November 14, 2015

U.S. Department of Transportation (DOT) 1291 Coventry ct, Maryville TN, 37803 Subject: Petition to the FAA for Section 333 Exemption Drone Video Production Dear Sir or Madam Drone Video Production, hereby submits to the Federal Aviation Administration, pursuant to the FAA Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333 of the Act. Drone Video Production requests to operate commercially its small unmanned aircraft system (UAS) which is c urrently regulated by the Federal Aviation Administration. This letter provides requested information as listed in the FAA's "Public Guidance for Petitions for Exemptions Filed under Section 333" as described as of this date at the FAA website at https://www.faa.gov/uas/legislative programs/section 333/how to file a petition/ Drone Video Production is an experienced aerial photographer in the State of Tennessee . We are experienced in flying hobby helicopters for recreational purposes. We have flown small RC electric helicopters for over three (3) years without incident. Safety is our commitment with each flight. An extensive pre
-flight safety checklist is completed and each flight is logged by the operator and verified by our spotter. Our exemption request would permit operation of ultra
- light weight, unmanned (remote control operated) in tightly controlled and limited airspace. More company information can be viewed on the company website at www.dronevideoproduction.org
. Purpose for the Exemption: Drone Video Production desired to utilize an unmanned aircraft system (UAS), herein described, to accomplish aerial photography of indust rial and commercial facilities as well as realestate. Contact Information: Drone Video Production Maryville, TN 37803 Mobile: 865
- 310
- 7099 E mail: dronevideoproduction@gmail.com List of Specific Sections of 14 CFR for which exemption is sought: This listing matches the list on page 7 of the FAA's "Public Guidance for Petitions Filed under Section333", Rev. 9/25/2014.

14 CFR 21, Subpart H
-Airworthiness Certificates 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 14 CFR 91.7 (a), Airworthiness required for operation 14 CFR 91.103 (b) (2), Preflight action 14 CFR 91.105, Flight cr ewmembers at stations 14 CFR 91.109, Flight instruction 14 CFR 91.119 (c), Minimum safe altitudes 14 CFR 91.121, Altimeter settings 14 CFR 91.151, Fuel requirements for flights in VFR conditions 14 CFR 91.405 (a), Maintenance required 14 CFR 91.407 (a) (1) , Operation after maintenance 14 CFR 91.409 (a) (2), Inspections 14 CFR 91.417 (a) and (b), Maintenance records (FURTHER DETAILS ON PAGES 8
- 11) In accordance with the outline given in the FAA's "Public Guidance for Petitions Filed under Section 333", the following information is provided for each numbered item listed in that guidance: 1. Aircraft Description Design and Operational Characteristics: • Drone Video Production plans to operate a Phantom 3 comprised of an unmanned aircraft and a transportable ground station. This aircraft is a quad
- copter design with gross weight (battery and propellers included) of 1000 g (2.205 lbs.). • The Phantom 3 has an HD camera for capturing aerial still photographs and videos. • It is equi pped with four rotors that are driven by battery
- powered electric motors. Maximum airspeed is 30 knots. • The Phantom 3 includes a Failsafe Function. It activates if the Remote Control is powered off, the Phantom 3 has flown outside effective control range , the signal between the Phantom 3 and the Remote Control is blocked, or if there is interference causing a signal problem. When activated, the Failsafe Function automatically flies the Phantom 3 back to the Home Point (the start location) and lands it. If GPS mode is not active, the Failsafe Function will execute a controlled descend and automatic landing. • Through the Phantom 3 Assistant software, each flight operation will be programmed with a maximum radius distance and maximum altitude from the Home P oint such thatthe flight control system will limit operations to within the confines of the property to

