Anthony D. Mason

Mason Media 7529 Ruby Keith Road White House, TN 37188

U .S. Departmen t of Transportation Docket Managemen t System 1200 N ew J ersey Ave ., SE Washingto n DC 20590
Re: Exemptio n Req uest Pursuan t to Sectio n 333 of t h e FAA Refor m Act a n d P art 11 of t h e Federal Aviation Regulation s fro m: 14 CFR 21 subpart H; 14 CFR 45.23(b ); 14 CFR 61.113(a) an d (b ); 14 CF R 91.7(a); 14 CFR 91.9(b)( 2); 14 CFR 91.103; 14 CFR 91. 109; 14 CFR 91.119(c) ; 14 CFR 91.121; 14 CFR 91.15 1(a); 14 CFR 91.203 (a) an d (b ); 14 CFR 9 1.405 (a); 14 CFR 91.407 (a) (1) 14 CF R 91.409 (a )(1) an d (2) ; 14 CF R 91.417(a) an d (b )

Dear Sir o r Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “ Reform Act” ) and 14 CFR Part 11, Anthony D. Mason (Mason Media) , operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ( “ FARs” ) to allow commercial operation 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 required by Section 333.
Commercial operation of an UAS, as described herein, which are equipped with camera(s) and /orsensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gatherin g.

 Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

 The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.
As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation ’ s (the FAA Administrator’ s) responsibilities to “... .establish requirements for the safe operation of such aircraft systems in the national airspace system. ”The name and address of the applicant is:

Anthony D. Mason Mason Media Phone: (615)766-3990 Email: masonmedianet@gmail.com Address: 7529 Ruby Keith Road, White House, TN 37188
Regulation s fro m wh i ch t h e exemptio n is requested: 14 CFR Part 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 91.109 14 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)

Anthony D. Mason (Mason Media) will operate the DJI Phantom 3, with a total weight of 1280g or 2

. 13 lbs. The di agonal size (including propellers) is 590 mm

. Under still air the maximum speed is no more than 16 m/s or 3 5

. 79 mph with a cruising speed of 10m/s or 22.37mph. The DJI Phantom 3 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Phantom 3 has four motors powered by a 6000mAh Li Po 2S battery. There are four propellers in use. The DJI Phantom 3 will be controlled with the Phantom 3 remote controller with
an operating frequency of 2.400GHz

– 2.483 GHz. The live video feed will have an operating frequency of 2.4GHz

– 5.850GHz. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative. Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’ s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 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. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 50mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observe r (VO).

 Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200

feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.

 The UAS pilot will be a designated Pilot in Command (PIC) and hold at least a sports Pilot’ s License along with a Medical Certificateor U. S Drivers license

. If the PIC feels another operator to be qualified with the necessary skills to be PIC & possess a SportsPilot’ s License along with a Medical Certificateor U. S drivers license, that person may be designated PIC provided they have a minimum of 20 hours of flight time with the UAS.

 A briefing will be performed regarding the planned UAS operations prior to each day’ s flight consisting of all the days’ production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (V FR ) only.

 The flights will occur no closer than a 2 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of
a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.

 The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

 The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencieswhen needed

.  If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre-determined location within a designated location and land autonomously.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.
14 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 Aviation 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 airports 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 restrictions and conditions proposed.
The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 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, a pplicat ion of t hese sa m e crite ria demonstrate s t h at t he re is n o cred ibl e t hreat to n ation al secu rity p osed

by t h e UAS, du e to its si ze, speed of operation , lo cat ion of o peration , la ck of exp losive m ate rials o r flammable liqu id fu els, a n d in ability to ca rry a substantial extern al load.

14 C.F.R

. § 45.23 (b). Marking of t he Aircraft Th e regulat ion requires: Whe n marks in clud e o n ly t h e Ro m an ca pital lette r "N " a n d t h e registratio n n umbe r is d isplaye d o n lim ited, restricted o r light-spo rt catego ry a ircraft o r experimental o r provision ally certi ficated a ircraft, th e o perator
must also d isp lay o n t h at a ircraft near each en tran ce to t h e cabin , co ckp it, o r p ilot stat ion, in letters n ot less th an 2 inches no r mo re t h an 6 inches h igh, t h e word s " limited, " "re stricted, " "lig ht-sport, " "experimental," or "provisional, " a s a pplicable. Eve n t hou gh t h e UAS will have n o a irworthiness certi ficate, a n exe mptio n may b e n eede d a s t h e UAS will have n o en tran ce to t h e cabin , co ckp it o r p ilot stat ion o n wh ich th e word “ Experimental ” can b e p laced. Given the size of the UAS, two-inch lettering will be impossible. The word “ Experimental ” will be placed on the fuselage in compliance with §45.29 (f). (based on a request or ruling by the FAA ) Th e eq uivalent level of safety wil l b e p rovide d by h aving th e UAS marked o n its fu se lage a s required by §45.29 (f) where t h e p ilot, o bserve r an d othe rs working wit h t h e UAS will se e t h e id entificat ion of t h e UAS as

