j 

/ Trans Global Productions, Inc. 

5600 North Dixie Blvd. 

Odessa, TX 79762 

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·- •••• f - .-. I: ?Ci Apri128, 20'·15 

_ l!&=Department of Transportation 

-~Docket Management System 

- 1200 New Jersey Ave., SE 

Washington. DC 20590 

Re: 

Exemption Request Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Refonn Act of 2012 (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"), seeks an exemption from the Federal Aviation 

Regulations ("FARs") listed below and discussed in Appendix A Attached as Appendix 8 is a summary 

of this 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 of the Phantom Vision Plus for aerial photography reduces the need to operate conventional 

aircraft for the same purpose and provides very high quality imagery at a fraction of the cost of surveys 

using conver1tional aircraft. These savings result in enhanced efficiency and productivity for the 

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 of safety to currently authorized operations using manned aircraft 

and under conditions 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; it will have automated control features, 

as described below. The Phantom Vision Plus will be operated by an individual who has passed an 

FAA approved ground training exam and a training 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 of comparatively hazardous operations now 

conducted with ftxed wing and rotary conventional aircraft, of which we've used in the past, the FAA 

can have ronftdence that the operations will achieve at least an equivalent level or greater level of 

safety. Approval of this exemption would thereby enhance safety and fulfill the . 

Secretary of Transportation's (the FAA Administrators) responsibilities under Section 333(c) of the 

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 Fans Among Farmers, Filmmakers, WALL STREET JOURNAL (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 it would take 2 to 3 weeks to collect all the data. Wrth a Trimble UX5, he 

accomplished the same task for 5,000 Euro and got all the data he neeOed in 3 to 4 days. Because the surveys cost him 

less to perform, he passes those savings onto his customers.). available at 

http:J/online.wsj.com/newslarticles/SB 1 0001424052702304 732804579425342990070808. 

_/ 
The name and address of the 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 has been in business since 1976. 

The regulations from which the exemption is requested are as follows: 

• 14 C.F.R. Part 21 

• 14 C.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)(~) 

• 14 C.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 

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Trans Global Productions, !nc. submits that grant of this exemption application for use of the 

Phantom Vision Plus in precision aerial surveys will advance the Congressional mandate 

in Section 333 of the Reform Act to accele;ate the introduction of UASs into the national airspace 

system ("NAS") if it can be accomplished safely. This law directs the Secretary of Transportation to 

consider whether certain UASs may operate safely in the NAS before completion of the rutemaklng 

required under Section 332 of the Reform Act. In making this determination, the Secretary is required 

to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of ~'1e operator. 

Reform Act § 333{ a){ 1). If the Secretary determines that such vehicles ·may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

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 of the 

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) of this section or any of sections 44702-44716 of this title if the 

Administrator finds 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 of the requested exemption is in the public interest based on the clear direction in Section 

333 of the Refonn Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety 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 grant the requested 

exemption without delay. 

Airworthiness of the Phantom Vision Plus 

A critical element of the exemption application involves evidence of the airworthiness of the 

Phantom Vision Plus. 

Trans Global Productions, Inc. believes that it is in compliance with the requirements of Order 

8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft, in 

lts use of systems 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 of a loss of communications 

• Configurable limitations for area of operation and altitude 

The criteria set forth in the Order specify the substantive showings of the device's safety and fitness for 

operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety. 

Mandatory Operating Conditions 

Giant of the exemption to Trans Global Productions, Inc. will be subject to the fo«owing mandatory 

conditions, which are based upon operating conditions set forth for operation of UAS by public entities 

pursuant to Certificates of Authorization, 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. 

• Operations to be conducted over private or controlled-access property. 

Permission frotn •and owner/controller required before commenv"ing any f'rlgr'it. 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Aircraft to remain within Visual Line of Sight (VLOS}. 

o VLOS guaranteed vJith a cylinder of operation around operator of 112 nautical miles (NM). 

o Cylinder walls may be expanded by observer with ability to control aircraft. 

• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centertine measured from runway thresholds. 