be s urveyed for Drone Video Production or Drone Video Production ' s Clients. These performance limitation requirements are included in the UAS Operating Procedure contained in Appendix A herein. Manufacturer's Documentation: Detailed manufacturer's design information (current to this date) is contained the in the following manuals in the appendices at the end of this document: • Appendix B
- Phantom 3 Spe cifications • Appendix C
- Phantom 3 Quick Start Guide • Appendix D
- Phanto m 3 User Manual • Appendix E
- Phantom 3 Pilot Training Guide 2. Procedures for Ensuring UAS Is In a Condition Safe for Flight Preflight Checks: At a minimum, the following items will be checked prior to initiating any operation. (See Appendix A in this document for detailed procedur es, Drone Video Production , Operating Procedure V1.13.4.15) • Operations must be in daylight hours and under visual meteorological conditions (VMC). • Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for each leg of the flight clearly marked. • Flight path is at least 500ft. from all non
- participating persons, vessels, vehicles and structures unless protective bar riers or structures are present, or permission is granted or such operations present no hazard to the Pilot in Command, the Visual Observer, trainees, and other essential persons. • Flight plan and schedule has been reviewed with site leadership and commun icated to all Drone Video Production and Client personnel in the area. • Remote control, smart battery, range extender, and ground station monitor are fully charged. • Propellers are mounted correctly. • Damping absorbers are in good condition, not dry
- rotted or worn. • Anti
- drop kits have been mounted correctly. • Micro
- SD card has been inserted.• Gimbal is functioning as normal.

• Compass has been calibrated. • Flight radius and altitude limits have been set with the Phantom 3 Assistant software, not to exceed 400ft. AGL altitude, and radius limited to the property boundaries of D rone Video Production or Drone Video Production’s Client site. • The Visual Observer (VO) is stationed at the required initial observation point according to the flight plan and in view of the Pilot in Command (PIC) and has means for continual verbal communication. • There are no inoperable components. • All site required safety permits are approved in in possession of the PIC. • Motors can start and function as normal. • Flight Indicator Lights on the aircraft verify that the Home Point is set to current location. • Record the Preflight Check, date and sign, and file it in the Equipment Inspection and Maintenance R ecord Book. 3. Radio Frequency (RF) Spectrum for Control The Remote Control ground station operating frequency is 5.278
- 5.85 GHz and is FCC compliant with communication distance in an open area of 800 m (875 yds.) Operating Frequency 5.728GHz
- 5.85 GHz C ommunication Distance (open area) FCC Compliance: 800m Receiver Sensitivity (1%PER)
- 93dBm Transmitter Power FCC Compliance: 100mW Working Voltage 120 mA@3.7V Built
- in LiPo Battery Working Current/Capacity 3. 7V, 2000mAh 4. Qualifications for The Pilot in Command (PIC) Logged Hours: The PIC will have accumulated and logged a minimum of 25 hours of total time as a UAS rotorcraft pilot with a multi
- rotor UAS prior to operations. The PIC will have also accumulated and logged a minimum of 5 hours as UAS pilot specifically operating the Phantom 3 , prior to operations. The PIC will have accompli shed, during dedicated training sessions, 3 take
- offs and landings in the preceding 30 days. Training, proficiency, and experience
- building flights in dedicated training sessions will be included in the accumulated and logged hours.Emergency and Evasive M aneuvers:

The PIC will have demonstrated the ability to safely operate the Phantom 3 in a manner consistent with how it will be operated in surveying Drone Video Production’s Client properties, including evasive and emergency maneuvers and maintaining appr opriate distances from people, vessels, vehicles and structures. The logged hours referenced above will document this. 5. Description of Intended UAS Operations • Operations will be restricted to Class G airspace. • No operations will occur within 5 mile s of a non
-towered airport reference point as denoted on a current FAA
- published aeronautical chart, unless a letter agreement with the airport's management is obtained, and the operation is conducted in accordance with a Notice to Airman (NOT AM) as requi red by the Certificate of Waiver or Operation (COA). • The Phantom 3 will be utilized to survey industrial and commercial facilities. The use of small unmanned aircraft systems provides more immediate and thorough information than is presently available by other means. Expense for scaffolding, rental of manned aircraft, rental of equipment, and lost time is saved. Safety is improved by reducing fall risk for workers and reducing potential for manned aircraft accidents. • As described in "2. Procedures for E nsuring UAS Is in a Condition Safe for Flight", altitude and distance limits will be entered into the P hantom 3 Assistant software prior to commencement of flight. This will restrict the operation to Drone Video Production’s Client property. The Failsafe Function integral with the Phantom 3 will assure this aircraft stays within the area deemed safe for operation. • Industrial facilities of the type mentioned above have strict safety procedures which must be satisfied. Drone Video Production ' s respect for compliance with these procedures is vital to assuring positive Client relationships and continuing business. All safety procedures for personnel will be strictly adhered to as well as all laws and regulations. 6. Proposed Speed, Altitude, Visibility and D istances Speed: The Phantom 3 is capable of a maximum speed of 15m/s (29.2 knots). In order to conserve power, and thereby maximize flight time, and to assure good quality still phot ographs and video, the Phantom 3 will be operated at a slow speed along t he flight path, typically 2m/s (3.9 knots) or below. Higher speeds may be used from time to timewhen traversing a section of the property of no interest and not included in a given

