U.S. Department of Transportation Docket Management System

1200 New Jersey Ave. SE W ashington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act), and 14 C.F.R. Part 11, Alpine Pro Media (APM), hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow commercial operation of APM’s sUAS/UAS in the NAS regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333, for the purposes of clos ed - set filming of motion pictures, music videos, web videos, corporate videos, television programs, commercials, still photography, wildlife/agriculture/conservation scientific data accumulation, product demonstrations and research and development. **Reques ted Exemption Summery**  **** The requested exemption would permit Alpine Pro Media to pursue commercial sUAS/UAS operations utilizing 2 advanced sUAS/UAS for the purposes of: 

### 1. Aerial Photography/Cinematography and Videography in closed - set motion picture fi lming. 

### 2. Wi ldlife/Agricultural/Conservation Surveying and Application. 

### 3. Product Demonstrations. 

### 4. Research and Development **Requested Exemption A ircrafts**  **-**1. sUAS - DJI Inspire 1 - Previously granted in Exemption: 12422

2. UAS - VulcanUAV Raven X8 Airframe - Previously granted in Exemption 12008 and 11062 (Xaircraft Super X Flight Controller - Previously granted in Exemption 11887 ) All APM’s sUAS/UAS are under 45lbs, and are incapable of flying over 25 knots, have a built- in GPS capability, hover and self- stabilization, navigation lights and failsafe/return to home (RTH) autopilot systems, which can be triggered manually by PIC(s), and automatically if communication between transmitter and receiver is interrupted. All operations occur with a PIC a nd a VO within VLOS over privately controlled closed - set property, and do so with the property owner/controller or authorized representative prior consent and knowledge, at no more then 400 feet AGL. Persons who have consented or otherwise agreed to be in the area where purposed operations will take place may be captured in photos and/or videos.

Alpine Pro Media Attn: Dan Sovince and Lucas W illiford AlpineProMedia.com 11568 SE Aquila ST Happy Valley, OR 97086 **FA Rs from which the exemption is requested**  **Relief****** 14 C.F.R. § 61.23(a) and (c)14 C.F.R. § 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a) 14 C.F.R. § 61.315(a) 14 C.F.R. § 91.7(a) 14 C.F.R. § 91.119(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a)(1) 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(1) & (2) 14 C.F.R. § 91.417(a) & (b) **AP M seeks relief extent**  from the above (FARs) to operate its sUAS/UAS’s commercially in the NAS for the purposes of closed - set filming of motion pictures, music videos, web videos, corporate videos, television programs, commercials, still photography, wildlife/agriculture/conservation scientific data accumulation, product demonstrations and research and development.

**Betterment of our Community .**  APM believes that the use of sUAS/UAS to perform closed - set filming of motion pictures, music videos, web videos, corporate videos, television programs, commercials, still photography, wildlife/agriculture/conservation scientific data accumulation, product demonstrations and research and development, elevates the level of safety of such practices to the pubic and community in which they are conducted, do the nature of the sUAS/UAS industry and the standards in which they are conducted. The FAA already recog nized, “UAS provides an additional tool for the filmmaking industry, adding a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft.” See Exemption No, 11062**Equivalent Level of Safety .** 

**AP M’s sUA** **S/UA S(s) and operations meet and/or exceed standards listed below:**  • APM will only operate its sUAS/UAS in VLOS of a PIC and a VO and operate at sites that are a “sufficient distance” from populated areas within the sterile private/controlled/clo sed - set property authorized for operations. Such operations will insure that APM will "not create a hazard to users of the NAS or the public." • APM does not operate its sUAS/UAS(s) within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless specific operations deem necessary, a letter of agreement with that airport’s management will be obtained or otherwise permitted by a COA issued to APM.



### • Ma ximum flight time for DJI Inspire 1 wil l be 20 minutes. • Maximum flight time for VulcanUAV Raven X8 will be 60 minutes. • Flights will be terminated at battery voltage of 3.72V per cell, the industry standard for lithium polymer batteries, which leaves 20% reserve, should that occur prior to the the maximum flight time. • All operations will be operated at an altitude of no more than 400 feet AGL. • APM’s PIC's will hold an airline transport, commercial, private, recreational, or sport pilot certificate and also hold a current FAA airman me dical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government.



### • APM’s sUAS/UAS(s) weighs less than 55 pounds, including payload.

### • APM’s sUAS/UAS(s) wi ll operate at speeds of no more than 87 Knots.



### • APM and/or PIC will ensure that the aircraft is in an “airworthy condition” prior to every flight, conducting pre -flight inspections **and** hands on inspections after every landing.



### • APM will terminate operations if **ANY** damage and/or anomalies arise during flight or any part of its operations are compromised in **anyw ay**  including unforeseen weather.



