PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

January 6, 2016

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Operati on West Building Ground Floor Room w

- 12

- 140 1200 New Jersey Ave, SE Washington, DC 20590



## Petition for Exemption

RE: Petition of C2 Collaborative for an Exemption under Section 333 of the FAA
Modernization and Reform Act of 2012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, LLC., on behalf of C2
Collaborative for exemption from certain rules of 14 C.F.R. C2 Collaborative requests Exemption in a n effort to be granted permission to operate small Unmanned Aircraft Systems (“ sUAS”) commercially in
the United States of America. These operations would be subject to the current rules and regulations

, not stated herein as rules requested for exemption under Section 333, under the jurisdiction of the Department of Transportation a nd the Federal Aviation Administration

. Additionally, all operations will adhere to str ict safety rules enforced by C2 Collaborative within their

company

. These safety rules will be modeled after recommendations made by th e FAA and community

based organizations such as the Academy of Model Aeronautics. Specific conditions relating to the safe operations of sUAS by C2 Collaborative will be covered in more detail in the documentation to come,
h owever basic flight safety parameters often cited by organizations such as the Academy of Model Aeronautics will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach areas to name a few

.

As was established in Huerta v. Pirker

, an aircraft is, “any” “device” that is “used for flight.” 1 Clearly this broad definition encompasses the types of sUAS the petitioner, C2 Collaborative , plans on flying commercially within the United States of America and as such, are governed by the rules of 14 C.F.R. Petitioner Name: C2 Collaborative Petitioner Contact: Jack Haden Petitioner Phone Number: 949

- 366

- 6624 Petitioner Email Address: jhad en@c2collaborative.com Petitioner Address: 100 Avenida Miramar San Clemente, CA 92672

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com Website: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 2

Due to this, in the following Petition for Exemption and associated documentation, C2 Collaborative will establish clear reasoning as to why their particular commercial sUAS flights should be granted exemption and why their business should be exempt from certain parameters of 14 C.F.R.

A s has been established by the FAA ov er the last year, sUAS pilots are allowed to petition for exemption from certain aircraft rules that may be inapplicable to sUAS craft or that may place an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. C2 Collaborat ive would like to request exemption from certain parameters contained in 14 C.F.R. The specific rules for which C2
Collaborative requests exemption will be covered in further detail in the documentation to come, but, in

sum mary, C2 Collaborative looks to be exempt from the types of rules that may limit or otherwise prevent their intent of operating sUAS commercially within the United States.

Furthermore, t hese commercial operations would only be conducted after a granted Section 333 Exemption and within the outlined conditions below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Letter

. With the approval of this exemption, C2 Collaborative will be allowed to commercially operate their sUAS within the United States of America. Specifically, C2 Collaborative will be allowed to fly commercially with the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Furthermore, C2
Collaborative will be opera ting their sUAS in furtherance of various applications within the following industries; Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and Search and

Rescue

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, along with these sUAS flight applications, will be expanded upon in more detail below.

In addition to C2 Collaborative ’s Petition for Exemption pertaining to the use of the aforementioned
aircraft and use

- cases, the granting of this Petition will also allow for the commercial operations of sUAS
in Clas s G Airspace, below 400 feet Above Ground Level (“AGL”) , nationwide, or as otherw ise granted in a Certificate of Authorization (“COA”). To start, C2 Collaborative will adhere to the blanket Certificate of Authorization that is granted to each entity receiving an Exemption Number. This COA currently allows for flights nationwide, in Class G Airspace, below 200 feet AGL. 2 Further flight areas sought by C2
Collaborative will be applied for through th e FAA’s COA Portal. Additionally, with the potential hazards
and obstacles associated with low

- altitude flight

, C2 Collaborative will adhere to the Visual Flight Rule (“VFR”) minimums which apply to this airspace. Further details on these operational minimums will be
discussed in the documentation to come.

The Petitio n for Exemption below provides details relating to the proposed applications of commercial sUAS use by C2 Collaborative

. Specif ically, C2 Collaborative seeks exemption in an effort to conduct commercial operations within the following industries; Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and Search and Rescue

.

In addition to the v ariety of Industry applications highlighted above, this Petition fo r Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications. Specifically, C2 Collaborative will incorporate a variety of sensor payloads on its sUAS in an effort to capture necessary imagery or data types for each specific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not limited to; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infrared I magery, LIDAR, Se nsor Technologies , GPS Guidance, Photogrammetry, Semi

- Autonomous and Autonomous Flight Controllers (For safety), Object AvoidancePETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 3

Systems, and more. With the data collected from these various sensor payloads, C2 Collaborative will be able to provide high quality data for representatives from the below

- highlighted industries.

