## FRONT SIDE FILMS 3919 Brace Ranch Road Loomis, California 95650

February 12, 2016

Docket Operations, M-30 U.S. Department of Transportation 1200 New Jersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001

Re: Petition for Exemption under FAA Modernization and Reform Act of 2012 (P.L. 112-95), Section 333

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(FMRA) and 14 CFR Part 11, Front Side Films hereby applies for an exemption from Federal Aviation Regulations (FARs) listed below under “Basis for Petition” and discussed in Appendix A. Exemption is being sought in order to allow Front Side Films to operate its unmanned aircraft systems (UAS) commercially for the purpose of aerial videography and photography, precision agriculture and environmental management, scientific analysis and research, surveying, aerial inspection of land and structures, search and rescue and emergency services, journalism and news gathering, real estate marketing, and television and film making and production.

INTRODUCTION OF THE PETITIONER

Front Side Films will provide services to its clients to enhance a variety of their business and personal objectives by providing digital photography, videography, data acquisition, cinematic consulting and other types of digital imaging and related services. The principal members of the organization possess over 8 years of experience in aviation, in both unmanned fixed-wing r/c androtorcraft UAS piloting as hobbyists, amassing more than 500 hours of flight time as pilot-incommand of numerous airframes for personal uses. The principal owner of Front Side Films, Mr. Damon Chamberlain, is a long-time member of the Academy of Model Aeronautics and is particularly active in the Sacramento, California AMA chapter. Mr. Chamberlain and his team are experienced photography, film and video professionals with experience in photographic and video technology, equipment, methodologies and business operations. In addition to and varied aviation experiences with UAS, the members of Front Side Films are skilled in the areas of ground-based photography, videography, photo and video editing, and consulting services. Theobjective of Front Side Films is to provide professional quality digital imaging, aerial data

acquisition, editing and analysis for a variety of commercial, public, private and not-for-profit organizations and individuals, including, but not limited to:

- Motion picture and television filming and production

- Photography and videography for journalism and news gathering purposes

- General aerial photography, including inspection of structures and construction sites

- Aerial image and data acquisition for search and rescue and other emergency situations

- Real estate marketing photography and videography

- Digital imagery and data acquisition for precision agriculture, environmental management, surveying, and scientific analysis and research

- Aerial photography and videography of landscapes and outdoor adventures

UNMANNED AERIAL SYSTEMS

DJI Phantom 3 Professional, DJI Inspire 1 and Freefly Systems ALTA

Front Side Films seeks an exemption to operate DJI Phantom 3 Professional, DJI Inspire 1 and Freefly Systems ALTA unmanned aerial systems (UAS) for compensation or hire within the National Air Space (NAS). The DJI Phantom 3 Professional, DJI Inspire 1 and Freefly ALTA are vertical takeoff and landing (VTOL) unmanned aircraft. The DJI Phantom 3 Professional is a four-rotor quadcopter that has a maximum gross weight of approximately 3 pounds 3 ounces, including DJI X3 gimbal camera systems, and a maximum speed according to the manufacturer of approximately 33.5 miles per hour. The DJI Inspire 1 is a four-rotor quadcopter that has a maximum gross weight of 6 pounds 7.5 ounces, including onboard gimbal and camera systems and batteries, and a maximum speed of approximately 48.5 miles per hour. The Freefly Systems ALTA is a six-rotor hexacopter that has a maximum allowable weight according to the manufacturer of 30.0 pounds including batteries ,gimbal and a variety of high definition digitalcamera systems, and a maximum speed of approximately 40 miles per hour. Each of the abovedescribed UAS are equipped with rotors and propellers driven by lithium polymer battery powered electric motors .Each are also equipped with the industry standards in GPS, electronics, guidance, propulsion, telemetry, safety features and ease of operator functionality. Detailed information regarding each UAS is attached to this petition as Appendices B, C and D.

