### j

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### Trans Global Productions, Inc. 5600 North Dixie Blvd.

Odessa, TX 79762 

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## ?Ci Apri128, 20'·15

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### ofTransportation**-~Docket** Management System

- 1200New Jersey Ave., SE Washington. DC 20590
Re: Exemption Request UnderSection 333 ofthe FAA Reform Act and 

### Part 11 of

### the Federal Aviation Regulations
Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Refonn Act of2012 (the "Refonn Act") and 14 C.F.R. Part 11; Trans Global Productions. Inc. operating the DJI Phantom Vision Plus version 3 Unmanned Aircraft System ("UAS" or "Phantom"), 

### seeksan exemptionfrom the Federal Aviation Regulations ("FARs") listed below and discussed inAppendixA Attached as Appendix 8 is a summary ofthis request. The requested exemption would pennit commercial operation 

### of DJI's Phantom VISion Plus, which weighs under 

### 3 lbs. and perfonns aerial photography and videography using an onboard camera. Applications for these UAS devices and associated data processing functions include 

### residential and commercial real estate, event coverage, surveying, inspection, and artistic endeavors. Use ofthe Phantom Vision Plus for aerial photography reduces the need to operate conventional aircraftforthe same purpose and providesvery high quality imagery at a

### fraction ofthe cost 

### ofsurveys using conver1tional aircraft. These savings result in enhanced efficiency and productivity forthe affected activities, as well as environmental benefits. 1 Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft and underconditions as may

## oe modified by the FAA as required by Section 333. As described more 

### fully below. the requested exemption would authorize commercial operations of aeriat surveys using the Phantom Vision Plus, which 

### at under 

### 3 lbs including battery and propellers, is small in size. The Phantom Vision Plus will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; itwill have automated control features, as described below. The Phantom Vision Plus will beoperated by an individual who has passed an 

### FAA approved ground training exam and atraining program for the UAS. 

### Finally, the 

### airspace in v-lhich the UAS will operate will be disclosed to the FAA in advance.
Trans Global Productions, Inc. respectfully submits that because this small, unmanned aerial vehicle

- the Phantom Vision Plus

- will be used in lieu ofcomparatively hazardous operations now conducted with ftxed wing and rotary conventional aircraft, ofwhich we've used in the past, the FAA can have 

### ronftdence that the operationswill achieve at least an equivalent level

### or greater level 

### of safety. Approval ofthis exemption would thereby enhance safety and fulfill the

. Secretary ofTransportation's (the FAA Administrators) responsibilities under Section 333(c) ofthe 

### Reform Act 

### to "establlsll requireme11ts for the 

### safe operation of such 

### aircraft systems 

### in the national airspace system:

1 See, e.g. Jack Nicas, Drones Find FansAmong Farmers, Filmmakers, WALL STREETJOURNAL (March 10, 2014, 7:45PM) (describing how an overseas surveyor used to spend 25,000 Euro ($34,345) to survey 15 square kilometers with a team of 12 surveyors, and itwould take 2 to 3 weeksto collect all the data. Wrth a Trimble UX5, he accomplishedthe sametaskfor 5,000 Euro and gotallthe data he neeOed in 3 to 4 days. Because the surveys cost him less to perform, he passesthose savings onto his customers.). available at http:J/online.wsj.com/newslarticles/SB10001424052702304732804579425342990070808. _/The nameand address ofthe applicant are: Trans Global Productions, Inc. Attn: Bobby L. Bailey Ph: 432-362-7122 Email: bbailey@cableone.net 5600 North Dixie Blvd 

### ()dessa, TX 79762
The company hasbeen in business since 1976.

The regulations from which the exemption is requested are asfollows: • 14 C.F.R. Part 21 • 14C.F.R. 45.23(b) • 14 C.F.R. 61.113(a) & (b) • 14C.F.R.61.133(a) 

### • 14 C.F.R. 91.7(b) • 14 C.F.R.**91.9(b)(~)** • 14C.F.R. 91.109(a) 

### • 14C.F.R.91.119 • 14C.F.R.91.151(a) • 14 C.F.R. 91.203{a) & (b) • 14 C.F.R. 91.405(a) • 14**C~F.R.** 91.407(a)(1) • 14 C.F.R. 91.409(a)(2) • 14 C.F.R. 91.417(a) Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal setforth in this letterare appropriate, provide an equivalent level ofsafety, and are in the public interest


### THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Trans Global Productions, !nc. submits that grant

### ofthis exemption application for useof

### the Phantom Vision Plus in precision aerial surveys will advance the Congressional mandate in Section 333 ofthe Reform Act to accele;ate the introduction of UASs into the national airspace system ("NAS") if it can 

### beaccomplished safely. This lawdirectstheSecretary ofTransportation to considerwhethercertain UASs may operate safely in the NAS before completion ofthe rutemaklng required underSection 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do notcreate a hazardto users ofthe NAS orthe public or pose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS inclose proximity to airports and populated areas; and 

### • Operation of

### the UAS

### within visual 

### line of sight of**~'1e** 

### operator.
Reform Act § 333{a){1). Ifthe Secretary determines that such vehicles ·may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ld. §333(c).2

2 Applicant submits that this provision places a duty on the Administrator to not only process applk:ations for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modifioation in order to alloW approval, to supply conditlon5 for the safe operation of the VAS. ESP welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require modification

### The Federal Aviation Act expressly grants the FAA the authority to 

### issue exemptions. This statutory 

### authority, by its terms, includes exempting civil aircraft, as the term is 

### defined under §40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from 

### a requirement of

### a regulation prescribed under subsection (a) or (b) ofthis section or any ofsections 44702-44716 ofthis title ifthe Administratorfinds the exemption is in the public 

### interest. 49 U.S.C. §44701(f). Sse also 49 USC §44711 (a); 

### 49 USC 

### §44704; 14 CFR §91.203(a)(1). The grant ofthe requested exemption is in the public interest based on the cleardirection in Section 

### 333 ofthe Refonn Act; the additional authority in the Federal Aviation Act, 

### as amended; the strong equivalent level ofsafety surrounding the proposed operations; ar.d the 

### signifteant public benefit, including enhanced safety and cost savings associated with transitioning to UASs for aerial survey phOtography. Accordingly, the 

### applicant respectruliy requests that the FAA

### grantthe requested exemption without delay. 

### Airworthiness ofthe Phantom Vision Plus
A critical element ofthe exemption application involves evidence ofthe airworthiness ofthe Phantom Vision Plus. Trans Global Productions, Inc. believes that it is in compliance with the requirements ofOrder 8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft, in lts 

### use ofsystems developed by DJi. 3 

### The Phantom Vision Plus has a high degree of redundancy and numerous safety features, including: • Return-to-home failsafe in the event ofa loss ofcommunications • Configurable limitations for area ofoperation and altitude
The criteria set forth in the Order specify the substantive showings ofthe device's safety and fitness for operation to ensure that the FAA 

### has sufficient basis to evaluate the aircraft's safety. 

### Mandatory Operating Conditions
Giantofthe exemption to Trans Global Productions, Inc. will be 

### subject to 

### thefo«owing 

### mandatory conditions, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates ofAuthorization, with additional restrictions: • All operations to 

### occur in Class G airspace. • Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. • Operationsto 

### be conducted over private or controlled-access property. Permission frotn •and owner/controller required before commenv"ing 

### any f'rlgr'it. • Operations to occurduring Visual Flight Rules Meteorological Conditions (VMC). • Aircraft to remain within Visual Line ofSight (VLOS}. o VLOS guaranteed vJith a cylinderofoperation around operatorof 112 nautical miles (NM). o Cylinderwalls may be expanded by observerwith ability to control aircraft. • Operations to occurduring daylight hours. • Above Ground Level (AGL) altitude to 

### be restricted to 400 feet. • All operations conducted invicinity of airport to remain more than 2.5 NM from centerline

azimuth of runway centertine measured from runway thresholds. • Operatorwill file a NOT AM for each flight, as required. All required permissions and permits will 

### be obtained from territorial, state, county or city

. jurisdictions, including local law enforcement, fire, or otherappropriate governmental agenetes.

3 Trans Global Productions. Inc. is submitting the following documents in support of this exemption application for the PhantomVISion Plus: 1) Phantom VISion Plill> Preflight Checklist (Exhibit 1);

. . . 2) Phantom Vision Plus Operations and Maintenance Manual (Exhibit 2); and 3) Phantom Vis1on Plus safety Guidefines (Exhibit 3).

