US Department ofTransportation Exemption Request Pursuant to Section 333 of the FAA

·< Reform Act and Part 11 ofthe Federal Aviation
February 8, 2016

Robert Louis Jurotich Drone 1Cine 11932 Lockhaven Place Saint Louis. MO 63128 

### Drone1cine@gmail.com

U.S Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590 1.,,,.}

Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart 

### H; 14CFR 45.23(b); 14 CFR 61.113(a) and (b); 14CFR 91.7(a); 14 CFR91.9(b)(2); 14CFR 91.103; 14 CFR 91.109; 14CFR 91.119(c); 14CFR 91.121; 14CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b)

The exemption is in the public interest. Pursuanttothe authority contained in 49 U.S.C. 106(f), 40113, and 44701.

Dear Sir or Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the

11Reform Act11) and 14CFR Part 11 of Unmanned Aircraft Systems (UAS), Robert Louis Jurotich Regulations rFARs 11) to allow commercial operation of Designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established bythe FAA as required by Section 333.

Thankyou in advance foryour consideration.Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following
areas:



### 1. Aerial photographyand Videography 2. Real Estate 3. Crops 4. Search and rescue 5. Police and fire dept 6. Land surveying 7. Musicvideos 8. Advertisement 9. Training Others on UAV Safetyand Flying

As described fully below, the requested exemption would permitthe operation of designated UAS as setforth in this document undercontrolled conditions in the NASthat would be a) limited b) controlled c) predetermined and d) safe. Approval ofthis exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfilling the Secretary ofTransportation 1 S (the FAA Administrator1s) responsibilities to 11

.... establish requirements forthe safe operation of such aircraft systems in the national airspace system. 11

The name and address ofthe applicant is



### Robert Louis Jurotich Drone 1Cine 11932 Lockhaven Place Saint Louis. MO 63128 Drone1**cine@gmail.~om**


### From which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 

### &(b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a) 14 CFR 91.409 (a) 14 CFR 91.417 (aAs in Grants of Exemption Nos. 11062to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), and 12645to Allied Drones (see Docket No. FAA-2014-0804), There is enhanced safety achieved using an unmanned aircraft (UA) with the specifications described bythe petitioner and carrying no passengers orcrew, ratherthan a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, givesthe FAA good causeto find thatthe UAS operation enabled bythis exemption is in the public interest.

Robert Louis Jurotich Will operate one or more ofthe Following model UAS.

YuneecTyphoon QSOO 4K

Safety requirements. The approval ofthis application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grantofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grantthe requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhancethe safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1.The UAS will weigh significantly lessthan 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no morethan 50mph.

3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/or Visual Observer (VO).4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlight time whichever occurs first.



### 5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.



### 6. Minimum crewfor each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of 20 hours on the designated UAS.

8. A safety briefing will be performed priorto each day•s flights consisting of all the days• Production activities.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closerthan a mile radius ofthe geographic center/Airport Reference Point (ARP) ofatower controlled or uncontrolled airport.

12. Flights will not be closerthan a 5 mile radius ofthe geographic center/Airport.

13. The operatorwill do a pre check of aircraft priorto each flight. And log each flight.

14. The operatorwill obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting personswill be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department of Transportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive uptodate information for the particular UASto be operated.

16. The PIC and VOwill be able to communicate byvoice and/or radio at all times.

17. The PIC will abide byall rules

18. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UASwill havethe capabilityto return to a predetermined location within a designated location and land autonomously.

19. The UASwill have the capabilityto abort a flight in case of emergencies with
an automated 11Return Home and Land 11 function.

20. The UAS will havethe capabilityto abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery.

21. Any incident, accident, orflight operation thattransgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA must be reported to the FAA•s 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.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishesthe procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meetsthe requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated
areas ofthe particular UAS. In all cases, an analysis of these criteria demonstratesthatthe UAS operated without an airworthiness certificate in the restricted environment and underthe conditions proposed will be at least as safe,
orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusivelywithin a secured and designated area. Unlike other civil aircraft, operations underthis exemption will betightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degreeof safetyto the public and property ownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part

### 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed bythe UAS, dueto its size, speed of operation, location ofoperation, lack of explosive materials orflammable liquid fuels, and inabilityto carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks include onlythe Roman capital letter 11N11 and the registration number is displayed on limited, restricted or light sport category aircraftor experimental or provisionally certificated aircraft, the operator must also display on that aircraft
near each entranceto the cabin, cockpit, or pilot station, in letters not lessthan 2 inches nor more than 6 inches high, the words 11limitedl' 11restricted/' 11light sport/'

11experimental!' or 11provisionall' as applicable.

