August 19 , 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

SUBJECT: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations.

Dear S ir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, TFF Production, Inc. (TFF), the owner and operator of the DJI Inspire 1 2 a small Unmanned Aircraft System (sUAS) seeks an exemption from Federal A viation Regulations (FARs) identified below, to allow commercial operations of small unmanned aircraft ( i.e., “small unm anned aircraft” or “ UA”) because we desire to assist in the safe and legal integrations of UA’s into the NAS.

We believe that TFF is e ligible for a Summary Grant for the proposed closed set filming, data

collection 1 , and demonstrations. We have carefully reviewed approved exemptions granted under section 333 by the FAA and believe our request for an exemption to be materially similar to exemptions

below and in the public’s best interest

.

Operation Exemption Numbers:

11062 to Astraeus Aerial (see Docket No. FAA−2014−0352)

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507)

11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382)

11 213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642)

11241A to Phoenix Air Unmanned, LLC (see Docket No. FAA−2014−0692)

11970 to Camera Copters, Inc. (see Docket No. FAA

- 2015

- 1100)

DJI Inspire 1 (UA) Exemption Numbers:

11279 to CineDrones, LLC (see Doc ket No. FAA

- 2014

- 0798)

11280 to Shotwell Media, LLC (see Docket No. FAA

- 2014

- 0885)

11288 to Toledo Aerial Media, LLC (see Docket No. FAA

- 2014

- 0979)

11303 to TradeCraft, LLC (see Docket No. FAA

- 2014

- 1019)

11313 to DeGrazia Music, LLC (see Docket No. FAA

- 201 4

- 1085)

11314 to Ryan K. Koffman (see Docket No. FAA

- 2014

- 0958)

The proposed S ummary Grant exemption , if granted, would permit TFF

, which uses the DJI Inspire 1 2

, to conduct closed set film / television production, aerial data collection 1 , and flight demons trations

. TFF ’sPage 2

operation under the exemption will be subject to strict operating requirements and conditions to ensure a greater level of safety to currently authorized operations using manned and unmanned aircraft under
conditions as may be modified by the FAA as required by Section 333.

_______________________ 1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precisi on surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

2 The FAA has previously authorized use of the DJI Inspire for commercial purposes on multiple

occas ions ( e.g., Exemption Nos. 11447, 11458, 11461, and 11463).

For ease of review

, TFF has organized the Exemption request using a table of contents that can be found on page 3.Page 3 TABLE OF CONTENTS

I. UA S

........................................................................... .............................. ..... ......4

II. P e ti t i on er ' s D e s cr iption.........................................................

... ........................................... .5

III. P e tition er’ s C ont ac t I n f o r m a tion.............................................

................................. ...5

IV. P r opos e d Op e r a tions.........................................................

... ................................ .5

- 7

V. C re w Qu a li f

i c a tion s a nd Duti e s.............................................

.................................. . . 7

- 8

VI. P ubli c / C ommu n i t y I nt er e st...................................................

................................. . ...8

VII. F C C I

n f o r m a tion............................................................

.............................. ... .. ...9

VIII. Regulations Fr o m W hi c h E x e mp t i o n is R e qu e st ed............

........ .............................. .......... . .. . .9

- 13

IX. P r iv a c y

........................................................................... ................................. ..14

X. C on c lusion........................................................................

. . ........... ........................... 14

- 15

SUPPORTING MATERIAL

APPENDIX A Inspire 1 Maintenance Manual

............................................................... ....................16

- 1 8 Inspire 1 Safety Guidelines

............................................................ .......................... 19

- 23 Inspire Intelligent Flight Battery Safety Guidelines...................................................... ....24

- 26

SUBMITTED CONFIDENTIALLY TO 333exemption@faa.gov

Petitioner submi ts its Manuals, as a Confidential documents under 14 CFR § 11.35(b), as the Manuals contain confidential commercial and proprietary information that the Petitioner has not and will not share with others. The Manuals contain operating conditions and procedu res that are not available to the public and are protected from release under the Freedom of information Act.