## Operator Requirements
Trans Global Productions, Inc. respectfully proposes that operator requirements should take into account the characteristics ofthe 

### particular UAS. Certain UASs, such as the 

### OJI Phantom Vision 

### Plus, are characterized by a high degree of pre-programmed control and various built-in technical capabilities that limit the potential for operation outside ofthe operating conditions set forth above. The Phantom Vision Plus has a semi-autonomous navigation and control system comprised of a Ground Control Station (GCS} and auto-pilot system. Some flights can 

### be pre-programmed with GPS guidance 

### and do not**r~?quire** 

### human intervention, Additional automated safety functions and safety enhancing features of

### the Phantom Vision Plus include the following:

• Low 

### power on the aircrafttriggers escalating alarms 

### atGCS at35% 

### end 10% 

### levels. • Ifthe auto-pilot detects a lost-link to the GCS for longerthan 30 seconds, return-to-home

sequence initiates. • The aircraft, weighing less than 71bs., fu11y loaded, is constructed of

### composite material intended to absorb impact energy. Given these safety features, Trans Global Productjons. Inc. proposes t'"tat operators ofthe Phantom should not be required to hold a commercial or private pilot certification. Instead, 

### operators should be required to: • have successfully completed, at a minimum, FAA private pHot ground instructio-."1 and passed

the FAA Private Pilot written examination or FAA-recognized equivalents; • have 

### successfully demonstrated capability to operate UAS in 

### accordance with manufacturer

standards.
Trans Global Productions, Inc. 

### notes that the FAA 

### has found that safety factors permitted operation of UASs by operators 

### with these qualifiCations

### in the case of

### operations 

### pursuant to public 

### COAs when the mandatory operating conditions specified above were present. SeeFederal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval. 

### at 20-21 (July 30. 2013). The 

### FAA 

### hasthe statutory authority to grant exemptions to the 

### requtrements for 

### and privileges associated with the grant of

### atrmen's certificates. 

### 49

## usc §44701 (f). 

### In summary, applicant seeks 

### an exemption from the FARs set forth above 

### and in Appendix A to allow commercial operations 

### ofa small unmanned vehicle conducting precision aerial surveys. Approval ofthe exemption allowing commercial operations ofthe Phantom Vision Plus 

### for precision 

### SUJVeywork

### will enhance safety 

### by reducing risk. Conventional aerial survey operations, usingjetorpiston-powered aircraft present risks associated with vehicles that weigh in the neighbortlood of5,000 to 7,000 lbs.• ormore, carry large quantities offuel, passengers, and, in some cases, 

### cargo. Such aircraft mustfly to and from 

### the survey location. In contrast, a Phantom weighing less than 71bs. and powered by batteries eliminates a portion of

### that risk given the 

### reduced mass and lack ofcombustible fuel carried on board. The Phantom Vision Plus Is 

### carried to the 

### survey location, notflown there. The Phantom Vision Plus will 

### carry no passengers or 

### crew and. therefore. will not expose any individuals to the risks associated with manned aircraft flights. Additionally, no national security issue is raised by the grant ofthe requested 

### exemptions. Given the size, 

### load carrying capaC!'ty, speed atwhiC!'l it operates. and the fact that it carries noexplosives orother dangerous materials, the Phantom Vision Plus poses no threatto national security. The operation ofthe Phantom Vision Plus, weighing less then 71bs., for precision surveys in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant ofthe exemptions requested herein, including exempting Trans Global Productions, Inc.

. from the requirements of Part 21. The Phantom Vision Plus's satisfaction ofthe

### criteria set forth tn Section 333 ofthe Reform Act-size, weight, speed, operating capabilities, lack of proximity to airports and populated areas, operati_on within visual line of

### siaht, and national security-and its showing of

### an equivalent level of

### safety as 1t may relate to the**requ~ement**

### for a pilot's license, provide more than adequatejustification for the grantoftherequested exemptions allowing commercial operation ofthe Phantom Visum Plus in the commercial precision aerial survey. photography andvideo business. 

### My current plan is to use 

### my Phantom Vision Plus to shoot

### video for my clients

### for use in 

### TV commercials and video productions. Some 

### of my dients have already expressed 

### adesirefor me to do so. I plan 

### on buying a DJI Inspire, a much mora expensive UAS than the Phantom, ifthere is a lot of desirefrom my clients.

Very Respectfully, ·

### APPENDIX A 

### EXEMPTION REQUESTAND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION Trans Global Productions, Inc. requests an exemption from the fofiowing regulations as well as any additional regulations 