• Operator will 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 other appropriate governmental agenetes. 

3 Trans Global Productions. Inc. is submitting the 

following documents in support of this exemption application for the Phantom VISion 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 of the 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 of the 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 aircraft triggers escalating alarms at GCS at 35% end 10% levels. 

• If the auto-pilot detects a lost-link to the GCS for longer than 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 of the 

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 has the 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 of a small unmanned vehicle conducting precision aerial surveys. 

Approval of the exemption allowing commercial operations of the 

Phantom Vision Plus for precision SUJVey work will enhance safety by reducing risk. Conventional 

aerial survey operations, using jet or piston-powered aircraft present risks associated with vehicles that 

weigh in the neighbortlood of 5,000 to 7,000 lbs .• or more, carry large quantities of fuel, passengers, 

and, in some cases, cargo. Such aircraft must fly 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 of combustible fuel carried on board. The 

Phantom Vision Plus Is carried to the survey location, not flown 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 of the requested 

exemptions. Given the size, load carrying capaC!'ty, speed at whiC!'l it operates. and the fact that it 

carries noexplosives or other dangerous materials, the Phantom Vision Plus poses no threat to 

national security. The operation of the 

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 of the 

exemptions requested herein, including exempting Trans Global Productions, Inc. . 

from the requirements of Part 21. The Phantom Vision Plus's satisfaction of the criteria set forth tn 

Section 333 of the 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 adequate justification for the grant of the 
requested exemptions allowing commercial operation of the Phantom Visum Plus in the commercial 

precision aerial survey. photography and video 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 a desire for me to do 

so. 

I plan on buying a DJI Inspire, a much mora expensive UAS than the Phantom, if there is a lot of 

desire from my clients. 

Very Respectfully, · 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO 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 of the 

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 or experimental or provisionally 

certificated aircraft. the operator must also display on that aircraft near each 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 of the 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 of safety will be achieved by having the Phantom Vision Plus marked as 

required by § 45.29(1) where the pilot, observer. and others working with the UAV will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to L'lis 

regulation, Exemption Nos. 10700, 8738, 10167 and 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 of airworthiness. 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 of the 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 or exceed current 

safety levels. Such an exemption meets the requirements of an equivalent level of safety 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 aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size. weight. speed. operational capability, and proximity to airports and populated 

areas of the UAS involved. In this case, an anatysis of these criteria demonstrates that the 

Phantom Vision Plus operated without an airworn;iness certificate, under the 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 not carry 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 under this 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 of the prior permission of the land owner, lne 

size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and 

not flown there all establish the equivalent level of safety. The Phantom Vision Plus construction with 

absorbent material provides at least an equivalent level of safety to that of such operations being 

conducted with conventional aircraft that would be orders-of-magnitude larger and 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 or property of others on board. Section 61.133(a) req~ires a': individual 

with a commercial pilot's license to be pilot in command of an aircraft for compensation or hire. 

Trans Global Productions. Inc. respectfully proposes that operator requirements should take into 

account the characteristics of the 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 of the operating conditions. set _forth in the 

exemption application. The Phantom Vision Plushas a semi-auto~omous navigation ~nd control 

system comprised of a Ground Control Station (GCS} and auto-pilot system. Some fhghts are 

-- - ------- -
pre-programmed with precisjon GPS guidance and do not require human Intervention. Additional 

automated safety functions and safety enhancing features of the Phantom VISion Plus include the 

following: 

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. 

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds. landing procedure 

begins. 

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

is intended to absorb impact energy. 

Given these safety features, Trans Global Productions, Inc. proposes that operators of the 

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 program for operation of the UAS. The 

manufacturer's training program will have been satisfactorily reviewed through the SAC 

process. 

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 where 

the mandatory operating conditions specified above are present. 

See Federal Aviation Administration, Notice N-8900.227, 

Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the 

statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial 

operations. Given these conditions and restrictions. an equivalent level of safety will be provided by 

allowing operation of the Phantom Vision Plus without a private pilot's certifrcate or a commercial 

pilafs certificate. under the conditions set forth herein. 