 Cinematography: High resolution video can p rovide a new perspective for clients. By providing an aerial shot to a client, C2 Collaborative can give that client a different vantage point from which that indiviidual or company can view their work. Furthermore, C2 Collaborative can use this imagery to better design and plan for their various projects.

 Construction Observation: High resolution video and imagery can assist architects and engineers determine if the construction materials and installations being utilized on a construction job site are in accordance with the construction documents and specifications developed by the designers. By capturing an aerial vantage point, these job

- site observers can better analyze the project

- site as a whole and assess the overall progress being made as well a s confirm the quality of workmanship.

 Land Inspection: High quality, high resolution imagery and 3D modeling can help land assessors, government agencies, surveyors , insurers, architechs, designers, and the like utilize aerial data to ensure confidence in their operations and efficiency in their practices.

 Real Estate: High qu ality, high resolution imagery and aerial cinematography can provide a new perspective for an interested property

- buyer, which in turn allows for another marketing piece for architechs, designers, land developers, landscapers, and real estate agents to mov e properties and thus create a stronger real estate market.

 Search and Rescue: High quality, high resolution imagery and aerial video can provide an incredible vant age point from which search and rescue teams can more effectively scope out an area. Furthermore, with the ability to stitch still images and georeference data, Search and Rescue teams can more effectively map the areas they have already search and more e fficently direct their resources to lesser searched areas.

The applications highlighted in this petition obviously p rovide high quality dat a to a variety of interested parties in vari ous industries. However, sUAS have more to provide than just interesting pictures and efficient operations. There is also the enhanced safety sUAS provide not only for the operators of these systems, but also, the people around them, communities as a whole, and the National Airspace System (“NAS”).

Within this Petition for Exemption you will find that the applications highlighted above along with the aircraft systems utilized by C2 Collaborative , satisfy the conditions highlighted by the Federal Aviation Administration as requirements for a successful Section 333 Exemption Petition

. 3 Specifically, the sUAS operating in furtherance of the industry app lications above should;

1. Provide a benefit to the public as a whole, and;
2. Not adversely affect safety.

To answer these requirements this Petition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as show t he positive affect these operations will have on safety.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 4

Specifically, it will be shown that the commercial sUAS flights proposed in this Petition further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aeri al Vehicle (“UAV”) Intervention

. 4 Basically, the “D” list provides a description of situations in which an unmanned vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial

op eration is going to be; Dull, Dirty, Dangerous, or Deep

. 5 This list is often associated with early military applications utilizing UAV’s. The UK Ministry o f Defense for example has used this list in determining the role o f Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is ; 5

 Dull

- flights require persistence or repetition.  Dangerous

- flights carry a high degree of risk.  Dirty

- flights must be carri ed out in hazardous environments, or;  Deep

- flights are beyond the range of manned platforms.

In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of UAV Intervention and safety attrib utes of the sUAS Operations proposed in this Petition for Exemption, it is also important to quickly consider the aircraft types utilized by C2 Collaborative

.

As mentioned above, C2 Collaborat ive seeks exemption for the utilization of the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. All of these aircraft ar e small Unmanned Aircraft Systems and are ba ttery

- powered. Operations conducted by C2 Collaborative with these sUAS will adhere to the guidelines set forth by the Federal Aviation Administration and Community

- Based Organizations such as the Academy of Model Aeronautic s (“AMA”). Through the adherence of these guidelines C2 Collaborative will c ommercially operate their sUAS with an equivalent level of safety, if not superior level of safety, as outlined by the Federal Aviation Administrati on’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by C2 Collaborative in this Petition for Exemption would produce far safer methods of data capture than currently

- used colle ction methods in which manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of metal, are powered by a combus tion engine, carry flammable fuel, and are carrying people. Plus, with the type of data

- capture proposed i n this Petition, a manned aircraft would have to operate in high

- risk situations, including, in close proximity to the ground where the risk of an accident is highest and the risk to people and property on the ground is the greatest. Contrasting the two a ircraft types, it is clear that a plastic, battery

- powered, unmanned vehicle operating at low altitudes, would be m uch safer than a multi

- thousand

- pound

, metal aircraft, powered by a combustion engine, and carrying a person at low altitudes.