study. Altitude: Altitudes below 400ft. AGL are adequate for the complete range of facilities and structures to be surveyed. The integral Flight Control System will be set to limit the altitude to always be below that level. Distance: The integral Flight Control System will be set to limit the radial distance from the Home Point (point off light comme ncement) such that the Phantom 3 will stay within the boundary of the property lines. The PIC will operate the equipment to assure those limits are not reached and will maneuver the Phantom 3 to follow the preplanned flight path with in the property boundaries. The Phantom 3 will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud when visibility is less than 3 statute miles from the PIC. Operations will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies. Safe descent and landing procedures will be followed in accordance with operating documents. 7. Description of the Area of Intended Operations As described in "5. Description of Intende d UAS Operations", t he Phantom 3 operation will be restricted to Drone Video Production’s Client property. Drone Video Production and Client personnel on the site will be made fully aware of the operation prior to commencement of operations. 8. Proximity of Airports Operations will be restricted to Class G airspace. No operations will occur within 5 miles of a non
-towered airport reference point as denoted on a current FAA
- published aeronautical chart, unless a letter agreement with the airport's management is obtaine d, and the operation is conducted in accordance with a Notice to Airman (NOT AM) as required by the Certificate of Waiver or Operation (COA). 9. Operation within Visual Line
- of
- Sight (VLOS) In addition to the PIC, all operations will include a Visual Obs erver (VO). The VO will assure that the Phantom 3 is always within their visual line
- of
- sight (VLOS), as well as the PIC's, at all times.The VO and the PIC will be able to communicate verbally at all times utilizing two
-way radios

available at Drone Video Production’s Client sites. 10. Procedures for Preflight Safety Assessment Prior to each flight, th e PIC will inspect the Phantom 3 , including the ground control station, in accordance with the Preflight Checklist (see "2. Procedures for Ensuring UAS Is In a Condition Safe for Flight"). If the Preflight Check indicates any unsafe conditions or a non
-functioning safety
- critical part, the flight will not commence until the needed maintena nce is performed and a satisfactory Preflight Check can be completed. All maintenance and alterations performed will be documented and filed in the Equipment Inspection and Maintenance Record Book. 11. Notifications As required, a Notice to Airmen (NOT A M) will be requested not more than 72 hours in advance and not less than 48 hours prior to an operation. In addition, any notifications required by the FAA Flight Standards District Office will be made. 12. Certificate of Waiver or Authorization (COA)
Pr ior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate of Waiver or Operation (COA) will be obtained for each aircraft. Services will start with one aircraft, with additional units added as needs for operations in crease over time. Each Phantom 3 aircraft will be identified with its 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 will be as Iarge as practicable. Spe cific Regulations for Which Exemption is Sought: 1. 14 CFR 21, Subpart H
-Airworthiness Certificates 14 CFR 21 covers the certification procedures for products and parts. Subpart H specifies requirements for Airworthiness Certificates for various aircraft types. Small unmanned aircraft systems are not specifically called out and addressed in these rules. Drone Video Production will, in lieu of airworthiness certification by afore mentioned rule, if exemption is granted, ensure that t he Phantom 3 system is in compliance with its operating documents as described herein. The PIC will assure that all Preflight Checks are completed and documented and the Phantom 3 is in full compliance with all manufacturers' operation and maintenancedocuments.