It should be noted that these particular UAS have each been approved in connection with prior Section 333 grants of exemption. Specifically, the DJI Phantom 3 Professional was the UAS identified by the petitioner in Exemption 11906 (and others); the DJI Inspire 1in Exemption 11280 (and others); the Freefly Systems ALTA in Exemption 12634 (and others). Each UAS is recognized in the UAS industry as a leading example of precision, quality, performance and durability and technological innovation. The UAS will offer Front Side Films a range of options for matching the desired flight characteristics and technology with the desired tasks, environmental conditions, and navigational demands, thus assuring overall safety and completion of assigned work product and desired results.

BASIS FOR PETITIONFront Side Films, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R.

Section 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional ,DJI Inspire 1, and Freefly Systems ALTA UASs in the national airspace system (NAS), and for an exemption from the requirements of 14 C.F.R. Sections 61.113(a) & (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b).

The granting of exemption from the above-listed FARs will allow Front Side Films to conduct commercial operations of its UAS to efficiently and safely deliver high-definition digital imagery and other acquired data to its clients and customers more cost-effectively than traditional methods. Employing UAS technology can also be safer for workers because in many instances the workers may avoid dangerous or precarious hazards or physical positions involving high risk of injury. Unmanned aerial systems also enable safe inspection of difficult to reach or environmentally sensitive locations without the use of heavy trucks, cranes, booms or other equipment requiring greater expense or attendant undesirable environmental impacts. In general, UAS operated by Front Side Films will economically benefit their customers by acquiring important and aesthetic digital imagery and data safely and less expensively for a wide variety of applications.

Front Side Films proposes to use UAS that are multi-rotor craft weighing a maximum of 30.0 pounds fully loaded, or less, which fly at a speed of 48.5 miles per hour, or less. The craft are all equipped with built-in safety features including sophisticated navigation controls and fail-safe technology to assure safe and predictable aerial maneuvers, take-off and landing. Proposed operations will be conducted under controlled conditions in airspace that is limited, predetermined, access controlled and under constant monitoring before and during flight. Operations contemplated under the exemption will be subject to strict operating parameters to ensure at least an equivalent level of safety to currently authorized and/or exempted operations.

NAME AND ADDRESS OF THE PETITIONER

The name and address of the Petitioner and point of contact is:

Front Side Films Attn: Damon Chamberlain 3919 Brace Ranch Road Loomis, CA 95650 (916) 712-4465 Email: damonchamberlain@hotmail.com

OPERATING DOCUMENTS

The comprehensive operations manuals/user guides/safety guides and other detailed information provided by the UAS manufacturers are attached to this petition as Appendix “B” (DJI Phantom 3 Professional), Appendix “C” (DJI Inspire 1) and Appendix “D” (Freefly Systems ALTA). Theappendices are comprehensive and current for each UAS, and offer a complete description of

each aircraft, including operating features and protocols, specifications, maintenance recommendations and guidance, safety and navigation information, battery maintenance and safety, aircraft controls and gimbals, and more.

Attached as Appendix “E” is Front Side Films Pre-flight Checklist and In-flight safety checklist; Appendix “F” contains Front Side Films UAS Flight Log Form and Front Side Films Monthly Maintenance and Inspection Log Form.

THE PILOT IN COMMAND (PIC)

The PIC will:

- Hold a current FAA sport pilot certificate or higher FAA pilot certification

- Hold a valid third-class medical certificate

- Have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with similar UAS type

- Have accumulated and logged a minimum of five hours as a UAS pilot with the make and model of UAS to be utilized for operations under the exemption and three take-offs and landings in the preceding 90 days prior to an operation

- As noted below in “Operating Parameters, Limitations, Conditions and Requirements”, the operator will not allow a PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Visual observers must have demonstrated that they understand the conditions and limitations of flight noted in the same section which follows immediately below.

OPERATING PARAMETERS, LIMITATIONS, CONDITIONS AND REQUIREMENTS

Grant of the exemptions will be subject to the following conditions, which provide at least an equivalent or higher level of safety than under the current conditions. These conditions are derived from Exemptions 11062 through 11067, 11080, 11109 and 11110, and others.

