### Videophotog Productions (Videophotog.com)

256 Tropic BLVD East Largo, FL 33770 dan@videophotog.com 727 492 3223 Dan Foard i Phone cameron@videophotog.com 727 600 5 299 Cameron Foard i Phone

Docket Operations, M
- 30 U.S. Department of Transportation Room W12
- 140, West Building Ground Floor 1200 New Jersey Avenue, SE. Washington, DC 20590
- 0001 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of th e Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, **Videophotog Productions** (Operator) seeks an exemption from Federal Aviation Regulations (FARs) to allow commercial operations of their UASs (Unmanned Aerial Systems) for the purpose of conducting aerial photography, video, and survey for various industries Broadcast TV & News
. Regarding the Unmanned Aircraft Systems The requested exemption wo uld support The “Blanket COA” for commercial operations d escribed on the FAA Website : The Federal Aviation Administration has established an interim policy to speed up airspace authorizations for certain commercial unmanned aircraft (UAS) operators who obtain Section 333 exemptions. The new policy helps bridge the gap between the past process, which evaluated every UAS operation individually, and future operations after we publish a final version of the proposed small UAS rule. Under the new policy, the FAA will grant a Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operat e within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports:
• 5 nautical miles (NM) from an airport having an operational control tower; or
• 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or
• 2 NM from an airport without a published instrument flight procedure or an operational tower; or
• 2 NM from a heliport with a published instrument flight procedure The “blanket” 200

- foot COA allows flights anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA prohibits UAS operations. Previously, an operator had to apply for and receive a COA for a particular block of airspace, a process that can take 60 days. The agency expects the new policy will allow companies and individuals who want to use UAS within these limitations to start flying much more quickly than before. Section 333 exemption holders will automatically receive a “blanket” 200 fo ot COA. For new exemption holders, the FAA will issue a COA at the time the exemption is approved. Anyone who wants to fly outside the blanket parameters must obtain a separate COA specific to the airspace required for that operation
.Docket Operatio ns April 11, 2015 Page 2

1. The Inspire 1 is a Quadcopter UAS capable of capturing 4K video and transmitting an HD video signal to a ground station. Equipped with retractable landing gear, it can capture an unobstructed 360 degree view from its camera. Th e built
- in camera has an integrated gimbal to maximize stability and weight efficiency while minimizing space. When no GPS signal is available, Vision Positioning technology provides hovering precision. 2. Reference Inspire 1 Maintenance Manual v1.0 3. Re ference Inspire 1 User Manual (EN) v1.0 [FCC Compliance
– Appendix Pg 62] Regarding the Unmanned Aircraft PIC 4. Operator proposes to operate its UASs with a pilot holding, at a minimum, a private pilot certificate.

 T h e U A S P I C w i l l b e t ra i n e d i n a d va ・ ・ nce for the safe operation of the UAS to be operated. This will include operation of the UAS both in normal and emergency modes of operation, and will include familiarization with the user manual published by the UAS manufacturer. Training will also includ e types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace.

 T h e P I C m u st h a ve a c c u m u l a te d a m i n i m u m o f 1 0 0 fl i g h t cyc l e s a n d 2 5 h o u r s o f tota l ・ time as a UAS pilot and at least 10 hours logged as a UAS’s pilot with a similar UAS type.

  A l l o p e ra t i o n s m u st u t i l i z e V i s u a l O b s e rve r s (VO s )
. V O s w h o a re n ot p i l ot s w i l l a tte n d ・ ・ ground training to understand the roles of an observer, communication procedures, and proper visual scan techniques, operation s at non - towered airports, and appropriate sections of the Aeronautical Information Manual. 5. The PIC must possess at least a third
- class airman medical certificate for all of petitioner’s flight operations. Regarding the Operation of the Unmanned Aircraft 6. Operator proposes Civil Commercial operation of an UAS to operate in the following manner:

o  ・ Ae r i a l p h oto g ra p h y a n d / o r v i d e o f o r p u b l i c a n d / o r p r i va te u s e i n c l u d i n g re a l ・ estate, architecture, land surveying, engineering and other related professional activities. o  Ae r i a l v i d e o a n d / o r p h ot o g ra p h y f o r p u b l i c a n d / o r p r i va te u s e i n c l u d i n g ・ ・ televisio n, public events, cinematography and news gathering. o  Ae r i a l i n s p e ct i o n / p h oto g ra p h y o f re s i d e n t i a l / c o m m e rc i a l st r u ct u re s u n d e r ・ ・ contract with the owners or local government authority.Docket Operations April 11, 2015 Page 3

