# FA **A -** **2015 -** **0150**

Andy Hawley JTV 152 W. Michigan Ave. Jackson, MI 49201 517

- 787

- 8817

– Office 517

- 783

- 5060

– FAX ahawley@jtv.tv 

## Petition for Exemption 14 **CFR § 11.81**
**– DRONE EXEMPTION**  **FA A** **- 2015**  **- 0150**  **RE: SECTION 333**  My name is Andy Hawley, Director at JTV in Jackson, Michigan . We operate a local TV channel and full service Media Company. Over the past year we have seen many UAS’s enter the marketplace. Our specific commercial use is aerial shots for video pr oduction, corporate video and golf courses. There is a market for this type of work and we would like to proceed under the legal guidelines of the FAA in this section. We intend to use a DJI Phantom II drone in our operations. The design and operationa l requirements are included in this petition as an attachment (operations manual). 1. Safety Operations. At all times, our operator will observe all safety requirements before, during and after every flight. We will minimize risk to the UAS in every wa y. We will ensure the safety of any persons on the ground in the vicinity of the drone operation. Our operation of the drone will be in strict accordance of our safety procedures and the operator will be required to conduct a pre

- flight safety checklist. 2. Procedures The rules we have implemented include: No operation above 200 feet No operation within 6 miles of any airport or flight path Operations will be during daylight hours Drone must be operated so the drone is within sight range of the ope rator at all times Drone will not be operated anywhere near the public, including public events, sporting activities, populated public places, events, parades, etc.No person, other than the drone operator and his or her assistant may be in the

vicinity of the drone operation The drone may not be operated by anyone other than a trained operator An assistant will be required in order to operate the drone Every operation will require a trained operator and an assistant The assistant will be trained Th e assistant will have safety as their primary responsibility and will warn the drone operator if any persons enter the immediate area of the operation The drone will be completely inspected before and after each use Drone operators will be completely tra ined and tested before operating the drone Drone operators will be required to perform drone operations in a testing scenario before being permitted to operate the drone Drone operator will be required to read the drone operation manual completely before operating drone
3. Frequency The drone will be operated remotely, using the manufacturer’s supplied transmitter and receiver. They operate on a frequency of 

### 5.728 to 5.85 GHz. The working frequency is 2.4ghz wi

- fi for mobile device link. The transm itter and receiver devices comply with all FCC regulations and rules The weight of the drone is 2.9 lbs. The drone has a built in video and still camera provided by manufacturer and housed within the drone.

4. Qualifications of PIC operators PIC operat ors will undergo a vigorous training period which will include classroom and field instruction. All PIC operators will be required to serve as an observer on a minimum of 15 flights before assuming PIC command. All PIC operators will be required to perfo rm a safety checklist before each flight. An observer/assistant will be required on all flights. Observers will be required to undergo the same training as a PIC operator, with the exception of actual drone operation 5. Basic first aid training will be required of all PIC operators and observors 6. Intended use

– JTV will use the drone to create videos and stills to be used in a variety of applications: Golf course layout videos, farm observation/recording videos, segments for television commercials. No persons will be allowed present during flight in the vicinity of the flight. We will provide the highest level of safety at a minimum equivalent to the rule we seek exemption. At no time will our operation adversely affect safety or property. 7. Th e maximum operating speed will be 20 feet/second. The maximum altitude will be 190 feet. The area of intended operation will be completely scrutinized immediately before flight to ensure there are no persons in the vicinity and nohazards to operation.

8. The area of intended operation is primarily flatland, in non

- populated areas. The drone will not be operated over water or over any street, highway or railway. 9. Airport proximity: We will not operate the drone within 6 miles of any airport or in a ccordance with statutory mandate under section 333. 10. Line of Sight: The drone will be operated at all times and without exception in line of sight of the operator. We will comply with this mandate by thorough training of operators and observers. Op erators and Observers will be required to cease flight should the drone not be visible at any time. The drone will only be operated on clear days and in broad daylight. 11. The drone will undergo a pre

- flight safety check, with all systems being tested before flight. The drone pre

- flight safety check will be followed by a visual observation test where the drone will be raised to 7 to 10 feet for final testing. The operator will perform the pre

- flight safety check before each operation. The testing wi ll ensure that the entire flight can be conducted safely. 12. We don’t intend to use the drone outside of any rules, regulations or guidelines We respect the FAA Guidelines and would never use UAS near crowds, public events, h ighw ays, airports or above the heights currently prohibited. I humbly request the FAA grant us exemption for use of commercial UAS under guidelines and regulations currently listed. I also support the FAA’s proposal to eliminate the requirement for a pilot’s license to be obtained for commercial use. Thank you for your swift response. Cordially,

Andy Hawley Director JTV , Inc. 152 West Michigan Avenue Jackson, MI 49201 517

- 787

- 8817 ahawley@jtv.tv www.jtv.tv