For the following listing, the Petitioner, Front Side Films is referred to as the operator.

1. Operations authorized by the grant will be limited to the UAS described above and manufacturers’ upgraded versions.2. The UAS weigh 30.0 pounds or less, including batteries, gimbals, camera systems and

other necessary attachments.

3. The UA will be flown at a maximum ground speed of 40 miles per hour. In no case will a UA be operated at airspeeds greater than the maximum UA airspeed recommended by the aircraft manufacturer.

4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued medical certificate or U.S. driver’s license.

6. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to communicate verbally at all times. Electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions duties required of the VO.

7. The operating documents and the grant of exemption will be accessible during UAS operations and made available to the Administrator upon request. The operator may update or revise its operating documents. It will be the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. If there is a discrepancy between the exemption conditions and limitations and the procedures outlined in the operating documents, the conditions and limitations in the grant of exemption take precedence and will be followed. Otherwise, the operator will follow the procedures outlined in its operating documents. If the operator determines that any update or revision would affect the basis upon which the FAA may grant this exemption, the operator will petition the FAA for amendment to the exemption.

8. Any UAS that has undergone maintenance or alterations that affect the UAS flight characteristics or operation, e.g. replacement of an essential flight component, will undergo a functional test flight prior to conducting further operations. Functional test flights will be conducted by a PIC with a VO and will remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as not to pose an undue hazard to persons and property.

9. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight the PIC will conduct a pre-flight inspection and determiner that the UAS is in a condition for safe flight. The pre-flight inspection will account for allpotential discrepancies, e.g. inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator will follow the UAS manufacturers’ maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under the exemption will comply with all manufacturer safety bulletins.

13. The PIC will possess at least a private pilot certificate and a current third-class FAA airman medical certificate. The PIC will also meet the flight review requirements specified in 14 CFR 61.56.

14. The operator may not permit any PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distance from people, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR Section 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PICs ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption will be permitted under the terms of this exemption. However, training operations will only be conducted during dedicated training sessions. During training, proficiency and experience-building flights, all persons not essential for flight operations are to be considered non-participants, and the PIC will operate the UA with appropriate distance from non-participants in accordance with 14CFR Section 91.119

15. UAS operations will not be conducted during night, as defined in 14 CFR Section 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be conducted.

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or, for airports not denoted with an ARP, the center of the airport symbol as denoted on the current aeronautical chart published by the FAA, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon request.

17. The UA will 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 PIC.

18. If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location or recovery point within the private or controlled-access property.19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and still maintain a reserve battery power of no less than 25%.

21. The operator will apply for and obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption.

22. All aircraft operated in accordance with the exemption will be identified by serial numberor equivalent, registered in accordance with 14 CFR part47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR Sections 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS at any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

24. The UA will remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS will not be operated by the PIC from any moving device or vehicle.

26. All flight operations will be conducted at least 500 feet from all non-participating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect non-participating personsfrom the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of non-participating persons; and, b. The owner/controller of any vessels, vehicles, or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.The PIC, VO, operator trainees or essential persons will not be considered nonparticipating persons under the exemption.

27. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Such permission will be obtained for each flight.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported tothe FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported

to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

THE PUBLIC INTEREST

The public interest in granting this exemption request is served by, among others, the following:

- The use of UAS improves public safety and reduces risk by alleviating the public‘s exposure to danger and emissions associated with conventional aerial methods (full size aircraft) that are very heavy, fast and carry passengers, flammable fuel and cargo.

- A myriad of ecological and environmental benefits and improved economic efficiency and scientific information and data acquisition are potential public benefits accomplished through the use of UAS for precision inspections of infrastructure and industrial plant and equipment such as energy pipelines, power lines, smokestacks, towers, and other man-made structures, which can be observed and later analyzed safely, accurately and unobtrusively.

- Commerce can be improved through data and image acquisition for real estate, construction, precision agriculture, surveying and other applications of UAS technology.

