June 28, 2015

Anton Ewing Video Solutions, LLC 2175 Cowle y Wa y San Diego, CA 92110 619

- 719

- 9640 Anton@antonewing.com

**Petition for Exemption Federal Aviation Administration**  Re: Unmanned Aircraft Sy stem (DJ I Phantom Quadcopter drone) use in NAS for compensation
Petitioner, Anton Ewing, hereb y petitions the Federal Aviation Administration (FAA) on behalf of himself and his employer, Video Solutions, LLC, for an exemption from Part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, wo uld allow operation of unmanned aircraft s ys tems (UAS) for the purpose of scripted, closed

- set filming for the motion picture and television industry

. The terms and conditions of Grant of Exemption No. 11062 are hereb y incorporated b y this reference as i f full y s et for herein with the exception of the mandatory 3 rd class medical certificate. Petitioner hereb y proposes the following terms and conditions for the grant of the exemption requested herein: The UA S proposed b y the petitioner is a proprietary design, conceived and constructed by Video Solutions, LL C. The UAS is referred to as a DJ I Phantom Quadcopter, and ha s four rotors and four motors in a quadcopter configuration. The UAS referenced h erein is under 4 5 lbs, wi ll be flown at all times under 3 00 feet AGL as measured b y the UAS GPS sy stem , kept within line of sight of the Pilot in Command, will have a separate safety observer at all times in communication with the PI C within 5 feet of eachother, will not be flown in excess of 40 mi les per hour , never flown at night, alway s using Visual Flight Rules and within visual line of sight, never using first person view by the PI C, the PIC will be able to use human vision unaided by any device other than corrective lenses as specified by a current state issued drivers license, with 72 hours advance notice to the local FSDO of flight operations, the PI C will have over 400 hours of logged flight experience in the same UAS ty pe or model, including 10 take offs and landings within the prior 30 day s, and a full and complete inspection of aircraft b y the PI C prior to take off.The PI C will 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 w ill be included in the operator’s manual: a. Actuators / Servos b. Transmissio n (single rotor) c. Powerplant (motors) d. Propellers e. Electronic speed controller f. Batteries g. Mechanical dy

namic components (single rotor) h. Remote command and control i. Ground control station (if used) j. Any other components as determine d by the operator
Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the nec essary 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 properl y documented in the aircr aft records. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator’s manual. T he PI C who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s manual.
Prior to operatio ns conducted for the 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 five hours as UAS pilot operating the make and model of UAS to be utilize d for operations under the exemption and three take

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

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the req uired flight time and 90 day currency . During training, proficiency , experience

- building, and take

- off and landing currency flights all persons not essential for flight operations are considered non

- participants, and the PI C must operate the UA with approp riate distance from non

- participants in accordance with 14 CFR § 91.119.Prior to any flight operations authorized by this grant of exemption, the PIC and visual observer (VO) must have successfull y 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 b y a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be docume nted and made available to the Administrator upon request.
Prior to operations conducted for the purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator

- approved and

- qualified pilot must be successfull y completed and documented. This documentation must be available for review upon request b y the Administrator. Because the knowledge and airmanship test qualifications have been developed b y the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and a pproval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual.
The UAS may

not be operated directly

over an y person, except authorized and consenting production personnel, below an altitude th at is hazardous to persons or property on the surface in the event of a UAS failure or emergency

. 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 or Aviation Safety Inspector (ASI) approval is necessary for 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 of Waiver for Motion Picture and Television Filming

. Regarding distance from non

- participating persons, the op erator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if it would not adversel y affect safet y and the Administrator has approved it. For example, an equivalent level of safet y may be determined b y an aviation safet y inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barrier s 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. If the 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.The UAS must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator’ s manual. Each UAS operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first. The PI C will request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to the operation

. The operator must develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be add ed to the operator’s manual. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins.
The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual. The prefli ght 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 inspec tion sections of the operator’s manual. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. At least three day s before sch eduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day notification may

be waived with the concurrence of the FSDO. The pl an of activities must include at least the following:

a. Dates and times for all flights b. Name and phone number of the operator for the UAS filming production conducted under this grant of exemption c. Name and phone number of the person responsible f or the on

- scene operation of the UAS d. Make, model, and serial or N

- number of UAS to be used e. Name and certificate number of UAS PI Cs involved in the filming production eventf. A statement that the operator has obtained permission from property o wners and/or local

officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request. g. Signature of exemption

- holder or representative A description of the flight activity , i ncluding maps or diagrams of any area, city , town, county , and/or state over which filming will be conducted and the altitudes essential to accomplish the operation The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PI C at the ground control station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. The UA must remain clear and yi eld the right of way to all other manned ope rations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). UAS operations may

not be conducted during night, as defined in 14 CFR § 1.1. All operations must b e conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. The UAS cannot be operated b y the PI C from any moving device or vehicle. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C. The UA may

not operate in Class B, C, or D airspace without written approval from the FAA. The UA may

not operate within 5 nautical miles of the geographic center of a 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 conduct ed in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. Any 1) incident, 2) accident, or 3) flight operation that transgresses the late ral or vertical boundaries of the operational area as defined b y 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 S afet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed b y AFS

- 80 and authorization to resume operations is provided. Unless otherwise specified in this grant of exemption, the UAS, PI C, and operator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.The Federal Aviation Administration by and through its authorized re presentative is requested to approve this petition based on the above terms and conditions for a certificate of authority and certificate of exemption to operate within the above parameters for compensation or hire within the United States National Air Spa ce. Respectfully

submitted: /s Anton A. Ewing
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