circle in a specific place or loiter( figure 8 flight) via GPS and can be operated in winds up to 30.4 knots (35mph) wind. For safety reasons, I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released. With three (3) modes to choose from, I will fly with the modes safest to complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed slowly descend to point oftakeoffand orto land at point of launch after ascending to a pre-set altitude to ensure the UAS will clear any obstacles that may be between the takeoff point and the current position ofthe UAS. This failsafe altitude will not be set more than 200ft and is determined before each flight. I, James Canale, will not operate my UAS near airports, hospitals nor police heliports, and do not operate near areas where general public is within fifty to one hundred (50

-100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS’s are capable ofvertical and horizontal operations, and is flown only within my line of sight, as the remote control pilot. My UAS's are also flown with a second operatorwho aids in watching for any obstacles, including manned aircraft, within the flight zone ofthe UAS. Utilizing battery power ratherthan combustible fuels, flights generally last between three (10) to fifteen (15) minutes, with an altitude under one hundred fifty (150) feet. Smart Mode includes, position hold, self

-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. I, James Canale, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights forfuture commercial use to gain familiarization with the characteristics ofthis specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All forthe sake of safety. I, James Canale, am extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users ofthe national airspace system orthe public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directiveto integrate UAS's into the national airspace system. My UAS, used in hobby flight, has a

demonstrable safety record and does not pose any threat to the general public or national security. **IV. How**  **James Canale** **’ s**  **Request Will**  **Benefit the**  **Public As**  **A Whole**  I, James Canale, feel that my request for an exemption will in the public interest are as follows:

• I will be able to provide cost

-effective aerial photography services to businesses that may not have been able to afford this in the past, this will help these businesses grow and improve the local and national economy.

• The aerial imaging that I can provide will only have a positive impact on the city of High Point, NC by providing images for companies looking to relocate to this area as well as individuals looking to relocate for career advancement through academic and geographical awareness.

• The service that I can provide will be much betterforthe environment, the UAS’s that I operate are battery powered and create no harmful emissions.

• The small UAS’s that I will be operating will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft.

• The UAS will also be carried to the location in need of aerial footage, not flown there. The UAS will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flight **V. Reasons**  **Why James**  **Canale ’** **s Exemption**  **Will Not**  **Ad versely**  **Af fect**  **Safety Or**  **How The**  **Exemption Will**  **Provide a**  **Level of**  **Safety At**  **Least Equal**  **To Existing**  **Rule:** My exemption will not adversely affect safety. Quite the contrary, forthe reasons stated permitting me, James Canale, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as ofyet undiscovered safety protocols for Realtors, land, and structure owners. For development in cooperation with the FAA. In addition I, James Canale, submit the following representations of enhancements to current aerial videography and photography: My UAS’s weigh less than thirty

-five pounds complete with a an integrated ultra

-light weight camera.; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); My UAS only operate for 3

-30 minutes perflight; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by line of sight; and have live video feed for a secondary pilot to monitorvideo recording; I receive a live telemetryfeed from my UAS during all flights which include remaining battery voltage, distance, altitude, and any anomalies that may occur during flight.
My UAS’s Command and Control utilizes spread spectrum 2.4Ghz

-2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use. My UAS’s camera system utilizes 5.725Ghz

-5.875Ghz frequencies in accordance with CFR 47, Part 15. My UAS’s have a GPS controlled flight controller

- a flight safetyfeature whereby it hovers orcircles and then lands at the GPS takeoff point if communication with the remote control pilot

is lost; I actively record and analyze flight data through the DJI Inspire 1 and DJI phantom 3 flight controller app to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger. My personal safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photographyfor community awareness real estate, structured inspections, land management and search and rescue. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far saferto operate a battery powered ultra lightweight UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential forfire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated forfamiliarization/competency and will continue to operate at and above current safety levels.
**VI. A**  **Summary The**  **FA A**  **May Publish**  **in the**  **Federal Register:** 
14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my UAS’s permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces of legislation permit the FAA to exempt my, James Canale’s, UAS’s from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, James Canale’s, current and projected UAS's meet or exceed each ofthe elements.
14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. Anequivalent level of safety will be achieved by maintaining a safety/flight manual delineating

areas ofwhere safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.
14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing”
14 C.F.R. § 91.203 (a) and (b) provides forthe carrying of civil aircraft certifications and registrations. They are inapplicable forthe same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, James Canale.
B. 14 C.F.R. § 45.23: Marking ofThe Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS can be marked with the appropriate “N” number once this “N” number has been given.
C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. The sUAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.
D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 300ft AGL; safely below the standard of400 AGL. I, James Canale, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.
E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2, Manual
The above

-cited Regulations require, amongst otherthings, aircraft owners and operators to

“have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter.

. . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my James Canale’s, UAS. However, as a safety precaution I inspect my UAS before and after each flight.
A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthinesscertificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area

of my UAS permits exemption from Part 21 because my, James Canale’s, UAS meets an equivalent level of safety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each ofthe elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, James Canale, seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, James Canale’s, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural inspection land management, search and rescue and real estate operations, and to develop economic platforms forthe aforementioned to enhance the experience ofthose seeking to relocate, rebuild, reevaluate and to find in the metro High Point area. **Ad ditional**  **FA**

**A Required**  **Operating Conditions**  **and Limitations**  When not covered elsewhere in this Operations Manual, the following conditions and limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s)and equipment 2. The UA may not be flown at a speed exceeding a ground speed of 85 knots. 3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL. 4. The UAS must be operated within visual line of sight (VLOS) ofthe PIC at all times. his requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's state driver’s license.5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times, 6. If a discrepancy exists between these limitations and any procedure outlined elsewhere in this operations manual, the conditions and limitations herein take precedence and must be followed. 7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation orflight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. 9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. At a minimum, the following must be included in the operator's manual:

a. Actuators / Servos b. Transmission (single rotor)

c. Powerplant (motors) d. Propellers

e. Electronic speed controller f. Batteries g. Mechanical dynamic components (single rotor) h. Remote command and control i. Ground control station (if used) j. Any other components as determined by the operator 10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a current state driver’s license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.1 1. Prior to operations conducted forthe purpose of motion picture filming (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours oftotal time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

-building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

-building flights, all persons not essential forflight operations are considered non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 12. Prior to operations conducted forthe purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum offive hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

-offs and three landings in the preceding 90 days. Training, proficiency, experience

-building, and take

-offand landing currencyflights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

-building, and take

-off and landing currencyflights, all persons not essential forflight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from non-participants in accordance with 14 CFR § 91.119. 13. Prior to anyflight operations authorized by this grant of exemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion ofthe operator. A record of completion ofthis qualification process must be documented and made available to the Administrator upon request. 14. Prior to operations conducted forthe purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator

-approved and

-qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support ajurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitionerwill conduct these tests in accordance with the operator’s manual. 15. The UAS may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency. 16. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting production personnel. At all times, those persons must be essential to the closed

-set film operations. Because these procedures are specific to participating persons, no further FSDO orAviation Safety Inspector (ASI) approval is necessaryfor reductions to the distances specified in the petitioner’s manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate ofWaiverforMotion Picture and Television Filming

.17. Regarding distance from non-participating persons, the operator must ensure that no

persons are allowed within 500 feet ofthe area except those consenting to be involved and necessaryforthe filming production. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect non-participating persons (observers, the public, news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. 18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance with the operator’s manual. 19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 20. Each UAS operation must be completed within 30 minutes flight time orwith 25% battery power remaining, whichever occurs first. 21. The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operatorto request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. The operator must develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service ofthe UAS. These procedures must be added to the operator’s manual. 24. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual. 26. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections ofthe operator’s manual. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.28. At least three days before scheduled filming, the operator ofthe UAS affected by this

exemption must submit a written Plan ofActivities to the local FSDO with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence ofthe FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights b. Name and phone number ofthe person responsible forthe UAS filming production under this grant of exemption

c. Name and phone number ofthe person responsible forthe on-scene operation ofthe UAS. d. Make, model and serial or N

-number ofthe UAS to be used

e. Name and certificate number ofthe UAS PIC's involved in the filming production event f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list ofthose who gave permission must be made available to the inspector upon request. g. Signature of exemption

-holder or representative h. A description ofthe flight activity, including maps or diagrams of any area, city, town, county, and/or state overwhich filming will be conducted and the altitudes essential to accomplish the operation 29. The 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. These documents must be made available to the Administrator or any law enforcement official upon request. 30. The UAS must remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 32. The UAS cannot be operated by the PIC from any moving device orvehicle. 33. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 34. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 miles ofthe geographic center ofa non-towered airport as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted inaccordance with a NOTAM as required by the operator’s COA. The letter of agreement

with the airport management must be made available to the Administrator upon request. 35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Furtherflight operations may not be conducted until the incident, accident, ortransgression is reviewed by AFS

-80 and authorization to resume operations is provided. Currently, the aforementioned aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, James Canale”s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields.There are no personnel on board my, James Canale’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, James Canale’s, operation of my UAS, weighing less than thirty

-five (35) pounds and traveling at lower speeds within limited areas low to the ground will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, James Canale, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted,
James Canale 3003 Ironwood Flat Drive High Point, NC 27265