### tr!Bt may technically apply to the

### operation ofthe 

### Phantom Vision Plus.
14 

### C.F.R. 

### § 45.23{b): Marking of the Aircraft 

### The regulation provides: When mar1<s include only the Roman capital letter "N" 

### and the registration number is displayed on limited, restricted or iight-sport category aircraft orexperimental orprovisionally certificated aircraft. the 

### operator mustalso display onthat aircraft 

### neareach

### entrance 

### to the cabin, cockpit, or pilot station, in letters not tess than 2 

### inches nor 

### more than 6 inches high, the 

### words**~limited,= ~restricted,=**  

### "light-sport,= "experimental," or "provisional," as applicable, The Phantom Vision Plus has no entrance to the cabin, cockpit, or pilot station on which the word "Experimental" can 

### be placed. 

### Given the 

### size ofthe 

### UAV, two-inch lettering will 

### be impossible. The word "Experimenter wiil be placed on the forward fuselage in compliance vmh 

### § 45.29(f). 

### The equivalent level ofsafety will be achieved by having the Phantom Vision Plus marked as required by 

### § 45.29(1) 

### where the pilot, observer. and 

### othersworking with the UAVwill see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to L'lis regulation, Exemption Nos. 10700, 8738, 

### 10167and 10167A.


### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR 

### § 91.203(a)(1) Section 91.203(a)(1) requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, 

### entitled Airworthiness Certificates. establishes the procedural requirement$

### for the issuance of airworthiness certificates as required by FAR 

### § 91.203(a)(1). Given the size ofthe aircraft (under 31bs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of

### airworthiness process under Part 21 Subpart H 

### to achieve orexceed current safety levels. Such 

### an exemption meets the 

### requirements ofan equivalent level ofsafety under Part 11 and Section 333 of

### the Reform Act. 

### The Federal Aviation Act

### and Section 333 of

### the Reform Act

### both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration 

### of the size. weight. speed. operational capability, and proximity to airports and populated areas ofthe UAS involved. In this case, an anatysis ofthese criteria demonstrates that the 

### Phantom Vision Plus operated without an airworn;iness certificate, underthe conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an air worthiness certifteate. The Phantom Vision Plusweighs less than 3 lbs. fully loaded. It will notcarry a pilot or 

### passenger,**v.~l!** not

### carry flammable 

### fuel. and

### will operate exclusively within an area 

### pre-disclosed and 

### in compliance with conditions set forth herein. Operations underthis exemption will be tightly controlled and monitored by both the operator. pursuant to 

### the conditions set forth above. and 

### by local 

### public safety 

### requirements. Receipt oftheprior

### permission 

### ofthe land 

### owner, 

### lne size ofthe aircraft, the lack offlammable fuel, and the fact 

### that the aircraft is carried to the location and notflown there all establish the equivalent level ofsafety. The Phantom Vision Plus construction with absorbent material provides at least an equivalent level of safety to that ofsuch

### operations being conducted 

### with conventional aircraftthatwould be orders-of-magnitude largerand would be carrying passengers, cargo, and flammable fuel.


### 14 C.F.R. 

### § 61.113(a) 

### & 

### (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. Section 61.113(a) 

### &(b) limit private pilots to no-n-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Phantom Vision Plus in this case is remotely controlled with 

### no passengers orproperty ofothers on board. Section 61.133(a)**req~ires** 

### a': individual with a commercial pilot's license to be pilot in command of an 

### aircraftfor compensation orhire. Trans Global Productions. Inc. respectfully proposes thatoperator requirements should take into 

### account the characteristics ofthe particular UAS. Trans Global Productions, Inc.'s Phantom Vision Plus has a high degree of pre-programmed control and various buj1t-in tectmlcal capabilities that strictly limit the potential for

### operation outside ofthe operating conditions.set_forth in the 

### exemption application. The Phantom Vision Plushas a**semi-auto~omous** 

### navigation**~nd** 

### control system comprised ofa Ground Control Station (GCS} and auto-pilot system. Some fhghts are

-- - ------- -pre-programmedwith precisjon GPS guidance anddo not require human Intervention. Additional automated safety functions and safety enhancing features ofthe Phantom VISion Plus include the following: • Low poweron the aircraft triggers escalating alarms at GCS at 35% and 10% levels. • Ifthe auto-pilot detects a lost-link to the GCS for longerthan 30 seconds. landing procedure

begins. • The aircraft, weighing less than 31bs., fully loaded, is constructed ofcomposite material which

is intended to absorb impact energy. Given these safety features, Trans Global Productions, Inc.proposes thatoperators ofthe Phantom Vision Plus should not be required 

