1

March 17 , 2015 Chosen Productions
Attn: Greg Steinmetz

4316 McCahill Rd
Red Bank, TN 37415

352

- 266

- 7180 greg@chosenproductions.org

U.S. Dept. of Transportation, Docket Operations
West Building Ground Floor, Room w12

- 140

12 00 New Jersey Avenue, SE., Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal
Aviation Regulations

De ar Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 11, and the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C.
§ 44701(f), Chosen Productions (“Petitioner”) hereby petitions for exemptions from :

14 C.F.R. Part 21 Subpart H

14 CFR § 45.23
14 CFR § 45.29 14 CFR § 91.203(a) & (b)

14 CFR § 91.9(b)(2)

14 CFR § 61.113 (a) and (b)

14 CFR § 91.11 9
14 CFR § 91.121

14 CFR § 91.151 14 CFR Subpart E § 91.403 14 CFR Subpart E § 91.405 (a)
14 CFR Subpart E § 91.407 14 CFR Subpart E § 91.409 14 CFR Subpart E § 91.417 8900.227 Paragraph 16(e)(1)2



### Petition Summary The proposed exemptions, if granted, would allow Petitioner to operate unmanned aircraft systems (“UAS”) weighing 55 pounds or less for the purpose of aerial still photography, aerial videography and closed

- set f ilming of motion pictures

. Based on the small size of Petitioner’s UAS, the qualifications and experience of Petitioner’s UAS operators, and the restricted, sterile environment within which Petitioner will operate, the requested exemptions fall squarely

wi thin the zone of s afety envisioned by Congress set forth in Section 333. The Petitioners, in the past have chartered full

- sized helicopters for the purpose of video production, which has proven more costly and with a higher safety risk than that of a small UAS . Chosen Productions highest goal is the s afety of the public, property and national airspace. The UAS will be operated in accordance with the FAA policy N 8900.227 Section 14 “Operational Requirements
for UAS”. T he specific guidelines and procedures detailed in the “Operations Manual” and the “Pilots Operating Handbook” proposed by the Petitioner gives the FAA good cause to find that the UAS operations are in the public interest.



### EXEMPT ION REQUESTS AND EQUIVELANT LEVE L OF SAFETY

14 CFR Part 21, S ubpart H: Airworthiness Certificates Petitioner requests an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the following paragraph and attached operations manual

. If an airworthiness certificate exemption is not appropriate for this application, then petitioner requests an experimental certificate be issued
under either or both of the f ollowing provisions:

21. 191 Experimental C ertif icates Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiat e major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes, we would expect that an experimental certificate , if applica ble, would permit o ur commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements outlined in Petitioners Operations Manual.

14 CFR 45.23 Display of marks; gen eral and 45.29 Size of marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word3

"EXPERIMENTAL" in letters at least 2 inc hes high near the entrance to the cabin, cockpit, or pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA.

Petitioner proposes to achieve an equivalent level of safety

, if an experimental certificate is required

, by including the word "EXPERIMENTAL" on a placard on the rear of the aircraft where the PIC, VO and others in the vicinity of the will be able to see the designation. An additional pla card , described in the following section, displayed on the aircrafts ground station will provide the aircraft's registration information at the ground level also

.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required The regulation provides tha t an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircra ft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockp it entrance so that it is legible to passengers or crew."

At a maximum gross weight of 27 pounds, the UA S is too small to carry the required “legible” documentation, is not capable of carrying passengers or crew, and does not have an entrance. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In o rder to identify the aircraft, we propose that the information placard outlined in the 14 CFR 45.23 exemption

section above

, be permanently affixed to the aircraft via placard containing the word
“EXPERIMENTAL” (if applicable) to satisfy the requirement of 14 CFR 45.23

. Petitioner is also prepared to “fold” documentation into a smaller form factor to be displayed in the aircraft if
needed.