This fact i s furt her bolstered by the operational and aircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 These directives include ;

1. The size of the aircraft
2. The weight of the aircraft
3. The speed of the aircraft
4. The operational capability of the aircraft
5. The aircraft operation’s proximity to airports
6. The aircraft operation’s proximity to populated areas , and;
7. The aircraft operation’s adherence to Visual Line of Sight RulesPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 5

As hi ghlighted above, it is clear that this Petition for Exemption and both the aircraft types and applications state d herein, strictly adhere to the operational and aircraft

- specific parameters highlighted by the FAA for a successful Exemption Petition and thu s, support the granting of this Exemption. A summary of the reasoning behind this statement can be found below as;

1. All proposed sUAS are Small
2. All proposed sUAS weigh below 55 lbs.
3. All proposed sUAS travel at less than 100 mph (87 Knots)
4. All proposed sUA S are capable flight systems and have been granted Exemptions previously
5. All proposed operations will take place at least 5 miles from an Airport
6. All proposed operations will take place in unpopulated area s (U nless prior approval is given {See Condition #3 4 [“ Proposed Conditions of the Exemption ”] below})
7. All proposed operations will adhere to the Visual Line of Sight Rules

By adhering to t he parameters published by the FAA and by promoting the public good through the various Industry applications to be highlighted below, this Pe tition for Exemption on behalf of C2 Collaborative s trongly supports the granting of this Exemption.

We kindly ask for your consideration of this Petition fo r Exemption. Please see the table of contents below for all our documentation and for assistance in reviewing this Petition. Thank you for your efforts in reviewing this document and we look forward to your response. If you have any questions while
revi ewing this document, please do not hesitate to ask. You can contact the Preparer of this document for all questions relating to this petition and they can be reached by email at dmzaerial@gmail.com

. Further cont act information can be found at th e top of this Petition or on the following website s; www.dronefly.com or www.dmzaerial.com . Once again thank you for your efforts in reviewi ng this Petition for Exemption and we look forward to your reply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)



## Contact Information

Document Preparer:

DMZ Marketing, LLC.
1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.comPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 6

Petitioner:

C2 Collaborative 100 Avenida Miramar San Clemente, CA 92672 Jack Haden
949

- 366

- 6624 jhaden@c2collaborative.com



## Disclosure

The Petitioner for this exemption is C2 Collaborative

, a landscape

- design firm that provides comprehensive landscape architectural design services for projects small to large in scale, for custom estate homes, masterplan communities, resorts, commercial/retail entities, residential spaces, and
sensitive ha bitats. C2 Collaborative purchased document preparation services through Dronefly, Inc. for the purpose of petitioning the FAA to be allowed to fly their s mall Unmanned Aircraft Systems commercially within the United States . Dronefly Inc., contracts DMZ Marketing, LLC.

, also known as DMZ Aerial, to help formulate these documents and work with the customer to help promote safe flying practices and appropriate operations. This is done through questionnaires, phone conversati ons, document preparation, training module creation, and more. If you have any questions relating to the Petitioner, Dronefly, Inc.

, or DMZ Marketing, LLC. (“DMZ Aerial”), please do not hesitate to contact us using the contact information provided above.



## Table of Contents

Petition for Exemption

................................ ................................ ................................ ............................ 1

Contact Information

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

Disclosure

................................ ................................ ................................ ................................ ................ 6
The Applicant

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

Commi tment to Safety

................................ ................................ ................................ ........................ 9
Experience and Expertise

................................ ................................ ................................ ................... 10

Privacy

................................ ................................ ................................ ................................ ............... 10
Publishable Summary

................................ ................................ ................................ ............................ 10

Petitioner’s Contact Information

................................ ................................ ................................ ........... 12
Proposed sUAS Operations

................................ ................................ ................................ .................... 13
Small Unmanned Aircraft Systems

................................ ................................ ................................ ..... 13

DJI Phantom 3 Profess ional

................................ ................................ ................................ ............ 13PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 7

DJI Inspire 1

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

DJI Matrice 100

................................ ................................ ................................ .............................. 14
Unmanned Flight Crew

................................ ................................ ................................ ...................... 15
Unmanned Flight Conditions

................................ ................................ ................................ .............. 15
Unmanned Flight Operations

................................ ................................ ................................ ............. 16
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ... 16
National Security

................................ ................................ ................................ ................................ ... 17
Proposed Conditions of the Exemption

................................ ................................ ................................ .. 17
Exemptions Requested & Applicable Conditions/Reasoning

................................ ................................ ... 23
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .......................... 23

14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft

................................ .................. 23
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ............... 24
14 C.F.R. 43.11: Dispositions of Records for Inspections

................................ ................................ ..... 24
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ... 24
14 C.F.R. 45.23(b): Display of Marks; General