The risks associated with the operation of the Phantom Vision Plus (given its size, speed, operational 

capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with 

private pilot operations Oi commercial operations contemplated by Part 61 with conventional aircraft 

(fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds 

the present level of safety provided under 14 C. F. R. § 61. 113( a) & (b) and does not rise to the level of 

requiring a commercial pilot to operate the 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 of the Phantom Vision Plus 

without an airworthiness certificate, no standard will exist for airworthiness of the 

Phantom Vision Plus. Given the size of the 

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 of safety will be ac:Pleved by insuring compliance with the 

manuals prior to each fltght. 

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) ... For which 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. or any combination thereof. Given the size and configu;ation of the 

Phantom Vision Plus. it has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room ~r capa~ity to 

carry such an item on the aircraft. The equivalent level of safety vlill be achieved by keeptng the flight 

manual (see. e.g., User Guide. 

-------~---- -----
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 to this 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 for flight 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 of a control box that communicates •.vith 

the aircraft via radio communications. If instruction is accomplished through a training program, as set 

forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for 

flight training without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. 

See Exemption Nos. 5778K & 9862A The equivalent level of safety 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 famlilar with the 

Phantom Vision Plus. 

14 CFR § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to anyperson. vessel. vehicle. or structure. As set forth herein. the 

Phantom Vision Plus will never operate at higher than 400 feet 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 of safety will be achieved given the size, weight, speed, end material with which 

the Phantom Vision Plus is built. Also, no flight will be taken without the permission of the land owner 

or those who control the land. Because of the advance notice to the landowner. all affected individuals 

will be aware of the flights. 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 or below 500 feet 

AGL. Indeed, the low-altitude operations of the UAS will maintain separation between these 

smaii-UAS operations and the operations of conventional 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 is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed -(1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The Phantom Vision Plus batteries provide approximately 25 minutes of powered flighl Without an 

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 longer time frame for flight in daylight VFR conditions is reasonable. . . . 

Trans Global Productions, Inc. believes that an exemptiOn from 14 CFR § 91.151 {a) IS safe and w1th1n 

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 

engender the type of risks that Section 91.151 (a) was meant to prevent giVen the s1ze and s~eed at 

which the UAS operates. The fact that it carries no pilot, passenger, or cargo al~o er:'hances 1t~ safety. 

Additionally, limiting Phantom Vision Plus flights to 20 minutes wou.l~ not affect 1fs f11~ht capaCity. If the 

operating software goes into warning 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 by the 

current regulation. 

14 C.F.R. § 91.203 {a) & {b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows; 

(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) of this section or a special flight authorization issued under §91. 715 is displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The Phantom Vision Plus fully loaded weighs no more than 31bs. As such, there is no ability or place 

to carry certification and registration documents or to display them on the UAS. In addition, there is no 

pilot on board the aircraft. An equivalent level of safety will be achieved by keeping these documents 

at the 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 of other exceptions 

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 aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspectjons, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... = 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the 

owner or operator to keep records showing certain maintenance work that has been accomplished by 

certificated mecllanlcs, under Part 43, or licensed pilots and records of approval of the aircraft for 

return to service. Maintenance of the Phantom Vision Plus will be accomplished by the owner/operator 

pursuant to the manuals, such as Exhibit 3. An equivalent level of safety will be achieved because the 

UAS is small in size, wt!l operate only in restricted predetermined areas, and is not a 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 order prior to initiating flight, perfoml 

required maintenance, ar.d keep a log of any maintenance that is performed. M<lraover, the operator is 

the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy 

condition and to ensure an equivalent level of safety. 
... .. ~· •. 

APPENDIX 8 

SUMMARY OF 

Trans Global Productions, Inc. 

SECTION 333 EXEMPTION REQUEST 

Trans Global Productions. Inc. hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the Phantom Vision Plus unmanned atrcraft in preciston 

aerial Photography abd videography 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) 

•14 C.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) 

•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)