14 CFR 91.9 (b)(2), Civil aircraft flight manual, marking, and placard requirements

. This regulation provides that no person may operate an aircraft unless a current, approved flig ht manual is in the aircraft. Petitioner assume s that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry
documentation.
To obtai n an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA S Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 (a) and (b) Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Su bparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry4

passengers or property f or compensation or hire. Our proposed operations require that the PIC
must either :

1. Hold a Private Pilot s Certificate issued by the FAA

2 . Meet the requirements of 8900.227 para 16(c)(2)(c ) "Operations without a pilot certificate"
in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the
FAA Private Pilot written examination."

T here are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply f o r a commercial pilot's license, we propose to generate an equivalent level of safety. Petitioner ’ s PIC currently holds a Private Pilots
Certificate issued by the FAA. Since the aircraft cannot carry passengers or property, we feel
we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to
conduct a business.

14 CFR 91.119 Minimum safe altitudes: General 14 CFR 91.119(c) states that over sparsely populated areas the aircraft cannot be operated closer
than 500 feet to a ny person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement.

Consistent with the relief typically provided to manned operations under FAA Order 8900.1, Volume 3, Cha pter 8, Section 1, Petitioner requests relief from 14 CFR 91.119 in respect to those participating persons, vehicles, and structures directly involved with the filming process. Petitioner’s Operating Manual sets forth safety factors for authorizing and con senting production personnel. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft.

14 CFR 91.121 Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an barometric altimeter setting available within 100 NM of the aircraft.

The UA S will always fly below 400 feet AGL and will not need to maintain cruising altitudes i n order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement

, in feet, above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter onboard the UAS. Instead,
altitude information is generated by GPS equip ment installed onboard the UAS and digitally transmitted to the ground station display. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requeste d relief from 14 C.F.R. § 91.121.

14 CFR 91.151 Fuel requirements for flight in VFR conditions The regulation provides that no person may begin a flight in an airplane under day

- VFR5

conditions unless there is enough fuel to fly to the first point of inten ded landing and to fly after
that for at least 30 minutes.

Petit ioner seeks exemption regarding; t he UA S is battery operated and the maximum d uration of flight with payload from a single battery charge is 9 minutes 30 seconds minutes with a 30 %

reserve. S ince the aircra ft will never fly more than 3/4 NM from the point of intended landing, a full battery charge at launch (procedures outlined in the Pilots Operating Handbook) will ensure
that we meet the reserve energy requirement of this paragraph.

14 CF R Subpart E (91.403, 91.405 (a) , 91.407, 91.409, 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the VO perform maintenance and inspec tion of the aircraft and "be authorized to approve the aircraft for return to service." Petitioners VO has six years’ experience in maintenance and service with this type of aircraft. As provi ded in the Pre

- Flight
Checklis t, both the PIC and VO will ensure that the aircraft is in an air worthy condition prior to every flight. This is also how the petitioner will comply with 14 C.F.R. 91.7(a) Civil Aircraft
Airworthiness. The Pilots Operating Handbook outlines documentation required for the maintenance, service and inspecting the UAS. The VO will document work performed in
accordance with 91.417 . We feel that due to the size, construction, and sim plicity of the aircraft, petitioner can ensure an equivalent level of safety.

8900.227 Paragraph 16(e)(1) Observer Medical This policy provides that both the PIC and VO must have a valid FAA second

- class medical
certificate issued under P art 67 in order to perform as a pilot or observer.

Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA S will return autonomously to the site of launching and land without crew intervention. Petitioner currently complies with the minimum medical requirements for the PIC as described in Paragraph 16(c)(4). Petitioner requests exemption from 8900.227 Paragraph 16(e)(1) requiring the VO to
meet the same medic al requirements as commercial pilot carrying passengers in a l arge airc raft Petitioner requests the minimum requirements for VO be vision corrected to 20/20. The 20/20

vision r equirement will ensure that both the PIC and VO can see and av oid air traffic

.