  Ae r i a l i n s p e ct i o n / p h oto g ・ ・ raphy of residential/co mmercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.
  Ae r i a l v i d e o/ p h oto g ra p h y o r p ro v i d i n g l i ve v i d e o f e e d ( s o a s l o n g a s a l l ot h e r ・ ・ parameters are met contained herei n) 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.
  T h e a b i l i ty to o f f e r t ra i n i n g to p e r s o n s i n d i v i d u a l l y o r b e l o n g i n g t o b o ・ ・ th 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 prope rty.

 Fo r a d d i t i o n a l o p e ra to r a d h e re n c e : ・ o Reference
– Inspire1SafetyGuidelinesv1.0 7. The UAS may not be flown at an indicated airspeed exceeding 50 knots The UAS must be operated at an altitude of no more than 2 00 feet above ground level (AGL). The UA m ay 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 PIC. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.

  A l l o p e ra t i o n s m u s ・ ・ t be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
  A b r i e fi n g w i l l b e p e rf o r m e d re g a rd i n g t h e p l a n n e d U AS o p e ra t i o n s p r i o r t o e a c h d a y ’s ・ ・ flight consisting of all the days’ p roduction activities.
  F l i g h t s w i l l b e te r m i n a te d a t 2 0 % b a tte ry p o w e r . ・ ・ 8. As described fully above, the requested exemption would permit the operation of an UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predeterm ined 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.”Given the small size of the UAS and the controlled environment provided, the proposed

operations will adhere to t he Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the Docket Operations April 11, 2015 Page 4 l evel 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. 9. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA - publis hed aeronautical chart unless a letter of agreement with the airport’s management is obtained, and the operation is conducted in accordance with a Notice to Airmen (NOTAM), as required by the operator’s COA. 10. The UAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting i s not permitted during flight operations. 11. Reference
– Inspire 1 Safety Guidelines v1.0 12. Operator’s Point of Contact
– Daniel Foard 256 Tropic BLVD E LARGO, FL 33770 Cell: 727492 3223 Alternate Contact PH Cameron Foard 7274923223 Exemption Reque sts and Equivalent Level of Safety 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 (a)(1) Based on the limited size, weight, operating conditions, design safety features, and the imposed conditions and limitations, Operator has demonstrated that its operations would not adversely affect safety compared to similar operations conducted with aircr aft that have been issued an airworthiness certificate under 14 CFR part 21, Subpart H. Therefore, as the FAA found for Astraeus Aerial (http://www.astraeusaerial.com) , Exemption 11062, the requested relief from 14 CFR Part 21, and any associated noise certification and testing requirements of part 36, is not necessary. 14 CFR § 45.23 (b)
– Display of marks Since Operator’s UAS has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed, two inch lettering will be impossibl e. Official marking systems for small UAS have not yet been established for operations inside the NAS.Docket Operations April 11, 2015 Page 5