1. Inspire 1 Quick Start Guide

2. Inspire 1 User Manual

3. TFF Motion Picture & Television Operations Manual (MPTOM)

4. TFF Flight Operations Procedures Man ual (FOPM)Page 4

I. UAS

Tyler Furlan, TFF Production , Inc

. ( TFF ) is petitioning for and exemption to operate a DJI Inspire 1 quadcopter. This quadcopter has an advanced flight controller that constantly updates and records using a high

- strength, intellig ent GLONASS + GPS System. This dual position system allows for greater safety and higher precision. In addition the Inspire 1 has advanced Inertial Measurement Unit (IMU)

that has a 6

- axis gyroscope and accelerometer to monitor any change in the sUAS’s a ttitude and

movement. These systems allow the Inspire 1 to operate safely and compensate and adjust immediately to hold its precise position at all times. In addition the DJI Inspire 1 can accommodate two operators a Pilot in Command (PIC) and a payload operator. This also enhances safety by allowing the PIC to operate the sUAS and concentrate only on flying the sUAS while the payload operator controls the camera. The sUAS will be equipped with cameras, camera stabilizing gimbals

and on

‐ screen displays (OSD) providing the PIC with altitude, airspeed, battery life and direction. The GLONASS + GPS system will be used to limit the altitude above the ground and limit the distance it

flies from the PIC. The Inspire 1 has GPS guided failsafe functions that command the autopilot to fly the sUAS back to the original launch site autonomously. This failsafe will be triggered if the system loses the minimum number of GLONASS + GPS signals or if the signal from the transmitter is lost or

if the PI C decides to abort the flight.

UA : DJI Inspire 1

Manufacturer : DJI Innovation

Model : Inspire 1 T600 Weight : 2935 g / 6.47 Pounds Passenger Capacity : 0 (unmanned) Size (dimensions) : 438x451x301 mm (17.24x17.76x11.85 inches) Max Speed : 22 mps (72.18 fps / 49.21 mph) Max Flight Time : 18

- 25 mins Max Ceiling (software limited) : 400 ft. AGL Operations : Line of Sight

Controller : The Inspire’s omni

- directional antenna has a range of 2 km Radio Frequency: Operates in the 2.420

– 2.483 GHz frequency from Con troller to Aircraft

Operates in the 5.725

– 5.850 GHz frequency from Controller to ControllerPage 5

II. Petitioners Description

Tyler Furlan, TFF Production, Inc

. (FTT) is petitioning for an exemption and is a company th at provides unman ned aerial supp ort to closed set film /television producti on, aerial data collection 1 , and

demonstrations

.

TFF has over 200 hours of flight training and experience with the DJI Inspire 1 and several PIC

candidates who hold at a minimum a Recreational Pil ots License

. TFF has over 1 0 years of video production and closed set film/television experience and understand s th e requirements to safely integrate UA on movie sets to increase the safety of all participants

.

TFF plans on providing a wide range of ser vices as the UAs market expands.

I I I. Petitioner’s Contact Information :

TFF Production, Inc.

Attn: Tyler Furlan

4329 N Drake Ave.

Chicago, IL 60618

Phone: (302 ) 918

- 5010

Email: 333petition@gmail.com

IV. Pr oposed Operations

 Before an operation of a sUAS within 5NM of an airport with a control tower, the control tower will be called to gain permission to operate the sUAS. The PIC will give the position, altitude, and the times the sUAS will be operated. Th e sUAS will not be operated at an altitude of over

150 ft. AGL unless otherwise cleared

.

 Before an operation of a sUAS within 5NM of a non

‐ tower controlled airport, airport operators will be notified and the PIC will give the right of way to avoid flyi ng in the proximity of

full

‐ scale aircraft. At no time will the sUAS be operated within the final approach course and the takeoff course of any runway. The sUAS will not be operated at an altitude of over 200 ft. AGL unless otherwise approved by the air operators

.