- The visual arts such as film, photography and television are improved through exciting and beautiful images captured via the versatile aerial platform UAS provides, which benefits the collective cultural and aesthetic demands and desires of an appreciative public.

- UAS may be an exceptional tool for journalists and all manner of news gathering and reporting media, to serve the public good in enhancing accurate dissemination of newsworthy and relevant information to interested citizens.

- Approval of this exemption will provide immediate employment opportunities for individuals and businesses whose livelihood may be directly or indirectly improved through career opportunities and job creation in a growing technology sector of the economy.

- Congress has established a national policy that favors prompt integration of UAS into the NAS, provided that judicious and reasoned agencies and officials guide the process prudently and with due emphasis on public safety and efficiency. The granting of this Petition for exemption will serve this public policy mandate and result in the attendant benefits perceived by this policy.

SUMMARY FOR PUBLICATION

For publication in the Federal Register, Front Side Films provides this summary:

An exemption is requested from the following regulations in order to allow commercial operation of its Unmanned Aircraft Systems involving aerial applications such as general aerial photography and videography, motion picture and television photography ,aerial photography of landscapes and outdoor adventures, aerial imagery for inspection of structures, construction projects and real estate, videography and photography for journalism and news gathering purposes, digital imagery and data acquisition for search and rescue operations, precision agriculture, environmental management, and scientific analysis and research.14 CFR Section 61.113 (a) and (b)

14 CFR Section 91.7(a) 14 CFR Section 91.119(c)
14 CFR Section 91.121 14 CFR Section 91.151(a)(1) 14 CFR Section 91.405(a) 14 CFR Section 91.407(a)(1) 14 CFR Section 91.409(a)(1) and (a)(2) 14 CFR Section 91.417(a) and (b)

CONCLUSION

Front Side Films seeks an exemption, pursuant to 14 CFR Section 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit Front Side Films to safely operate UAS commercially for the purposes and operations described herein. In granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate and policy of FMRA, while also providing a significant number of benefits to the public, the environment and the economy. The exemption will enable Front Side Films to utilize its aviation experience, technological expertise, advanced aircraft, and entrepreneurial vision to enhance the safety, beauty and economic progress of the public and private sectors and advancing the interests of society at large.

Front Side Films respectfully requests that the Administrator grant this Petition for an exemption from the requirements discussed herein, and permit Front Side Films to operate commercially the unmanned aircraft systems in the aerial operations set forth herein.

Thank you for your consideration.

Sincerely,

Damon Chamberlain Front Side Films



### APPENDIX A14 CFR Section 61.113(a) and (b); Private Pilot Privileges and Limitations: Pilot in

Command; Commercial Pilot Privileges and Limitations

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the UAS proposed for use by Front Side Films are remotely controlled with no passengers or cargo on board.

Front Side Films respectfully requests exemption from these requirements based on the particular characteristics of the UAS that will be used. The risks associated with the operation of the UAS described above (given the size, weight, airspeed, operational characteristics and lack of combustible fuel) are much lower than the risks associated with commercial operations contemplated by Part 61 with conventional manned aircraft. Accordingly, a private pilot, adequately trained in the proper use of UAS, possesses the requisite skills and knowledge of the NAS and FAA regulations to assure the safe operation of the UAS. In addition, Front Side Films will operate the identified UAS with a high degree of control and a number of built-in technical capabilities that serve to strictly limit the potential for operation outside of the operating conditions and restrictions set forth in this Petition.

Front Side Films emphasizes and requires UAS training and flight experience for those PICs who will operate these aircraft in the proposed commercial applications. By requiring extensive flight experience with these aircraft (multirotor UAS) in general, and with each specific make and model of the UAS to be utilized for operations under the proposed exemption, the Front Side Films PICs will possess greater knowledge of and experience with the UAS than they would by holding a commercial pilot license for an entirely different type of airborne system.

Given the inherently lower-risk nature of the UAS and these training and experience requirements and UAS safety features and operational safeguards, Front Side Films proposes and requests that PICs should not be required to hold a commercial pilot certification. Instead, PICs should be required to hold a current private pilot certification and have the experience with UAS as indicated in this Petition.

