Zephyr Aerial Productions, LLC

Attn: Christopher Norton , CEO PO Box 130387 The Woodlands, TX 773 93 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590
Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.10 3; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)
Dear Sir or Madam:

Pursuant to Section 333 of the FAA Moderniz ation and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Zephyr Aerial Productions, LLC operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial oper ation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA. As detailed in this document and the attached Appendix of UAS, the requested exemption would permit the operati on of UAS platforms previously approved by the FAA for commercial operations in the United States. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) Reform Act. The name and address of the applicant is: Zephyr Aerial Productions, LLC Attn: Christopher Norton , CEO Phone: 281

- 723

- 4488 Email: Zephyr.Aerial.Productions.llc@gmail.com Address: PO Box 130387 , The Woodlands, TX 773 93

- 0387
Regulations from which the exemption is requested:
14 CFR Par

t 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.10914 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)
**AUTHORITY FOR EXEMPTIONS** The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections §44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate in the national airspace system without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider: • The UAS’ size, weight, speed and operational capability; • Whether the UAS operates within the visual line of sight of the operator; • Whether the UAS operates outside of highly populated areas and away from close proximity to airports. Reform Act 333(a). If the Secretary determines that a UAS “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.” Id. 333 (c).
**UAS AND OPERATIONAL DESCRIPTION** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. As the operator of these aircraft, Zephyr Aerial Productions is committed to the following conditions and limitations on its operations. Zephyr Aerial Productions understands that failure to comply will be grounds for the immediate suspension or rescission of any exemption granted.
1. Operations are limited to the UAS listed in the Appendix when weighing less than 55 pounds including payload.
2. Operations for the purpose of closed

- set motion picture and television filming are not contemplated.
3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles perhour). In no case will the aircraft be operated at airspeeds greater than the

maximum aircraft operating airspeed recommended by the aircraft manufacturer.
4. The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in Command (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 U.S. driver’s license.
6. All operations wil l utilize a visual observer (VO). The aircraft will be operated within the visual line of sight (VLOS) of the PIC and VO at all times.
7. All operating documents needed to operate the UAS and will be accessible during UAS operations and made available to the Administrator upon request. The operator will also present updated and revised documents if it petitions for extension or amendment.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e. g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations.
9. Zephyr Aerial Productions is 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 determine the UAS is in a condition for safe flight. 11. Zephyr Aerial Productions will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption will comply with all manufacturer safety bulletins. 13. The PIC will hold a UAS flight training certificate, in some cases training directly from the aircraft manufacturer, and a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. 14. Zephyr Aerial Productions will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated to acquire aerial data, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Zephyr Aerial Productions will operate flights for the purposes of training Zephyr Aerial Production’s PICs and VOs (training, proficiency, and experience building) and determining the PIC’s ability to safely operate the UAS. 15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).16. The aircraft 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 den oted with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA. 17. The aircraft 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 PI C. 18. If the UAS loses communications or loses its GPS signal, the aircraft will return to a pre

- determined location. 19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power or fuel for the aircraft to conduct the intended operation and to operate after that for at least five minutes or with the reserve power or fuel recommended by the manufacturer if greater. 21. All operations shall be conducted in accordance with an ATO

- issued COA if the blanke t COA does not cover the intended operation. 22. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 23. Documents used by Zephyr Aerial Productions to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 24. The aircraft will remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may be operated by the PIC from a moving device or vehicle; however, specific requests will be made via subsequent COA. 26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the aircraft or debris in the event of an accident; or b. The owner/controller/operator of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made an assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. 27. The PIC, VO, operator trainees or essential persons will not be considerednonparticipating persons under this exemption.

