Household Media Group, LLC Derek Darmstaedter

3225 Hidden Creek Dr. Antioch, TN 37013 (615) 669-7551 derek.darmstaedter@gmail.comDate: October 26, 2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave.,

SE Washington, DC 20590 RE: Petition of Perch Photography, LLC for Exemption Pursuant to Section 333 ofthe FAA Reform Act Dear Siror Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14C.F.R. Part 11, Household Media Group, LLC, operator of Small Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography and videography,

hereby applies foran exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted within and under the conditions outlined herein oras may be established bythe FAA as required by Section 333.1 As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace thatis(1) limited (2) predetermined and (3) controlled. The proposed exemption, if granted, would allow Household Media Group, LLC to conduct commercial operations of small unmanned aircraft systems ("UAS") meeting or exceeding allofthe operational and safety requirements Congress has set forth in Section 333. Page 2 Household Media Group, LLC isa media/technology company owned and runby Derek Darmstaedter. Mr. Darmstaedter has been active in Radio Controlled Aircraft for the past 3 years with experience rotary wing aircraft. Household Media Group, LLC plans to exploit the capabilities of Unmanned Aerial Systems to offera multitude of services, including: - Aerial surveying - Event PhotographyNideography - Agriculture purposes -Real Estate Photography - Aerial filmmaking and photography - Construction site inspections and monitoring Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations inthe NAS. Section 333(a) states that the FAA "shall determine ifcertain unmanned aircraft systems may operate safely inthe national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(l) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations. The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested: 14 C.F .R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b)14 C.F.R. 91.7 (a)14 C.P.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a)&(b)14 C.F.R. 91.205 (b)14 C.F.R. 91.215 14 C.F.R. (91.401 - 91.417) Unmanned Aircraft System sUASs are oftentimes seen as superior to helicopters dueto the smaller devices cheaper equipment and personnel cost, reduced noise andas such, a much smaller environmental impact which promotes public safety. We are petitioning for exemption to enable Household Media Group, LLC to operate a Dll Inspire 1 upgraded tothe latest firmware and equipped witha three-axis camera gimbal and using a4K camera. This sUAS hasa built-in capability to limit the height it flies above the ground, to limit the radius ofthe distance itflies from the operator. The Inspire 1also has the failsafe function ofthe autopilot system which means when the communication between the Main Controller and the transmitter is disconnected, the outputs ofall command sticks from controller will gotothe center position. Ifthe GPS

signal is good enough, the system will automatically trigger Return to Home and will

land safely.Please refer tothe link totheDn Inspire 1 Instruction Manual for the performance limitations and flight operations.http://download.djiinnovations.com/downloads/inspire_l /en/Inspire_ I_ User_Manual_ v l.2_en .pdf Aircraft weight is104oz. with battery, 3 Axis Camera Gimbal and Camera A Pre- flight inspection will be performed bythe PIC in accordance with the factory instruction manual. An added step will bethe inspection ofthe propellers. A propeller will be replaced ifithas any nicks and cracks witha manufacturers authorized propeller. The sUAS will be maintained in accordance with the manufacturers instruction manual and only manufacturer's authorized replacement parts will be used.FCC Information This DJI Cl transmitter used for controlling the sUAS complies with part 15ofthe FCC rules. Operation is subject tothe following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The DJI Cl radio transmitter used for controlling the sUAS is wireless technology which has been tested and found tobe compliant with the applicable regulations governing a radio transmitter inthe 2.400GHz to 2.4835GHz frequency range. Antenna Separation Distance when operating our DJI Cl transmitter, the PIC will maintain a separation distance ofat least5em between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.Pilot in Command and Observer Qualifications and Duties The PIC will maintain at least2 hours flying time and3 takeoffs and landings within 30 days inthe type ofUAS utilized in operations. The PIC will have at least 50 hours total time andat least 30 hours flying Radio Controlled Model Aircraft ofwhich will be10 hours flying sUAS's. Training will be conducted atalocal Radio Control Club flying field. Perch Photography has the ability to provide "dual controls" utilizing two DJI Cl transmitters witha wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated asa slave. The PIC instructor, utilizing the master transmitter, will beatall times be able assume control ofthe sUAS. The PICis responsible forthe safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, all procedures including but not limited to: Safe in flight operations Risk Mitigation to Persons and property Airfield Suitability The Observer must have the visual acuity to observe the sUAV andbe able to communicate clearly with the PIC. The Observers duties are; warning the PIC ofany impending obstacles inthe flight path ofthe sUAS. warning the PIC ofany deviations inthe planned flight path ofthe sUAS. warning the PIC should any unauthorized personnel appear inthe area ofthe planned flight. The Observer will have the authority to order the PICto terminate the flight should he feel the flight cannot be conducted safely.General Operating Standards • Household Media Group, LLC will only operate its sUAS inline of sight ofapilot and/or observer and will operate at sites that area 'sufficient distance' from populated areas. Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." • Before an operation ofasUAV within 5NM ofan airport witha control tower, the control tower will be called to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. The sUAS will notbe operated atan altitude of over 150 feet AGL. Weather minimums will be3 miles visibility anda 1000 foot ceiling.