14 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter 11N11 and the registration number is displayed on limited, restricted or light sport category aircraftor experimental or provisionally certificated aircraft, the operator must also displayon that aircraft
near each entranceto the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 111imited/' "restricted/' 111ight sport/111experimental/' or "provisional/' as applicable. Even though the UAS 

### will have no airworthiness certificate, an exemption may be needed as the UASwill have no entrance to the cabin, cockpit or pilot station on which the word

11Experimental 11 can be placed. Given the size ofthe UAS, two inch lettering will be impossible. Theword**~~Experimental"** will be placed on the fuselage in compliance with §45.29 (f). US Department ofTransportation February20, 2015 The equivalent level of safetywill be provided byhaving the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UASwill seethe identification ofthe UAS as "Experimental. 11 14 C.F.R. § 61.113 (a) and (b The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations becausethe applicant's UAS do not carry any pilots or passengers nor property. The risks attendanttothe It is believed thatthe operation and limitations setforth in the FOM will equate to the safe operation ofthe UAS.

14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use of safety checklists priorto each flight, an equivalent level of safetywill be provided. 14C.F.R. § 91.9 (b) (2):Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: 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 ofthis chapter, unlessthere is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or placeto carry such a flight manual on the aircraft, notonly because there is no pilot on board, but becausethere is no room or capacity to carry such an item on the aircraft. The equivalent level of safetywill be maintained by keeping theflight manual atthe ground control point where the pilotflying the UAS will have immediate accessto it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flightto insurethe safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no 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. UAS and remotely piloted aircraft, bytheir design do not have fully functional dual controls. Flight control is accomplished through the use of a control boxthat communicates with the aircraftvia radio communications. The FAA has approved exemptions forflight training without fully functional dual controls for a number of aircraft and forflight instruction in experimental aircraft. The equivalent level of safety is provided bythe fact that neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicoptersto be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UASthat is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not morethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the UASwill never operate at higherthan 400 AGLwith the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated morethan 200feet abovethe highest point on the structure. Itwill however be operated in a restricted areawith security perimeter, where buildings and peoplewill not be exposed to operations withouttheir preobtained consent. The equivalent level of safetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission of the property owner or local officials. Because of the advance noticeto the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far
morethan the maximum SSibs. Proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe UASwill ensure separation between these UAS operations and the operations of conventional aircraftthat must complywith Section 91.119.

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set 11
•••to the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 11 As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level of safetywill be achieved bythe operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning 11aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothe first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes. 11 The applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. Operating the UAS in atightly controlled area where only people and property
owners or official representatives who have signed waivers will be allowed does not engenderthetype of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This restriction would be morethan adequateto return the UAS to its planned landing zone from anywhere in its limited operating area.14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides 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 unlessthe airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legibleto passengers or
crew. The UASfully loaded weighs well underthe proposed 551 b limit and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level of safetywill be achieved by keeping these documents atthe ground control point where the pilotflying the UASwill have immediate accessto them, to the extentthey are applicable tothe UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417{a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner 11Shall havethat aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph {c) ofthis section, have discrepancies repaired as prescribed in part43 of this chapter

...,11 and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applyto the applicant. Maintenancewill be accomplished bythe operator pursuantto the flight manual and operating handbook. An equivalent level of safetywill be achieved becausethe UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. If mechanical issues arisethe UAS can land immediately and will be operating from no higherthan 400 feet AGL. The operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safetywill be achieved because maintenance and inspectionswill be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, and a link on last page, the operatorwill ensurethatthe UAS is in working order priorto initiating flight and perform required maintenance needed.The applicant Robert Louis Jurotich believes this exemption request and associated safetyconsiderations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing sufficientjustification for the granting of commercial operations ofthe applicant•s UAS. Ialso feel its in the public's interest on granting the exemption, as we can educatethem atthe same time. And all the positive sides ofthe newtechnology and the levels of safety.

The applicant Robert Louis Jurotich requests your respective approval ofthis Section 333 exemption petition request.

Thankyou foryourattention in this matter Robert Louis Jurotich of your actions, and or approvals. Thankyou, foryour interest in this request.

Robert Louis Jurotich