................................ ................................ ..................... 25
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ .......... 25

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ............ 25

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

................................ .......... 26
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duration

................................ .... 26
14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ......... 27
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Co mmand

.......................... 28
14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

................................ ................... 29
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ..................... 32
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ................. 32
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ............... 33
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ....... 33
14 C.F.R. 91.105: Flight Crewmembers at Stations

................................ ................................ ............. 34

14 C. F.R. 91.109: Flight Instruction

................................ ................................ ................................ .... 35
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ............................. 36

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

................................ ................................ ......................... 36
14 C.F.R. 91.121: Altimeter Settings

................................ ................................ ................................ ... 37
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ...................... 39
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ..................... 39PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 8

14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

................................ ..... 40

14 C. F.R. 91.403: General

................................ ................................ ................................ ................... 42
14 C.F.R. 91.405(a): Maintenance Required

................................ ................................ ....................... 42
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ .................... 43
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ .............................. 43
14 C.F.R. 91.417(a) and (b): Maintenance Records

................................ ................................ ............. 43

Privacy

................................ ................................ ................................ ................................ .................. 45
Public Interest and Safety

................................ ................................ ................................ ...................... 45
Cinematography

................................ ................................ ................................ ............................ 46

Construction Observation

................................ ................................ ................................ .............. 48
Land Inspection

................................ ................................ ................................ ............................. 50

Real Estate

................................ ................................ ................................ ................................ ..... 51

Search and Rescue

................................ ................................ ................................ ......................... 53
Regulations Requested for Exemption

................................ ................................ ................................ ... 55
Appendix 1: Regulations Requested for Exemption

– List

................................ ................................ ... 55

Exhibit List

................................ ................................ ................................ ................................ ............. 55
Exhibit 1: C2 Collaborative Operations Manual

................................ ................................ .................. 55
Exhibit 2: C2 Collaborative Logbook Example

................................ ................................ ..................... 55
Exhibit 3: C2 Collaborative Visual Observer Training Procedures & Guide

................................ .......... 56

Visual Obse rver Training Procedures

................................ ................................ .............................. 56
Visual Observer Training Guide

................................ ................................ ................................ ...... 56
Exhibit 4: C2 Collaborative Pilot In Command Training Guide

................................ ............................. 56
Pilot In Command Training Procedures

................................ ................................ .......................... 56
Pilot in Command Training Guide

................................ ................................ ................................ ... 56

Exhibit 5: DJI Phantom 3 Professional

................................ ................................ ................................ 57

Exhibit 6: DJI Phantom 3 Professional User Manual

................................ ................................ ............ 57

Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

................................ ................................ .... 57

Exhibit 8: DJI Phantom 3 Professional Features

................................ ................................ .................. 57
Exhibit 9: DJI Phantom 3 Professional Specifications

................................ ................................ .......... 57
Exhibit 10: DJI Phantom 3 Professional Flight Control ler System

................................ ........................ 57
Exhibit 11: DJI Phantom 3 Professional Smart Battery Manual

................................ ........................... 57
Exhibit 12: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

................. 58
Exhibit 13: DJI Inspire 1

................................ ................................ ................................ ...................... 58PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

Exhibit 1 4: DJI Inspire 1 User Manual

................................ ................................ ................................ . 58
Exhibit 15: DJI Inspire 1 Quick Start Guide

................................ ................................ .......................... 58
Exhibit 16: DJI Inspire 1 Features

................................ ................................ ................................ ....... 58
Exhibit 17: DJI Inspire 1 Specifications

................................ ................................ ................................ 58
Exhibit 18: DJI Inspire 1 Flight Controller System

................................ ................................ ................ 58
Exhibit 19: DJI Inspire 1 Smart Battery Manual

................................ ................................ ................... 58

Exhibit 20: DJI Matrice 100

................................ ................................ ................................ ................ 59

Exhibit 21: DJI Matrice 100 User Manual

................................ ................................ ............................ 59

Exhibit 22: D JI Matrice 100 Features

................................ ................................ ................................ .. 59
Exhibit 23: DJI Matrice 100 Specifications

................................ ................................ .......................... 59
Exhibit 24: DJI Matrice 100 Smart Battery Manual

................................ ................................ ............. 59

References

................................ ................................ ................................ ................................ ............ 59
Exemption References

................................ ................................ ................................ ........................... 60



## The Applicant

The Applicant seeking this Exemption is C2 Collabor ative , headquartered at;

100 Avenida Miramar San Clemente, CA 92672

C2 Collaborative provides comprehensive landscape architectural design services for projects small to large in scale, for custom estate homes, masterplan communities, resorts, commercial/retail spaces, residential areas, and sensitive habitat programs. Originally founded in 1987 as The Collaborative West, C2 Collaborative was recently re

- branded with a global focus. The company's approach is an active partnership with clients and their consultants that transcends the entire design process from the conceptual master planning phase through construction observation.