Due to consideration of the size, weight, speed, and limited operating area associated with Drone Video Production’s proposed Phantom 3 , we believe it will not create a hazard to users of the National Airspace System (NAS) or the public. Therefore, a request is m ade for exemption from 14 CFR part 21, and any associated noise certification and testing requirements of part 36. 2. 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 14 CFR 61.113 (a) and (b) prohibit private p ilots from fulfilling the role of PIC if the aircraft is carrying property for compensation, unless the flight is only incidental to that business or employment. Drone Video Production believes that due to the size, weight, speed, and limited operating are a associated with Drone Video Production ' s proposed Phantom 3 operation, a PIC possessing the aforementioned training and logged hours, would ensure safety and prevent creating any hazard to users of the National Airspace System (NAS) or the public. We th erefore request an exemption from these parts of 14 CFR. 3. 14 CFR 91.7 (a), Airworthiness required for operation Lf the exemption from 14 CFR 21, Subpart H (item 1 above) is granted, no airworthiness certificate will be required. On this basis, exemption from 14 CFR 91.7 (a) is requested, presuming that airworthy condition by definition in the rule means having an airworthiness certificate. Drone Video production will, in lieu of airworthiness certification by 14 CFR 21, ensure that the Phantom 3 system i s in compliance with its operating documents as described herein. The PIC will assure that all Preflight Checks are completed and documented and execute full compliance with all manufacturer's operation and maintenance documents. 4. 14 CFR 91.103 (b) (2), Preflight action 14 CFR 91.103 (b) (2) specifies that the PIC be familiar with aircraft performance under expected values of airport elevation and runway slope, aircraft gross we ight, and wind and temperature. Since the Phantom 3 will not be operating out of airports this rule is not applicable. On this basis and on the basis that the operating documents cover requirements for operation safety, an exemption from this rule is requested. 5. 14 CFR 91.105, Flight crewmembers at stat ions This part requires certain actions by on board crewmembers. Since the Phantom 3 is unmanned,an exemption from this rule is requested.

6. 14 CFR 91.109, Flight instruction 14 CFR 91.109 describes requirements for flight instruction and requires that the aircraft used for flight instruction have fully functioning dual controls. The details pertain to manned airplanes and are not applicable to a small unmanned aircr aft system such as the Phantom 3
. Flight training wi ll be required for the Phantom 3 pilo t as detailed on page 5 herein, "4. Qualifications for the Pilot in Command (PIC)." Compliance with these training requirements with logged hours assures that the required competency for safely operati ng the Phantom 3 will be maintained. On this basis an e xemption from this rule is requested. 7. 14 CFR 91.119 (c), Minimum safe altitudes 14 CFR 91.119 (c) requires that no operation is permitted below 500 feet above the surface, except over open water and sparsely populated areas. T he proposed use of the Pha ntom 3 is specifically for altitudes that range from the surface to maximum 400 feet AGL. On the basis of the aforementioned safety procedures, we believe there will be no increased hazard to users of the National Airspace System (NAS) or the public will b e created by the Phantom 3 as detailed here. 8. 14 CFR 91.121, Altimeter settings 14 CFR 91.121 provides specific rules for altimeter settings for cruising altitude and flight level of aircraft and speaks of altimeter stations along the route and the elev ation of the departure airport. In lieu of these specific requirements, most suitable for manned airplanes, the Phantom 3 has barometric altimeter and GPS derived altitude limitations. All altitudes reported to Air Traffic Control (ATC) will be in feet above ground level (AGL). On this basis, an exemption from this rule is requested. 9. 14 CFR 91.151, Fuel requirements for flights in VFR conditions 14 CFR 91.151(a) requires that no person may begin a flight under Visual Flight Rule (VFR) conditions unle ss (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. The Phantom 3 has a built
- in Low Battery Level Warning Function: 9 1) If the smart battery is depleted to the point that may affect the safe return of the aircraft, the low battery level warning notifies the PIC to take action. 2) The thresholds for these warnings are automatically determined based on the currentaircraft altitude and its distance from the Home Point.