 Weather minimums will be 3 miles visibility and a 1000 ft. ceiling.

 TFF will only operate its sUAS in line of sight of a PIC and/or VO and will operate at sites that are a ‘sufficient distance’ from populated areas. Such operations will ins ure that the sUAS will

not create a hazard to users of the NAS or the public.Page 6

 All flight operations will be conducted at least 500 feet from all non

- participating person, vessels, vehicles, and structures unless

(a) Barriers or structures are present that su fficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protect ion and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating

persons.

(b) The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered non

- participating persons unde r this exemption

 All of our operations will be less than 200 ft. AGL if we are operating within 30 miles reach of primary class B airports with in the United States.

 Maximum flight time for each operational flight will be less than 30 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute

limit.

 The sUAS will utilize ‘GPS fences’ so that it will not be operated at an altitude of no more than 400 ft. AGL, and not more than 200 ft. above an elevated pl atform from which data collection is planned.

 Minimum crew for each op eration will consist of the PIC and VO

.

 The sUAS operated by the petitioner weighs less than 55 lbs., including the payload.

 The sUAS will oper ate at speeds of no more than 40 knot s, can hover, and can simultaneously move vertically and horizontally.

 All operations must utilize a VO

. The VO and the PIC must be able to communicate by voice, 2 way radio, or cellular communications at all times during flight operations.

 Flight ope rations will be restricted to flights over water, public or private property with the permission of the property owner(s).

 All required permits will be obtained from state and local government prior to operation.

 sUAS will not be operated over densely populated areas unless proper authorization and barriers are set in place

.Page 7

 sUAS will not be operating over any open

‐ air assembly of people.

 sUAS will not be operating over heavily trafficked roads.

 All new to service sUAS both custom and pre

‐ manufact ured will have a minimum of 25 logged flight hours and deemed safe by the PIC prior to commercial operations.

 Flight operations will also adhere to the specifications stated in th e DJI Safety Guidelines (downloadable at this link: http://www.dji.com/product/inspire

- 1/download )

 The sUAS will be maintained in accordance with the maintenance specified in the User Manual and the Maintenance Manual (downloadable at this link http://www.dji.com/product/inspire

1/download )

V. Crew Qualifications and Duties

The PIC will maintain at least a Sport Pilot License and a current Class III medical certificate, plus at least 10 hrs. Of flight tim e on the DJI Inspire 1 and at least 2 hrs. o f flight time with 3 takeoffs and landings within 30 days of sUAS operations. The PIC will have at least 100 hrs. Total flight time and at least 20 hrs. Flying RC aircraft of that 10 hrs. On the DJI Inspire 1.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation, in flight operation, and post flight requirements. Procedur es including but not

limited to.

PIC Duties:

 Utilize the FAA B4UFLY App to verify legal and safe opera tion in the planned flight area

 Risk Assessment

 Pre

- Flight Site Inspection

 Pre

‐ Flight Check List

 Ensure Safe Flight Operations

 Safety Briefing

The Visual Observer (VO) must have the visual acuity to observe the sUAS and be able to communicate clearly with the PIC verbally, 2 way radios, or by cellular communications at all t imes. The VO is not

allow ed to use any visual assist ques other than corrective lenses as prescribe on their valid state driver’s

license or third class medical certificate. Duties for the VO are as follows but not limited to.

VO Duties :

 Creating a pre

‐ flight weather report utilizing a personal weather station to collect data on the wind speed, ambient temperature, and barometric pressure.

 Notifying the PIC of any impending obstacles in the flight path of the sUAS

 Notifying the PIC of any de viations in the p lanned flight path of the sUAS

 Notifying the PIC if unauthorized persons enter the area of the planned flightPage 8

The DJI Inspire one has a second controller which allows the operator of the UA to completely focus on flight operations. The camera operator (CO) will be in close proximity to the UA operator and be able to communicate through 2 way radios, verbally, or with cellular communications at all times. The camera operator’s duties are as follows but not limited to.