### • APM will not operate DJI Inspire 1 when wind speeds exceed 20mph sustained.



### • APM will not operate VulcanUAV Raven X8 when wind speeds exceed 10mph sustained.



### • APM’s sUAS/UAS(s) and the closed - set sterile environment within which they will operate, adhere to the Reform Act's safety requirements.

**14 CFR 61.23 (a) and (c) Medical Cer tificates**  **** Regulation provides that a person requires a first or second class medical to act as pilot in Command of an aircraft for compensation or hire. Our proposed operations require that the PIC must hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.23 even though the intent of this application is to conduct a business. **14 CFR 61.101(e)(4) and (5), 14 CFR 61.113 (a), and 14 CFR 61.315(a) Pilot privileges and Limitations**  **** Regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private Pilot certific ate may act as PIC of an aircraft for compensation or hire. Our proposed operationsrequire that the PIC must hold at least airline transport, commercial, private, recreational, or

sport pilot certificate. Since the aircraft cannot carry passengers or prop erty, we feel we meet the intent of 61.113 Subparagraph (b).

**14 CFR 91.7(a) Civil A ircraft A**  **irw orthiness**  **** Regulation prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contem plated by the FARs, this Regulation is inapplicable.

**14 CFR 91.119(c) Minimum safe altitudes**   Regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since o perations of APM’s sUAS/UAS(s) would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over closed - set property or persons where per mission has been obtained and careful pre planned/scripted flights are performed. The aircraft will be operated at low altitudes allowing, if a failure occurs, an emergency landing without undue hazard to persons or property on the surface. Therefore we ma intain that due to the size(s) of APM’s sUAS/UAS(s), the hazard to persons, vehicles and structures/property is minimal compared to manned aircraft. ** 14 CFR 91.121 A** **ltimeter settings**   Regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. APM’s sUAS/UAS(s) will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An AGL altimeter measurement is transmitted via built in telemetry from the sUAS/UAS(s) (FC) Flight Controller through the sUAS/UAS(s) receiver and or ground station to the PIC’s on - screen display (OSD), providing a constantly updated AGL readout. ** 14 CFR 91.151(a)(1) Fuel requirements for flight in VFR conditions** **-**Regulation provides that no person may begin a flight in an airplane under day- VFR conditions

unless there is enough fuel to fly to the first point of i ntended landing and to fly after that for at least 30 minutes. APM feels the intention of this paragraph is to provide an energy reserve as a safety buffer for flight delays. APM follow all industry standards attaining to lithium polymer battery charging/d ischarging and practices, and since operations will never be out of VLOS, commencing all flights at full charge will ensure that we meet the reserve energy requirement of this paragraph by terminating flights at or before 3.72v per cell.

**14 CFR Subpart E (91.401**  **- 91.417)**  **- Maintenance, Preventive Maintenance, A** **lterations**   Regulation provides that the operator is primarily responsible for maintaining the aircraft in an “airworthy condition”, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" af ter maintenance and inspection. It is APM’s intention that APM and/or PIC’s perform strict maintenance and inspection’s that follow manufactures recom mendations of the applied sUAS/UAS(s) parts and components and "be authorized to approve the aircraft for return to service." APM and/or PIC’s will ensure that the aircraft is in an airworthy condition prior to every flight ** and** conducts hands on inspection s after every landing to ensure an elevated level of safety of its operations. APM and/or PIC’s will document all maintenance, preventive maintenance and alterations performed in accordance with 91.417. APM feels that due to the size(s), construction, and simplicity of the aircraft, an equivalent level of safety is achieved.

**Summery** **** Alpine Pro Media herein respectfully requests exemption from 14 C.F.R. § 61.23(a) and (c) 14 C.F.R. § 61.101(e)(4) and (5) 14 C.F.R. § 61.113(a)14 C.F.R. § 61.315(a)

14 C.F.R. § 91.7(a) 14 C.F.R. § 91.119(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a)(1) 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(1) & (2) 14 C.F.R. § 91.417(a) & (b) Pertaining to the safe, commercial use of its sUAS/UAS in the NAS under closed - set controlled operations. APM would like to add that it would be very easy to ignore the FAA and operate sUAS/UAS(s) commercially. W e know of and have seen entities who are al ready doing so. Wehope the simple fact that APM, who operate a very small media company, expresses our willingness to comply, and concern about sUAS/UAS operational safety, NAS and the community, by requesting this exemption. Alpine Pro Media does not wi sh to exercise the above requested exemption outside the Continental United States. Thank you for your time.

Sincerely Alpine Pro Media Attn: Dan Sovince & Lucas W illiford AlpineProMedia.com