28. All operations conducted over private or controlled

- access property will be conducted with the permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 29. 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 to the FAA's UA S Integration Office (AFS −80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
**DESCRIPTION OF SPECIFIC REGULATIONS** C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Avi ation Act (49 U.S.C.§44701 (f)) 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 airpo rts and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restri ctions and conditions proposed. The UAS to be operated here under is less than 55 lbs. fully loaded, carries neither a pilot nor p assenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or f lammable liquid fuels, and inability to carry a substantial external load.
14 C.F. R. § 45.23 (b). Marking of the aircraft This regulation requires that certain limited, restricted or light

- sport category aircraft or experimental or provisionally certific ated aircraft must be marked with letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," o r "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. Zephyr Aerial Productions will mark the UAS as practical. 14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in commandSections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a UAS flight

-training course. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by P art 61 when drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b). 14 C.F.R. §91.7(a): Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maint enance and use of safety checklists prior to each flight an equivalent level of safety will be provided.
1 4 C.F.R. § 91.9 (b) (2): Civil aircraft flight manual in the aircraft Section 91.9 (b) (2) provides: No person may operate a U.S.

-registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration 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 or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. 14 C.F.R. § 91.1 03: Preflight action This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery or fuel requirements, checking takeoff and landing distances, and all other actions in the Operating Manual and safety checklists. These actions will provide an equivalent level of safety.
14 C.F.R . §91.109: Flight instruction Section 91.103 provides 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls f or a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. 14 C.F.R. § 91.1 19: Minimum safe altitudesSection 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will

never operate at altitude higher than 400 AGL and all operations will occur during daylight hours under Visual Meteorological Conditions (VMC ) only. The equivalent level of safety will be achieved given the size, weight and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner. Because advance notice to the property owner and any onsite personnel, as well as the precautions outlined below, all affected individuals will be aware of the planned flight operations. Flight operations will be conducted at least 500 feet from all non

-participating persons (persons other than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, unless operations do not present an undue hazard. The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be conducted at least 5 mil es from an airport. The PIC or VO will provide notification to the local Flight Standards District Office and airport controller of all operations within 5 miles of an airport. The FAA will have advance notice of all operations through the filing of notice s -to

- airmen. Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS proposed herein, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.
14 C. F.R. §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, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR c onditions Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from Section 91.151(a) (1) is requested to the extent required to allow flights of a variety of UAS during daylight hours in visual flight rules (VFR) conditions to continue until 90 percent of remaining battery power or fuel reserves remain. Zephyr Aerial Productions seeks the requested relief because without an exemption from Section 91.151(a)(1), the flight time duration of the selected aircraft will be reduced and severely constrain the practicality of any aerial acquisition of data that Zephyr Aerial Productions proposes to conduct pursuant to this Petition. The technical specifications of the proposed UAS, their Operations Manuals, and Zephyr Aerial Production’s proposed operating limitations, ensure that Zephyr Aerial Production will safely operate the selected aircraft during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain.14 C.F.R. §91.203 (a) and (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore, there is no ability or place to carry certification and registration documents or to display them on the UAS. 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, to the extent they are applicable to the UAS. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (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 sh all inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished pursuant to the User Guide or Operating Manual. An equivalent level of safety will be achieved because these UASs are limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. The PI C will ensure that the UAS is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.
**ADDITIONAL INFORMATION** The applicant, Christopher Norton , has been professionally involved in commerci al aviation for more than 30 years. Also the primary pilot, Christopher Norton currently holds a n Airline Transport Pilot License with type rating in the B

- 737 . Christopher also performs the duties of Line Check Airman for the B737

. In addition he hold a B 727 Flight Engineers Certificate and a Flight Dispatchers Certificate. Christopher Norton has an in

- depth understanding of the capabilities and safety concerns involved in using this technology as an asset to the community. Satisfaction of criteria provide d in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of the applicant’s UAS.
**PU BLIC INTEREST**  Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances safety while reducing risk. Manned aircraft in certain application such as pipeline monitoring create a greater risk because the aircraft are much larger and carry an onboard human pilot. In contrast, a UAS w eighing 55 pounds or less will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. In addition, additional streams of aerial data will allow large commercial entities to make decisions abou t how to best deploy ground resources and ensure the safety and cost