“ Experimental. ”

14 C.F.R

. § 61.1 13 (a) and (b) : P rivate Pi lot P rivileg es and Lim itations: Pi lot i n Co mmand. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Anthony D. Mason (Mason Media) may achieve an equivalent level of safety as achieved by current Regulations because the applicant’ s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have at least a Sports Pilot’ s License along with a current Medical card or U.S. drivers license forthe current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the safe operation of the UAS.
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 maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.

14 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. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.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 for 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. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, 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 or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 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 Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. ” The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’ s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which theexemption wil l be gra nted

. Applican t believes t hat a n eq uivalent level of safety ca n b e a chieved by lim iting flights

to 30 minutes o r 25% of b attery p ower — whicheve r happens first. This restriction wou ld b e more than adequate to return t he UAS to its p lanned la nding zone from anywhere in its l imited o perating area.

14 C.F.R

. §91.203 (a) and (b): Carrying C ivil Aircraft Certification and Regi stration The regulation p rovides in p ertinen t part: (a) Except as provided in § 91.715, no p erson may o perate a civil aircraft unless it h as within it t he following: (1) An a ppropriate a nd cu rren t airworthiness certi ficate. .

. . (b) No p erson may o perate a civil aircraft unless t he a irworthiness certificate required by p aragraph (a ) of t his section o r a special fligh t authorization issued u nde r §91.715 is d isplayed at the ca bin o r cockp it entrance so that it is legible to p assengers o r crew. The UAS fu lly loaded we ighs no more than 55 lbs

. and is o perated with ou t an o nboard p ilot. As such , t here i s
no a bility o r place to ca rry certification a nd registration d ocuments o r to d isplay t hem o n the UAS. An eq uivalent level of sa fety wil l be a chieved by keeping these d ocuments a t the gro und co ntrol poin t where the p ilot flyin g the UAS will h ave i mmediate a ccess to t hem, to t he exten t they a re a pplicable to t he UAS.

14 C.F.R

. §91.405 (a); 407 (a) (1); 409 (a) (2); 41 7(a) & (b): Maintenance Inspections. These regulations require t ha t an a ircraft operato r o r owne r “sh all have t hat a ircraft inspected as prescribed in sub part E of t his p art and sha ll between required in spections, exce pt as provided in p aragraph (c) of t his section, h ave d iscrepancies repaired a s p rescribed in p art 43 of t his ch apter..., ” and others sha ll inspect or maintain t he a ircraft in co mpliance with P art 43. Given t hat t hese section a nd P art 43 apply o nly to a ircraft with a n airworthiness ce rtificate, t hese se ctions will n ot apply to t he a pplicant. M aintenance wil l be a ccomplished by t he operato r pursuan t to t he flight manu al and o perating handbook. An eq uivalent level of safety wil l be a chieved because t he UAS is very limited in si ze and wil l carry a sm all payload a nd o perate only in restricted a reas fo r a lim ited period of t ime. If me chanical issues a rise t he UAS can la nd imm ediately a nd wil l be o perating from no higher than 400 feet AG L. The o perato r will en sure t hat t he UAS is in working orde r p rior to in itiating flight, perform required maintenance, a nd keep a log of a ny main tenance p erformed

. Moreover, t he o perato r is t he person mo st fami liar with t he aircraft and b est su ited to mai ntain t he a ircraft in a n a irworthy co ndition to provide the equivalent level of sa fety. An eq uivalent level of sa fety wil l be a chieved b ecause maintenance a nd in spections will b e p erformed in accordance with t he UAS Manufacturer's U se r Manu al. As p rovided i n t he FOM, t he o perator will en sure that t he UAS is in working orde r p rior to in itiating flight a nd p erform required main tenance n eeded.

Additional Information The applicant, Anthony D. Mason (Mason Media) , has been taken a UAS flight training of remote controlled aircraft. Also the primary pilot, Anthony D. Mason (Mason Media) has an in -depth understanding of the capabilities and safety concerns involved in using this technology as an asset to the community. Satisfaction of criteri a 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.
Sincerely, Anthony D. Mason Mason Media