Camera Operator (CO) Duties:

 Pre

- Flight Camera Inspection

 Pre

- Flight Shot List Assessment

 Pre

- Flight Check List

V I . Public Interest

TFF’s qualified PIC’s and competent pilots will be operating according to limitations necessary to ensure the safety of people, ves sels, vehicles, or structures . Production personnel are exposed to manned aircraft which is a high risk to their safety due to manned aircraft weight, size , speed, and payload capacity. (See Appendix A)

The UA is also able to respond to a lost

- link eve nt with a pre

- coordinated, predictable, automated flight maneuver. These safety features have no adverse effect to participating and nonparticipating individuals compared to a manned aircraft that holds a standard airworthiness certificate performing a sim ilar operation and ensure that these operations will not adversely impact the safety of the public and thus being in the public’s best interest.

The sUAS operated by TFF are powered by batteries, are small, quieter, lighter, and more maneuverable

than l arger aircraft running on combustible fuel, thus leaving a very small environmental impact. Our sUAS operate at lower altitudes and have no people on board, thereby reducing the risk levels associated with traditional aircraft and larger UAS. These fact ors increase the safety of operation and reduce the

risk of death or serious bodily injury by our aircraft. Also, with a limited payload and short flight duration, there is little risk to national security.

Low altitude data collection methods are mo re efficient than ground based observations or manned aircraft imagery for displaying detailed characteristics of ground based objects. Because of the above mentioned characteristics of our sUAS, TFF intends to sell their data at a significantly reduced c ost allowing for more clients to be able to afford this type of data. The benefits of unmanned sUAS data collection methods and continued development and improvement of small sensors and increased flight times will benefit future clients greatly.

TFF co ntinues to witness UA operations take place illegally because of the growing demand. We believe that it’s in the public’s best interest and our own to receive an exemption allowing us to work towards building a community of legal and responsible operators in the Midwest.Page 9

V I I. FCC Information

The transmitter used for controlling the UA complies with part 15 of the FCC rules. Operation is subject to the following two conditions:

(1) This device may not cause harmful interference (2) This device mus t accept any interference received, including interference that may cause undesired operation.

The Spektrum radio transmitter used for controlling the UA is wireless technology which has been tested and found to be compliant with the applicable regulation s governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance

When operating our transmitter, the PIC will maintain a separation distance of at least 5 cm between his body (excluding fingers, hands, wrists, ank les and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.

VI I I. Regulations from which exemption is requested

 14 C.F.R. 11.87 Publication and Comment P rocedure

 14 C.F.R. Part 21 Airworthi ness Certification

 14 C.F.R. 45.23 (b) Marking of the A ircraft

 14 C.F.R. 61.113(a) and (b) Private Pilot Privileges and L imitations

 14 C.F.R. 91.109 Flight I nstructions

 14 C.F.R. 91.119 Min imum Safe A ltitudes

 14 C.F.R. 91.1 21 Altimeter S ettings

 14 C.F.R. 91.151(a) Fuel Requirements for Flights in VFR C onditions

 14 C.F.R. 91.203 (a) & (b) Civil Aircraft: Certifications R equired

 14 C.F.R. 91.215 ATC T ransponder and A ltitude R epo rting E quipment U se

 14 C.F.R. (91.401

- 91.417) Maintenance , Preventive Maintenance, AlterationsPage 10

14 C.F.R. 11.87 : Publication and Comment P rocedure

TFF requests that the publication and comment procedure be waived to help move towards a Summary

Grant in accordance with 14 C.F.R 11.87 which states the “...circumstances in which FAA may decide not to publish a summary of my petition for exemption?”

a) TFF does not set any precedent and agrees to the SAME limitations on operations and on their

DJI In spires as exemptions 11279, 11280, and 11288. b) In pursuit of a Summary Grant we believe the publication and comment procedures would delay the process. c) We also feel it would affect our ability to serve in the public’s best interest because there are

sever al operations currently being done illegally as many clients are looking for companies with exemptions. However, since there are so few companies in Chicago they are choosing to hire companies who are operating illegally. If we are able to obtain a summa ry exemption we believe it would be in the public safety, the FAA, potential clients, and our own best interest. d) We also feel that we’ve filed our information in a timely manner and could help free up limited resources to focus on other more complicated tasks.