- effectiveness of their operations. **EQUIVALENT LEVEL OF SAFETY**Zephyr Aerial Productions proposes that the exemption requested herein apply to civil aircraft that have

the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current and proposed regulatory structure. **PRIVACY** All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise they will be made anonymous.
**NATIONAL SECURITY** Given the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue.
**ADDITIONAL INFORMATION Christopher Norton, Founder and CEO**  Christopher Norton has been professionally involved in commercial aviation for more than 30 years. Christopher graduated from Florida Institute of Technology with a Bachelor of Science in Aviation Management. A s the primary pilot, Christopher Norton currently holds an Airline Transport Pilot License with type rating in the B

- 737. Christopher also performs the duties of Line Check Airman for the B

- 737. In addition he hold a B

- 727 Flight Engineers Certificate and a Flight Dispatchers Certificate. Christopher has been involved in a number of Flight Ops IT initiatives throughout his career . Starting in the late 1980’s, Christopher was part of a four

-man team that worked to bring Internet based communications to a maj or airline pilot group. Later Christopher led the team that sele cted and implemented and created the training program s that created the PBS Scheduling System currently in use by over 10,000 pilots. He also worked hand and hand with Steve Abdu in the selection of the initial EFB product that would bring this technology to a majo r airline. The EFB Project involved interfacing with the FAA and numerous other airlines working towards a Class 2 solution. During the EFB Project, Christopher was a member of the w orking group responsible for putting together the video and writt en documentation that resulted in the then FAA Administrator, Marion Blakey , approving Own Ship Moving Map for Taxi on a Class 2 device. Most recently, Christopher was selected by management of a major airline to join the Change Management Team and was directly involved in most Flight Ops IT integration projects related to the merger. These projects included CCS ( Crew Communications System) used by over 10,000 crewmembers, ACARS 2.0 Inflight Data Uplink Projects , and iPad Based Class 2 EFB initiatives. Christopher Norton has an in

- depth understanding of the capabilities , technology and safety concerns involved in integrating UAV technology in the NAS and using it as an asset to the community. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of the applicant’s UAS.
**Steve Ab du, EVP Video Effects**  Steve Abdu has more than 42 years of experience as a Captain and First Officer for a major U.S. airline. His experience includes global operations utilizing the B727, B737, B757, B767, and B777. During his airline tenure, Steve overs aw the implementation of a Preferential Bidding System (PBS), and was instrumental in developing the training program to introduce the new system to the pilot group. Additionally, Steve was part of a select group of pilots chosen by his airline to determine which variant ofthe Electronic Flight Bag (EFB) would be installed on the B757/767 fleet.

An avid technologist, Steve was naturally interested in Unmanned Aerial Vehicles (UAVs ) when the evolving technology became available and affordable. Sensing the tremendous potential these vehicles possess, he assembled 2 small UAV’s for evaluation and to learn the technology. His fleet has expanded to 6 UAV’s, equipped with cameras and First Person Viewing (FPV). Steve also is a principal in a video production c ompany that has produced instructional videos for the past 20 years and has over 30 productions on the market. He shoots, directs, produces, edits and manufactures the DVD media final output from his studios in northern New Hampshire and Vista Mar, San Carlos, Republic of Panama. **Norm Gustitis, EVP Emergency Management Services**  Norm Gustitis is a Captain at a major U.S. airline with over thirty years and approximately 29,000 hours of flight experience. He holds Ty pe Ratings on the EMB

- 110, DC

- 9, MD

- 80, B7 37, B757 and B767. Norm graduated from Southeastern Oklahoma State University in 1980 with a Bachelor of Science Degree in Aerospace Technology and a minor in Business Administration

- Management. Norm has served in several Flight Operations Management roles, including Assistant Chief Pilot, Lead B757/767 Line Check Airman, FAA Aircrew Program Designee (APD), and pilot hiring board member. After serving in these positions he was then selected as a F light Operations Duty Manager (FODM), a position designed for specially trained and qualified Captains to provide 24/7 real

- time support from his airline’s operations center to flight crews located around the world experiencing emergencies, diversions, mec hanical problems, dispatch, medical and/or technical issues. Additionally , Norm provided technical and operational support for the B