### to hold a commercial or private pilot certification. Instead, operators should be required to: • have successfully completed, at a minimum, FAA private pilot ground instruction and passed

the FAA Private Pilot written examination or FAA-recognized equivalents; • have completed the manufacturer's training programfor operation ofthe UAS. The

manufacturer'straining programwill have been satisfactorily reviewed throughthe SAC process.
Trans Global Productions, Inc. notes thatthe FAA hasfound that safety factors permitted operation of UASs by operators with these qualifications in the case ofoperations pursuant to public COAs where the mandatory operating conditions specified above are present.
See Federal Aviation Administration, Notice N-8900.227, UnmannedAircraft Systems (UAS) OperationalApproval, at20-21 (July 30, 2013). The FAA hasthe statutory authority, granted at49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions. an equivalentlevel ofsafety will be provided by allowing operation ofthe Phantom Vision Plus without a private pilot's certifrcate

### or a commercial 

### pilafs certificate. underthe conditions set forth 

### herein. The risks associated with the operation ofthe Phantom Vision Plus (given its size, speed, operational capabilities, and lack ofcombustible fuel) are 

### so diminished

### from the level of risk associated

### with private pilot operations Oicommercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations ofthe UAS as setforth above meets or exceeds the present level ofsafety provided under 

### 14 C.F.

### R. § 61. 113(a) 

### & (b) 

### and does not rise 

### to the level of requiring a commercial pilotto operatethe aircraft under§61.133(a). 

### 14 C.F.R. 

### § 91.7(a): Civil aircraft ai!Worthiness. 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 ofthe Phantom Vision Plus without an airworthiness certificate, no standard will existfor airworthiness ofthe Phantom Vision Plus. Given the size ofthe aircraft and the requirements that have presumably already been met in the SAC approval process for the Phantom VIsion Plus (for Instance. the Phantom VIsion Plus's Maintenance & Inspection Manual and Safety Chec.ldist), an equivalent level ofsafety will beac:Pleved by insuring compliancewiththe manuals priorto eachfltght.


### 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No person may operate a U.S.-reglstered civil aircraft

... (2)

...Forwhich an**Alrpl~ne** . . or Rotorcraft Flight 

### Manual is not required

### by §21.5 of

### this chapter. unless lllere IS available 1n the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material. markings, and placards. orany combination thereof. Giventhe size and configu;ation ofthe Phantom Vision Plus. it has no ability or place to carry such a flight manual on

### the aircraft, 

### not only becausethere is no piloton board, but because there is no room

### ~r**capa~ity** to carry such an item on the aircraft. The equivalent level ofsafety

### vlill be achieved 

### by keeptng the flight manual (see. e.g., UserGuide.**-------~----** -----Exhitm 2) at the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following exemptions tothis regulation: Exemption Nos. 8607, 8737, 8738, 9299,9299A,9565,9565B, 10167, 10167A, 10602,32827,and10700.


### 14 C.F.R. 

### § 91.109(a) & 91.319(a)(1): Flight Instruction These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. The Phantom Vision Plus is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use 

### ofa control box that communicates

### •.vith the aircraftvia radio communications. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level ofsafetywill 

### beassured. The FAA 

### hasapproved exemptionsfor flight training withoutfully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A The equivalent level ofsafety will 

## oo achieved by the manufacturer providing the training 

### as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots famlilarwith the Phantom Vision Plus.


### 14 CFR 

### § 91.119: Minimum SafeAltitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying overareas otherthan congested areas to an altitude of500 feet above the surface, except overopen water orsparsely populated areas. In those cases, theaircraft may not be operated closer than 

### 500feet to anyperson. vessel. vehicle. or structure. As setforth herein. the Phantom Vision Plus will never operate at higherthan 400feet AGL It will, however, be 

### operoted to 

### avold congested or populated areas 

### il'ia.t are depicted in yellow on VFR sectional charts. Because aerial survey work, photography and videography must be accomplished 

### at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119{c) is needed. The equivalent level ofsafetywill be achieved giventhe size, weight, speed, end materialwith which the Phantom Vision Plus is built. Also, no flight will be taken without the permission ofthe land owner 

### orthose who control the land. Because 

### ofthe advance notice to the landowner. 

### all affected individuals will be aware oftheflights. Compared to aerial operations conducted lh'ith aircraft or rotorcraft weighing far more than 

### 3 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at orbelow 500feet AGL. Indeed, the low-altitude operations ofthe UAS will maintain separation between these smaii-UAS operations and the operations ofconventional aircraft that must compty with Section 91.119.