3) A color coded battery level indicator shows battery level, and an estimated remaining flight time in minutes is displayed. 4) When the critical battery level warning activates, the aircraft will gradually descend and land automatically. As standard operating procedure, the PIC will immediately return the Phantom 3 to the Home Point for a battery swap when the battery level reaches 25%. On the basis of these specific safety features of battery power level monitoring, and operating procedures, an exemption from this rule is requested. 10. 14 CFR 91.405 (a), Maintenance required Please see exemption request explanatio n in item 15 below (14 CFR 91.417). 11. 14 CFR 91.407 (a) (1), Operation after maintenance Please see exemption request explanation in item 15 below (14 CFR 91.417). 12. 14 CFR 91.409 (a) (2), Inspections Please see exemption request explanation in item 15 below (14 CFR 91.417). 13. 14 CFR 91.417 (a) and (b), Maintenance records Parts 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), and 91.417 (a) and (b), contain requirements for maintenance of larger aircraft. In lieu of adapting these rules fo r the P hantom, Drone Video Production is requesting an exemption on the basis th at it will inspect the Phantom 3 and ensures that it is in a condition for safe flight prior to beginning any operation. We propose that adherence to the operating documents describin g the requirements for maintenance, inspection, and record keeping, are sufficient to ensure that safety is not adversely affected. PUBLIC BENEFIT Granting this Section 333 Exemption would benefit the public in the following ways: • Public Safety: Common p ractice for industrial facility construction projects and periodic site
- wide industrial facility visual assessment involves utilization of manned aircraft. The potential risk to life and property is order of mag nitudes less for use of a small unmanned airc raft system as compared to conventional aerial photography by manned fixed wing aircraft.• Industrial Safety: In order to accomplish inspections of difficult to access areas at high

elevations requires either erection of scaffolding or lifting personnel by crane in protective enclosures to view the subject of interest. Fall protection gear and compliance with OSHA rules governing such work is crucial for life safety. The ultimate protection, however, would be to not involve personnel in such activity and instead complete this work with an unmanned aircraft system. • Energy Savings and Environmental Protection: Reduction of frequency of manned aircraft used to do aerial photography and surveys for construction sites and industrial facilities results in burning less fuel thereby saving energy and reducing emissions of combustion gases. REASONS SAFETY NOT ADVERSELY AFFECTED AND IS AT LEAST EQUIVALENT TO EXISTING RULE The key fe atures of the proposed Phantom 3 unmanned aircraft system that assu re that safety to the public and safety of the National Airspace System (NAS) is not adversely affected are the following: • Credentials and training for the Pilot in Command (PIC), along with detailed operating procedures, assure that the level of compet ency required for successful and safe flight operations is achieved. • The built
- in Flight Control System, which includes a Failsafe Function, assures immediate return to the Home Point and safe landing under failure scenarios, thereby preventing injury o r damage. • Visual Line
- of
- Sight (VLOS) operation provided by the PIC and the Visual Observer (VO), and their ability to communicate verbally at all times, assures full operational control. • Detailed operations and maintenance procedures, including a Pr eflight Checklist, provide assurance of mechanical integrity a nd full functioning of Phantom 3 unmanned aircraft system prior to commencement of any operation. SUMMARY FOR PUBLICATION IN FEDERAL REGISTER Petition for Exemption Docket No.: FAA
- 2015
- xxxx Pe titioner: Drone Video Production Section of 14 CFR 14 CFR 21 Subpart H, 61.113{a) and {b), 91.7 (a), 91.103 (b) {2), 91.105, 91.109,91.119(c), 91.121, 91.151,91.405 (a), 91.407 (a) {1), 91.409 (a) {2), 91.417 (a) and (b).

Description of Relief Sought: The petitioner is seeking an exemption to utilize an unmanned aircraft system (UAS) to accomplish aerial photography, surveys and assessments of realestate, as well as industrial , and commercial facilities. Dakota K. McAfee Owner Drone Video Production