Before an operation ofa sUAS within 5NM ofa non-tower controlled, airport operators will be notified and the PIC will give the right of way to avoid flying inthe proximity of full-scale aircraft. Atno time will the sUAVbe operated within the final approach course and the takeoff course ofany runway. The sUAVwill notbe operated atan altitude of over 150 feet AGL. Weather minimums will be3 miles visibility anda 1000 foot ceiling. • Maximum flight time for each operational flight will bea maximum of25 minutes. • Flights will be terminated at 25% battery power reserve should that occur prior tothe25 minute limit. •The sUAVwill be programmed so thatitwill notbe operated atan altitude ofno more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist ofthe sUAS Pilot, and Visual Observer. •The sUAV operated bythe petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals). •The sUAVwill operate at speeds ofno more than 60 knots, can hover, and can simultaneously move vertically and horizontally. • Given the small size ofthe sUAV and the restricted sterile environment within which they will operate, our sUAV operations adhere tothe Reform Act's safety requirements. The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on

board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 25 minutes, thisis offers little orno riskto national security. Low level oblique photos and video from several angles arefar more effective than ground based imagery for displaying the characteristics of large, complex properties withseveral buildings and large trees. The applicants inthe past have chartered 2-seat fullsized helicopters for this purpose, which has proven more costly than many potential clients have been ableto afford. The benefits of reduced cost and improved quality of presentation from theUAwill be valuable toand benefit many buyers and sellers ofreal property. Additionally, we request that webe allowed touse our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, etal.,

while remaining subject toall limitations cited inthis application aswedoso. (a)No flight will be made witha Gross weight exceeding 15 pounds; (b)All operations must occur in FAA Class G airspace atno more than 400ft AGL, atan airspeed ofno more than 60 knots and no further than1NM from the PIC; (c)All operations must utilize a visual observer (VO). The VO and PIC must be ableto communicate by voice atall times during a flight operation; (d) Operations will be restricted to flights over private property with the permission ofthe property owner; (e)All required permits will be obtained from state and local government prior to operation;(f) Household Media Group, LLC will notbe operated over densely populated areas; (g) Household Media Group, LLC will notbe operating over any open-air assembly of people;(h) Household Media Group, LLC will notbe operating over heavily trafficked roads; EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Household Media Group, LLC requests an exemption from the following regulations as well asany additional regulations that may technically apply to the operation ofthe sUAV System:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. While

the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued fortheDn Inspire 1 under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes:(a) Research and development Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and

reliability requirements ofthe regulations. Since the experimental certificate canbe used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the