- 787 proving runs required of his airline by the FAA for N orth American operational certification. He is currentl y involved in the training and qualification process for both new hire and transition pilots in the B

- 757/B

- 767 for domestic and international operations. **John Keown, EV P, Marketing**  John Keown has more than 29 years experience in aviation and has been working for a major U.S. airline for the past 17 years with 7 years experience as a Captain. He has worked closel y with the FAA on regulatory issues and brings a wealth of knowledge to the table in navigating the bureaucratic processes. His experience extends beyond th e cockpit as he also works on technology

issues both inside and outside the airline in which he is currently employed and has successfull y acquired, started, run, and sold several small businesses. **Dianna Klein, EVP, Regulatory Compliance** Dianna Klein ha s been involved in numerous facets of aviation including Part 91 and 141 flight instruction, Part 135 charter operations, Part 121 airline operations at the regional and major level, and as an officer and pilot in the United States Air Force. She is currently a B

- 787 pilot for a major U.S. airline and holds ty pe ratings in the BE

- 400 and the B

- 737.Dianna holds a Master of Science in Aeronautical Science degree with a dual specialization in

Aviation Safety

and Human Factors from Embry

- Riddle Aeronautical University

- Day tona Beach . Additionally , she is a graduate of the MITRE Corporation’s Aviation Safety Management Sy stems Principals course. Dianna is also the President of Shenandoah Aviation, LLC, an aviation safety consulting firm located in Spring, TX.
D ianna has held several Flight Operations positions at her airline, including B

- 737 Instructor/Evaluator, Project Manager, and Flight Manager. Prior to flying for a major U.S. airline, Dianna flew the EMB

- 145 for a large U.S. regional airline, and was also a Captain on a King Air C90 for a Part 135 operator. Also, she flew the C

- 5 Galax y in support of combat operations during Operations Iraqi and Enduring Freedom for both the USAFR and Air National Guard. **Peter Schnur, EVP, Training and Standards** 
Peter Schnur is a B

- 787 First Officer at a major U.S

. airline since January of 1999. In addition to the 787, he has flown the B

- 737 as a First Offi cer and Captain, and the B

- 757 and B

- 767 as First Officer. Prior aviation experience includes operation of the EMB

- 120 as a First Officer, the ATR

- 42 and ATR

- 72 as Captain and Check Airman, and the EMB

- 145 as Captain and Line Check Airman. He also worked as a Certified Flight Instructor (with Instrument and multi

- engine ratings) from 1992 until 1996, accruing more than 1,500 hours of instructional time in single

- and multi

- engine General Aviation airplanes. Peter graduated from Embry

- Riddle Aeronautical University, Prescott Campus, in June of 1994, with a Bachelor of Science in Aeronautical Science. Additionally, Pet er has worked for the pilot’s union associated with his airline on the Scheduling Committee from 2006 to 2013. His committee duties included implementation of a preferential bidding system (PBS), including initial development and deployment of a training s ystem and syllabus. The documents, training classes and support systems he developed continue to be utilized by the airline today

. Other areas of expertise derived from his committee involvement include pilot staffing and allocation , trip construction, and the negotiation and implementation of pilot contracts

.

**FEDERAL REGISTER SUMMARY** Docket No.: No. FAA

- 2015

-

____ Petitioner: Zephyr Aerial Productions, LLC Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations (14 CFR). Description of Relief Sought: Zephyr Aerial Productions is seeking an exemption to conduct commercial acquisition of aerial data using unmanned aircraft systems. Sincerely, ////Signed////Christopher Norton

CEO & Founder Zephyr Aerial Productions, LLC PO Box 130387 The Woodlands, TX 77393Appendix

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- S 82. C

- Astral Bramor gEO 83. CarbonCore Octocopter 1000 84. Carbon Core Cortex Quadcopter 85. CCO w/Wkm M 86. Chameleon Pro12

87. CinesStar 88. Cinestar 6 89. Cinestar X8 90. Cinestar 8 91. Cinestar 8 HL 92. Cinestar 8 Okto XL 93. Coaxial Quad Multirotor VAO1