14 C.F.R. Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, I request an

expe rimental certificate be issued for the DJI Inspire 1 under either or both of the following provisions:

21.191 Experimental certificates . Experimental certificates are issued for the following purposes:

(a) Research and development Testing new aircraft desi gn 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 airwo rthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulation s. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, I would expect that an experimental certificate would permit my commercial purpose as well. The aircraft wil l not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, I propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then I request an exemption of 14 CFR Part 21, Subpart H, and the requirement for airw orthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.Page 11

14 CFR 45.23 Marking of the Aircraft

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications.

M y UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small

aircraft with dimensions smaller that minimal letter ing requirement.

Each TFF UA will carry its appropriate “N” number issued by the FAA, in such size as can reasonably fit upon the sides of the aircraft in at least one location. If an N number is not obtained from the FAA, I

will mark TFFs related Traini ng UAS in the largest possible lettering by placing the word “EXPERIMENTAL” on its airframe as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UA will see the markings. The FAA has previously issued exempt ions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700

.

Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Si nce the aircraft will operate within .5 miles of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. The FAA has previously ruled in its exemption that a Private Pilot’s Certificate is required for flight of the UAS for commercial purposes. TFF proposes that the Pilo t in Command will carry a minimum of a

Recreational Pilots Certificate with a third class medical or valid state driver’s license. TFF will assure that all PIC’s proposed to oversee the operations of the UAS aircraft also have at minimum of 25 hours fligh t time on the UAS being used for the operation.

TFF’s UAS’s do not carry any pilots or passengers. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. T hus, allowing any TFF qualified operator or PIC with a minimum of a Recreational Pilot License to oversee operations of the proposed UAS’s to meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.109 Flight Instru ctions

The regulation states that "No person may operate a civil aircraft that is being used for flight Instruction unless that aircraft has fully functioning dual controls." Training will be conducted by TFF. We have the ability to provide dual control s utilizing two C1 transmitters with a wired link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated

as a slave. Please refer to the attached DJI Inspire 1 User Manual. The PIC instructo r, utilizing the master transmitter, will be at all times be able assume control of the sUASPage 12

14 C.F.R. 91.119: Minimum Safe Altitudes

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. TFF UAS will never operate at an altitude greater than

400 AGL.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or str ucture. Since the typical mission of the sUAS would be closed set motion picture filming, aerial data collections, and demonstrations of persons, vessels, vehicles, or structures it would be necessary to operate closer than 500 feet to the items listed. Op erations will only be flown over property or person(s) where permission has been obtained and careful pre

- planning has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazar d to persons or property on the surface. 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, which should be considered in granting the exemption.

14 CFR 91.1 21 Altimeter Settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board computer to the display screen held by the PIC, providing a constantly updated A GL readout.

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

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to f ly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12

- 45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We reque st an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 2 0% battery reserve after that.

14 CFR 91.203(a) & (b) Civil A ircraft: Certifications R equired

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. TFF’s largest UA, the DJI Inspire 1, at a maximum gross weight of 7 pounds , thePage 13

sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircr aft by the FAA will be located with the crew at the ground control station and available for inspection upon request

14 C.F.R. 91.215 ATC Transponder and Altitude Reporting Equipment and Use

This regulation states all aircraft operating within 30 Naut ical Miles of class A, B and C airspace must be equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our

UASs we cann ot carry a traditional transponder. All of our operations will be less than 250 ft. AGL if we are operating within the 30NM reach of a mode c vail.