Operator is prepared to mark the UAS with the name of the organization and location nor origin and fulfill any other request by the FAA to this topic in accordance with 45.29 (f) where the pilot, observer, and others working with the sUAS will see the iden tification of the sUAS. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. 14 CFR § 61.113 (a) & (b)
- Private pilot privileges and limitations This regulation provides: (a) This regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. (b) This 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 carry passengers or property for compensation or hire. All the requirements of a private pilot certificate will prepare the UAS operator for the environment t hat they will be operating in. *Please reference Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating a UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. 14 CFR § 91.7 (a) & (b)
- Civil aircraft airworthiness This regulation provides: (a) No person may operate a civil aircraft unless it is in an airworthy condition. (b) The pilot in command of a civil aircraft is re sponsible for determining whether that aircraft is in condition for safe flight. The pilot in command shal l discontinue the flight when non
- airworthy mechanical, electrical, or structural conditions occur. While the operator’s UAS will not require an airw orthiness certificate, operator is required to ensure that its aircraft is in an airworthy condition
– based on compliance with the operating documents prior to every flight. As previously determined with Astraeus Aerial, Exemption 11062, relevant material s may be kept in a location accessible to the PIC in compliance with the regulations. 14 CFR § 91.9 (b)(2)
- Civil Aircraft Flight Manual, marking, and placard requirementsDocket Operations April 11, 2015 Page 6

14 CFR § 91.203 (a) & (b)
- Civil aircraft: Certifications required As previously determined with Astraeus Aerial, Exemption 11062, relief from these sections are not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulati ons. 14 CFR § 91.109
- Flight instruction: Simulated instrument flight and certain flight tests This regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dua l controls." The controls for a UAS do not currently have a set of fully functioning dual controls. If a UAS’s pilot is being trained, the pilot performing the training would be directly supervising and could take over the controls from the pilot in train ing if the need arose. This would be similar to the technique of a "throw
- over type" control wheel in some fixed wing aircraft. We feel that this technique meets the intent 91 .109 and provides an equivalent level of safety. 14 CFR § 91.119
- Minimum safe altitudes This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this UAS would be photography or survey of persons, vess els, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained, and careful pre
- planning has been performed. Further, UAS airc raft operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and careful pre
- planning would provide an equivalent level of safety. Furthermore, Opera tor can place barriers and/or structures to sufficiently protect nonparticipating person from the UA or debris in the event of an accident. 14 CFR § 9l.l21
- Altimeter settings This regulation provides that aircraft shall maintain cruising altitudes by re ference to an altimeter setting available within 100 nautical miles of the aircraft. The UAS will normally be flying close to the ground, and in line of sight of the PIC or an observer. This line of sight operation will provide separation from other aircraft, obstructions and terrain providing an equivalent level of safety. Additionally, the altitude information generated by onboard GPS equipment installed on the aircraft will aid in estimating the altitude. Docket O perations April 11, 2015 Page 7 14 CFR § 91.151
- Fuel requirements for flight in VFR conditions This 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 fly after that f or at least 30 minutes. We feel the intention of this paragraph it to provide a reasonable reserve of energy to plan for a safe landing shoul d there be a delay in landing. Given the close proximity to the ground station, the ability for the UAS to land in a very small space and the built in energy level monitoring of the UAS there is a resulting equivalent level of safety if the flight is planned to be completed with 20% battery energy remaining. We request an exemption to the word "fuel" and ask for an equ ivalent interpretation with the word "energy".14 CFR § 91.205 (b)
– Powered civil aircraft with standard category U.S. airworthiness

certificates: Instrument and equipment requirements Since the Operator’s UAS does not have a standard category U.S. airw orthiness certificate, relief from 14 CFR § 91.205 is not necessary. 14 CFR § 91.215
- ATC transponder and altitude reporting equipment and use Section 91.215 (b)(3) includes provision for aircraft not originally certificated with an engine
driven electr ical system or which has not subsequently been certified with such a system installed. For UAS not equipped with a transponder, sub
- paragraph (d)(3) authorizes requests for ATC authorized devi ations made to the ATC facility having jurisdiction over the con cerned airspace within the time periods specified. For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation. 14 CFR § 91.401
– 91.417
– Maintenance, preventive maintenan ce, and alterations This regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Operator believes that adherence to their documents containing prefli ght and post
- flight checks for the UAS is sufficient to ensure that safety is not adversely affected. Respectfully, Daniel M. Foard
- President Cameron J. Foard Vice President Videophotog Productions 256 Tropic BLVD E. Largo, FL 33770