- V1 94. Coaxial Quad Multirotor VAO2

- V2 95. CopelandRED LLC Delta Wing Aircraft 96. Cy berQuad Maxi 97. DJIFlame Wheel F450 98. DJIFlame Wheel F550 99. DAx8 100. DJI Inspire 101. DJIInspire 1 102. DJIInspire 2 103. DJIM P330z 104. DJI Phantom 105. DJIPhantom 1 106. DJIPhantom 2 107. DJIPhantom 2+ 108. DJIPhantom 2 Vision 109. DJIPhantom 2 Vision+ 110. DJIPhantom Vision + 111. DJIPhantom 3 112. DJIPhantom FC40 113. DJISpreading Wings S900 114. DJISpreading Wings S1000 115. DJISpreading Wings S1000+ 116. DJI S800 117. DJIS800 EVO 118. DJI T600 119. Draganflyer Guardian 120. Draganflyer X4ES 121. Draganflyer X4P 122. Draganflyer X6 123. DT

- 18 124. DYS D800

- X8 125. Eagle VTOL 126. Eagle V2 127. E

- Flite Apprentice 128. Event 38 E384 129. F

- 450 130. Falcon VTOL13

131. Fire Fl y 6 132. First Aerial Responder UAV 133. Flame Wheel G4 7.8 Skycrane 134. Flying

- Cam 3.0 SARAH 135. Foxtech Kraken 130 V2 136. FreeFl y S ys tems ALTA RTF 137. FreeFl y S ys tems Octocopter Airframe (Legacy) 138. G4 139. G4 models 140. GeoStar 141. GerMAP G220 142. GerMAP G180 143. goFarm GF

- 1 144. Gry phon Dy namics X8 145. GT80X 146. Harris 18 HL 147. HEFF 148. Helicopters West DJ I Inspire 149. Helicopters West Sky Jib 8 150. Helios 960 151. Hawkeye Mk

- III 152. HexaCrafter HC

- 1100 85. 153. HexaCrafter HO

- 1250 154. HH Blade 350QX2 AP 155. Hobby

king “ Bixler” Fixed Wing Trainer 156. HoneyComb AgDrone 157. Horizon Hobby

Blade 350 Qx2 quadcopter 158. Hoverfl y LiveSky, BigSky 60 and H

- Frame 159. Hubsan X4 micro drone 160. HVP 14301 Multi Rotor 161. Id entified Sy stem 162. IMT Global xFold Cinema 163. Indago 164. InovalDrone:Inova One 165. InstantE ye Mk

- 2 166. InstantE ye Mk

- 2 Gen2 167. Intuitive Aerial Aeragon 168. K130 Octocopter 169. KongCopter X8 170. Kopterworx Hammer X12 171. Latitude HQ

- 4 Hy

brid Multirotor 172. LB700 173. Leading Edge Precision Vision 10 174. Leptron Avenger14

175. Lewis Realty

Associates Hexacopter 650 176. Liberty 1 177. Lockheed Martin Desert Hawk III 178. Lockheed Martin Indago 179. Matrix quad copter 180. MaxFlight 181. MD4

- 200 182. MD4

- 1000 183. Mikrokopter 2.5 184. MLB Company Super Bat 185. MU

- 1H 186. Multirotor G4 7.8 Skycrane 187. Nighthawk 188. Nighthawk VTOL 189. OktoXL 6S12 190. PAG X4 191. Parksone Radian RTF 192. Parrot Bebop drone 193. Parrot PF 725100 Bebop Drone 14MP 194. Parrot Skycontroller 195. Patriot X4 196. Patriot X8 197. Finwing Penguin V2 198. Birdseyeview FireFly 6 199. Phoenix 200. Phoenix VTOL 201. Phoenix 60 202. Phoenix 60LE 203. Pixhawk 204. Precision Drone Pacesetter 205. PrecisionHawk 206. PrecisionHawk Hawkeye Mk