### 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning ·a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there isenough fuel to fly to the first point of intended landing and, assuming normal cruising speed -(1) During the day, to

### fly afterthatfor at least 30 minutes; or(2) At night, to fly afterthatfor at least45 minutes." The Phantom Vision Plus batteries provide approximately 25 minutes of powered 

### flighl Withoutan exemption from§ 14 CFR 91.151, the UAS's flights would 

### be limited to approximately 20 minutes in length. Given the limii.ations on its proposed operations and the location of L'iose proposed operations, a longertime frame forflight in daylight VFR conditions is reasonable.

. . . Trans Global Productions, Inc. believes that an exemptiOn from 14 CFR 

### § 91.151{a) IS safe andw1th1n the scope of a prior exemption. 

### See Exemption 10673 (allowing LocKheed 

### Martin Corporation to operate without compliance with 91.151(a)). Operating the small UAS, without 30**minute~** of**reserv~** fuel does not engenderthe type 

### ofrisks that Section 91.151 (a) was meantto prevent giVen the s1ze and**s~eed** at which the UAS operates. The fact that itcarries no pilot, passenger, orcargo**al~o** er:'hances**1t~** safety. Additionally, limiting Phantom Vision Plus flights to 20 minutes**wou.l~** not affect 1fs**f11~ht** capaCity. Ifthe operating software goes intowarning of low battery the Phantom V1s1on Plus would s1mpty return to.; 

# . .

home and land. Given its weight and construction material, the risks are less than contemplated bythe current regulation.


### 14 C.F.R. 

### § 91.203 {a) 

### & {b): Carrying Civil Aircraft Certification and Registration This regulation provides asfollows; (a)

...no person may operate a civil aircraft unless it has

...an appropriate and a.ment airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section ora special flight authorization issued under§91.715 is displayed 

### atthe cabin orcockpit entrance so that it is legible to passengers or

## crew. The Phantom Vision Plus fully loaded weighs no morethan 31bs. As such, there is no ability orplace to carry certification and registration documents orto display them on the UAS. In addition, there is no piloton board the aircraft. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample ofotherexceptions Includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700.


### 14 C.F.R. 

### § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraftoperatororowner "shall have thataircraft inspected as prescribed in subpart E ofthis 

### part and shall between required inspectjons, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...= Section 91.407 similarly makes reference to requirements in Part

### 43; Section 91.409(a)(2) requires an annual inspectionfor the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner oroperatorto keep 

### records showing certain maintenancework that has been accomplished by 

### certificated mecllanlcs, under Part 43, or licensed pilots and records of approval ofthe aircraft for return to service. Maintenance ofthe Phantom Vision Plus will be accomplished by the owner/operator pursuanttothe manuals, such as Exhibit 3. An equivalent level ofsafety will be achieved because the UAS is small in size, 

### wt!l operate only in restricted predetermined areas, and is nota complex mechanical device. As provided in the attached User Manual and the Safety Checklist, the operator of Phantom 

### VISion Plus will ensure 

### that the UAS 

### is in working orderpriorto initiating flight, perfoml required maintenance, 

### ar.d keep a log ofany maintenancethat is performed. M<lraover, the operator is the person mostfamiliar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety.... 

## ..**~·** 

# •.

APPENDIX 8


### SUMMARY OF Trans Global Productions, Inc.
SECTION 333 EXEMPTION REQUEST Trans Global Productions. Inc. hereby provides pursuant to Part 11 a summary ofits exemption 

### application to allow commercial operation of

### the Phantom Vision Plus unmanned atrcraft in preciston aerial Photography abdvideography work. An exemption is 

### requested from the following regulations:
•14 C.F.R. Part 21 

### •14 C.F.R. 

### 45.23(b) •14 C.F.R. 61.113(a) & (b) •14 C.F.R. 61.133(a) ·14 C.F.R. 91.7(b) •14C.F.R. 91.9(b)(2) •14 C.F.R. 91.109(a) •14C.F.R 

### 91.119 •14 C.F.R. 91.151(a) •14 C.F.R. 91.203(a) & (b) •14C.F.R. 91.405(a) 

### •14 C.F.R. 91.407(a)(1) •14 C.F.R. 91.409(a}(2} •14 C.F.R. 91.417(a)