14 CFR Subpart E ( 91.401

- 91.417)

- Maintenance, P reventive M aintenance, A lterations

The regulation provi des 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 authorize d under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an

air worthy condition prior to every flight.

The UAS Inspection program will be every 50 hr. or 200 flights as suggested at the top of the attached Inspire 1 Maintenance Manual (Appendix A) . Other required tests and inspections (transponder, E.L.T., etc.) will be p erformed as per Part 91 when necessary. Each aircraft will have a flight log containing upcoming scheduled maintenance and inspections and the dates or times they must be performed. A section for discrepancies is also found in the flight log. The pilot in command will assure the aircraft to be flown is in airworthy condition and all required inspections and maintenance has been completed before each flight

The DJI Inspire 1 is nearly maintenance free, it performs automatic pre flight checks and the failure of any check will prevent take

- off. Checks which cannot be done by the system will be performed by a qualified person prior to each flight and at predefined intervals as part of the Maintenance Schedule in the User Manual (see Exhibit 1).

Preflight chec klist includes: 1. Visual inspection of the airframe 2. Visual inspections of rotor integrity 3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached User Guide (System Maintenance section), the operator of TFF will ensure thatPage 14

the sUAS i s in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft

and is best suited to maintain the aircraft in an airwort hy condition and to ensure an equivalent level of safety.

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equiva lent level of safety.

IX. Privacy

There is little risk that the proposed use of the DJI Inspire 1 by TFF will result in any privacy violations because all flights will occur over private or controlled access property with the property owner’s prior

conse nt and knowledge. When a UA is being flown, the onboard cameras will be focused on the ground beneath it, and thus turned so as to be facing away from any occupied structures that may be in the area to minimize inadvertent video or still images of uninvolv ed persons. TFF will also make sure to be aware of concealing itself from heavily trafficked nearby roads by using the landscape to avoid causing

driver distractions.

All data collected that is used for public view, all images containing uninvolved person whom have not signed a release will be blurred or blacked

- out. No attempt will be made to identify any individuals filmed during the flights except in cases where the y are trespassing upon or damaging customer property, or interfering with the petitioner’s or it’s customer’s operations.

X. Conclusion

By granting Tyler Furlan, owner, TFF Productions, Inc. the requested summary grant exemptions, the FAA will help e nsure the development of safe and successful commercial UAS operations and will advance the public knowledge and perception for such operations of sUAS. TFF personnel have a long history with Remote Controlled. We are committed to promoting the sUAS rese arch efforts of policymakers by sharing data from our commercial sUAS operations and serving as a resource for future sUAS research opportunities.

TFF sUAS used, under authorization by the US DOT

‐ FAA, are small, light

‐ weight (under 55 lbs.) devices that will be operated only in daylight within the line of sight of the PIC and VO, they will operate under 400 ft. AGL and outside 5NM from any airport or location with aviation activities, unless

the a ir traffic control (ATC) authorities have been properly notified and that the ATC authorities have authorized each flight within the specified radius of their facilities.

TFF seeks an exemption pursuant to 14 C.F.R. and Section 333 of the FAA Modernizati on and Reform Act of 2012 (FMRA), which will permit the safe operation of our sUAS commercially, without an

Airworthiness Certificate. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FMRA of 2012, while also advancing the interests of the public, byPage 15

allowing TFF to safely, efficiently, and economically operate our sUAS commercially within the

NAS. In accordance with the FAA Regulations and the FMRA of 2012, Section 333, TFF respectfully requests that th e Administrator grant this petition for a summary grant exemption from the requirements of 14 C.F.R Sections.

If additional information is required, or if you have any questions regarding this petition for a
summary grant Exemption, please don’t hesitate to contact me at (302 ) 918

- 5010 or 333petition@gmail.com

Kind Regards,

Tyler FurlanPage 16

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