- III 207. PrecisionHawk Lancaster 208. Precision Lancaster MK3 209. Prioria Hex 210. Prioria’s Maveric 211. Pulse Aerospace, PA 01 Vapor 212. Pulse Aerospace Pulse Vapor 35 213. Pulse Vapor 214. Puma AE DDL 215. PV 14817 Multi Rotor 216. PV HL 1 217. PV HL2 218. Q115

219. Quadcopter LLC MikroKopter 220. Quiet UAV 221. Qube 222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy L ift Prof. Multi

- Lo ader 223. Frame Ronin Edition Microdrones:MD4

- 1000 224. RCTimer Hexacopter 225. RDASS 226. REHawk 500 227. REHawk 680 228. RF

- 70 229. Riegl RiCopter 230. RITEWING Z3 Spade 47” 231. Ritewing Drake 60” 232. RITEWING Z3 Spade 70” 233. RITEWING Z4 Spade 52” 234. RMAX 235. Roboflight 236. Rotomotion SR

- 15 237. RV Jet 238. Scout X4 239. SD02 240. Seahawk 1.2 241. SelectTech Geospacial’s EH

- 4 242. SenseFl y eBee 243. SenseFl y eBee RTK 244. SenseFl y eXom 245. Sensurion Magpie MP

- 1 246. Service

- Drone Recon One 247. Service

- Drone Blackbird 248. SH 900 249. ShadowHawk 250. Shrike 251. Sirius 252. SkyCatch 253. Sky Jib 8 v.2 Heavy Lifter 254. Sky Phill y MI 255. Sky walker Aero 256. Sky walker Fl ying Wing X8 257. SnapRoll Media SUAS 258. Solutions Phoenix 30 259. SteadiDrone 260. Steadidrone Quad 261. Steadydrone QU4D16

262. Steadidrone Mavik 263. SuperX/P2 Multirotor 264. Swift Radioplanes Lynx 265. Tali 500 266. Talon 120LE 267. Tarot FY690S Hexacopter 268. Tarot quadcopter 269. Tarot 680pro 270. Tarot 690 271. Tarot 900 272. Tarot 960 273. Tarot T

- 15 274. Tarot T15 C/F Folding Octocopter 275. Tarot T18 UAV 276. Tarot T690 277. Tarot T810 278. Tarot T960 279. Tarsier S ys tems MoAC 280. Tayzu Robotics Titan X8 281. TBS Discovery Pro 282. Team Black Sheep Discovery Pro Tarot T15 283. T

- Rex 700E F3C 284. TREX 800E DFC PRO 285. Trimble UX5 286. Trimble UX5 hp 287. Trimble ZX5 288. Turningy

Talon 500 289. TUP X8

- 800 290. Turbo Ace CINEWING 6 291. TurboAce Matrix

- G quadcopter 292. Turbo Ace matrix

- E 293. Turbo Ace MATRIX

- 1 294. UAV Solutions Phoenix 60 295. Universeye Penguin 296. Unmanned Fl ying Rolling Orb “UFRO” 297. US2 GreenHawk 298. UtiliCopter ITX8 299. VA03

- v1 300. VA04

- v1 301. VA07

- v1 302. Viking UAS Multicopter (VTOL) 303. Viking UAS FF

- X4/X8 304. VK

- Patriot X4/X8 305. Viking UAS Patriot X4/X8 Multirotor20

17 306. Viking UAS X6 Model 800 307. Viking UAS Viking ONE 308. VK

- 450 309. Viking Unmanned Aerial Sy stems, LL C AgriView VK Ranger EX 310. Viking VK

- FF

- X4 311. VK

- Ranger EX

- SAR Fixed Wing UAS 312. Volantex Raptor Tarot T

- 18 313. Volt Aerial Robotics Octane 314. Vulcan frame controlled by a DJIA2 flight controller 315. Vulcan Mantis 316. Vulcan Octocopter 317. Vulcan Raven 318. Vulcan UAV 319. Walkera TALI H500 320. Walkera Scout X4 321. Wookong DJ I 5800 322. xCel Drones XD550CDR 323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter, and x12 Copter 324. X8

- M