The risks associated with the operation of the UAS identified herein (considering their size, weight, airspeed, operational characteristics, and absence of combustible fuel) are so diminished from the level of risk associated with commercial operations contemplated by Part 61 with conventional aircraft (rotorcraft or fixed wing) that allowing operations of the UAS as set forth above meets or exceeds the present level of safety provided under 14 CFR Section 61.113(a) and (b) and does not rise to the level of requiring a commercial pilot to operate under 61.113(a).

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the UAS identified herein with a private pilot’s certificate, under the conditions set forth in this Petition. The FAA has granted exemption to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109 and 11110.14 CFR Section 91.7(a): Civil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the named aircraft without an airworthiness certificate, no standard will exist for the airworthiness of the aircraft. Given the size of the aircraft and the requirements that the operator has agreed to as relates to airworthiness, as set forth herein and in the various operating documents, an equivalent level of safety will be achieved by ensuring compliance with the aircraft manuals and operating documents for each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109 and 11110.

14 CFR Section 91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civilian aircraft. Section 91.119(c) prohibits operations below 500 feet above the surface, or closer than 500 feet to any person, vessel, vehicle or structure. As this exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. The equivalent level of safety will be achieved given the size, weight and airspeed of the UAS as well as the location where it will be operated. No flight will be taken without the permission of the property owner or local officials, where required. Because of the advance notice to the property owner and participants, all affected individuals will be aware of the planned flight operations as set forth in the plan of operations. Front Side Films therefore requests a waiver from Section 91.119(c) for all participating persons, i.e. persons associated with the operations.

Front Side Films will also ensure that non-participating persons are kept at least 500 feet from the operating area, or seek approval from the Administrator for less separation if an equivalent level of safety can be achieved. Compared to flight operations with conventional aircraft or rotorcraft weighing far more than the maximum 30.0 pounds proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those risks associated with the conventional craft. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of any conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11153, and 11159.

14 CFR Section 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out or display, an exemption may be needed. An equivalent level of safety will be achieved by the operator confirming the acquisition of GPS signals and an initial ground level altitude of zero prior to take-off. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067 and 11080.

14 CFR Section 91.151(a): Fuel Requirements for Flight in VFR ConditionsSection 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (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 battery(ies) powering the named UAS rotorcrafts provide approximately 20-25 minutes or less of powered flight, depending upon overall flight conditions. To meet the 30 minute reserve requirement in 14 CFR Section 91.151, UAS flight would not be practicable or effective. Front Side Films believes that an exemption from 14 CFR 91.151(a) is safe and falls within the scope of prior exemptions.

Operating the UAS in a controlled area with a limitation on the flight upon reaching 25% of battery power does not engender the type and magnitude of risks that 91.151(a) was intended to alleviate given the size and airspeed of the UAS. Front Side Films believes that an equivalent level of safety can be achieved in this manner. This restriction would be more than adequate to return the UAS safely to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted by the FAA to other Petitioners, including exemptions 11062 and 11159.

14 CFR Sects. 91.405(a); 407(a)(1); 409(a)(1)and(2); 417(a)and(b):Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in Subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Front Side Films. Maintenance will be accomplished by Front Side Films pursuant to Front Side Films’ operations manuals and practices along with manufacturer specifications. An equivalent level of safety will be achieved because these small UAS are very limited in size ( no more than 30.0 pounds), will carry a small payload and operate only in restricted areas for limited periods of time with no flammable fuel. If mechanical issues arise the UAS can land almost immediately, and furthermore will be operating from no higher than 400 feet AGL.

As provided herein Front Side Films will ensure that the UAS is in proper working order prior to initiating flight, perform a preflight operational and safety checklist, perform required maintenance, and keep a log of any maintenance performed. Furthermore, Front Side Films is most familiar with the UAS and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted these exemptions to conduct similar operations in Exemptions 11228, 11241 and 11251.