UA will beat least as safe, ifnot safer, thana conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate isnot appropriate for this application, then we request an exemption of14 CFR Part 21, Subpart H, and the requirement foran airworthiness certificate in general, citing the equivalent level of safety outlined inthe previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least2 inches high near the entrance tothe cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" canbe placed, and may not havea registration number assigned to itbythe FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" inthe placard onthe topofthe aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others inthe vicinity ofthe aircraft while itis preparing for launch will be abletosee the designation. Additionally, we feel

that the permanent placard discussed inthe previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display atthe ground station ahigh contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin. 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may actas pilot in Command ofan aircraft for compensation or hire. Subparagraph (b) allows a private pilot toactas pilot in command ofan aircraft in connection with any business or employment if:(1) The flight is only incidental tothat business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposedoperations require that the PIC must hold at leasta Private Pilot Certificate witha Class III Medical issued bythe FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent ofthis application isto conduct a business. 14 CFR 91.7 Prohibits the Operation ofan aircraft without an airworthiness certificate. Asno such certificate will be applicable inthe form contemplated bythe FARs, this Regulation is inapplicable. 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual isinthe aircraft. We assume that the intent ofthis requirement isto ensure

that flight manual information is available tothe aircrew while operating the aircraft. We request an exemption tothis requirement since the aircraft isnot only too small to carry documentation, the documentation would notbe available tothe crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose thata current, approved sUAS Flight Manual must be available tothe crew atthe ground station anytime the aircraft isin,or preparing for, flight. 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate acivil aircraft thatis being used for flight instruction unless that aircraft has fully functioning dual controls." Training will be conducted ata local Radio Control Club flying field. Perch Photography has the ability to provide "dual controls" utilizing two DJI Cl transmitters witha wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated asa slave. The PIC instructor, utilizing the master transmitter, will beatall times be able assume control ofthe sUAV. 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feettoany person, vessel, vehicle, or structure. Since the typical

mission ofthe sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feettothe items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-planned flight path has been performed. The aircraft will be operated atalow altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons or property onthe surface. Therefore we maintain that duetothe small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference toan altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the**----~"** takeoff point is transmitted via radio from the sUAS on-board computer tothe display screen held bythe PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight inan airplane under day-vFR conditions unless there is enough fueltoflytothe first point of intended landing andto fly after that forat least 20 minutes. We feel the intention ofthis paragraph isto provide an energy reserve asa safety buffer for delays to landing. The sUAV is battery operated and the maximum duration of flight froma single battery charge is15 minutes witha 20% reserve. Since the aircraft will never fly more than1NM from the point of intended landing, afull battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption tothe word "fuel" and ask foran

equivalent interpretation with the word "energy". 14 CFR 91.203(a) &(b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned tothe aircraft anda registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance sothatitis legible to passengers or crew." Ata maximum gross weight of5.3 pounds, the sUAS istoo small to carry documentation, does not have an entrance, andisnot capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft bythe FAA will be with the crew atthe ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed tothe aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of14 CFR 45.23. 14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, AlterationsThe regulation provides thatthe operator is primarily responsible for maintaining the -,_aircraft inan airworthy con-'fil:ion, including compliance with part 39and 43. Paragraphs 91.4<;..;-e J**~re** that the aircraft be "approved for return to service bya person authorized under 43.7" after maintenance and inspection. Itisour intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft isinan airworthy condition prior to every flight andin addition conduct detailed inspections after every two hours of flight. Maintenance performed bythe PICis limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that duetothe size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.**--~--** Safety and Benefits ofthe UAS Household Media Group, LLC will be using the UAS ina variety of applications that

generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits over the useof full-sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography,just to name afew. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. By granting Household Media Groups requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Household Media Group, LLC is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data

from its commercial UAS operations and serving asa resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition. ConclusionAs pointed outinthis application, allthe SUAs which our company would use, under authorization bythe US DOT-FAA, are small, light-weight devices operated within the line of sight ofthe Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless theair traffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.

All our SUAs have proven capability for controlled flight They are devices offered for general sale onthe market around the world and have often been used as Model Aircraft inthe USA. We are certain that the studies conducted until now bythe FAA, about Section 332, Public Law 112-95,2014, have already provided you with the assurances on the airworthiness ofSUAs such as ours._..**----~** For the foregoing reasons, the**ex~tfOns** requested herein should be granted and**~ousehold McdiaQro.up~L__CB&culd**  be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. The submission ofthis application andits contents isthe best demonstration that indeed itis possible to pursue the authorization process sothat some SUAs may be used for legitimate commercial activities and under reasonably safe conditions.ttta-;zzDerek DarmstaedterHousehold Media Group, LLC