C2 Collaborative has completed numerou s commercial, residential, and institutional projects throughout California, the United States, Asia, South America , and t he Middle East. This work includes resorts, recreation communities, lifestyle centers, community planning, urban & civic layouts, indu strial

- work, and park design.



### Commitment to Safety

A commitment to safety is key to any successful business. C2 Collaborative is committed to operating within the National Airspace System safely and legal ly. It is for this reason that they have filed thisPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 10

Petition for Exemption in an effort to make their actions known and to be sure they are operating within the rules and regulations set forth by the Federal Aviation Administration. Additionally, C2 Coll aborative is a family

- owned business that has stri ved for a high level of quality

- work, integrity, safety and creativity for over 25 years. All of the company's commercial fights will be under contract and sanctioned by the client/property owner. Further more, any individuals on film will be consenting participants, including C2 Collaborative employees, contractors

, or hired actors. If any other individuals are captured on film, they will have to sign a release form.

Additionally, C2 Collaborative ’s intent on hiring a lic ensed Pilot In Command shows their commitment to safety. A licensed pilot is not only required by current FAA rules but also provides for a heightened level
of saf ety for the National Airspace because a pilot will have completed significan t training in the National Airspace System and be cognizant of all federal aviation rules. Plus, in addition to the Petitioner’s utilization of a licensed Pilot In Command, they will also be following the conditions set forth
within the Conditions of the Exemption Section below, which will provide an equivalent, if not superior level of safety as is provided by current rules.



### Experience and Expertise

C2 Collaborative has extensive experience in the fol lowing industries; Land information Services, Real Estate, and Construction Observation. The company has worked on over 1,000 projects that required them to have expertise in these categories in all stages of construction, from design to execution.
Furth ermore, pertaining to cinematography experience, the Petitioner Contact for C2 Collaborative, Mr. Jack Haden, has taken multiple college

- level cinematography and photography courses as well as helped produce TV commercials, which has given him invaluable e xperience in safe operating procedures pertaining to cinematography. Finally, Mr. Haden

, as well as other members of C2 Collaborative

, have volunteered their time in the search for missing people. This experience exposed them to search and rescue procedu res that has helped them develop an action

- plan for a future Search and Rescue offering utilizing UAV Systems.



### Privacy

In terms of Privacy, C2 Collaborative will ensure that all of their commercial fights will be under contract
and sanctioned by the client/property owner. Furthermore, the company will ensure that all individuals on film are consenting participants, including; employees, contractors

, or hired actors. If any other individuals are captured on film, they will have to s ign a release form. Finally, all video/data will be
stored on a secure

, private server which can only be accessed by Senior Project Staff.


## Publishable SummaryPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 11

DMZ Marketing, LLC. files this petition for exemption on beha lf of C2 Collaborative

, a landscape

- design firm that provides comprehensive landscape architectural design services for projects small to large in scale, for custom estate homes, masterplan communities, resorts, commercial/retail entities, residential spaces, and sensitive habitats. C2 Collaborative is seeking exemption from certain parameters of 14
C.F.R. in orde r to commercially operate sUAS withi n the United States in the following industries; Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and Search and Rescue

. Specifically, C2 Collaborative requests exemption from the following Federal Aviation Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F. R. 27: Airworthiness Standards

- Normal Category Rotorcraft
3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products

6. 14 C.F.R. 45.23(b): Display of Marks ; General

7. 14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft
8. 14 C.F.R. 45.29: Size of Marks
9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations

10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101 (e) (4) and (5): Recreational Pilot Privileges and Limitations

12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command
13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airwort hiness
15. 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual
16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

17. 14 C.F.R. 91.103: Preflight Action

18. 14 C.F.R. 91.105: Flight Crewmembers at Stations
19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Rig ht

- of

- Way Rules

21. 14 C.F.R. 91.119: Minimum Safe Altitudes
22. 14 C.F.R. 91.121: Altimeter Settings
23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

25. 14 C.F.R. 215: ATC Transp onder and Altitude Reporting Equipment and Use
26. 14 C.F.R. 91.403: General
27. 14 C.F.R. 91.405(a): Maintenance Required

28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

29. 14 C.F.R. 409(a)(1) and (2): Inspections
30. 14 C.F.R. 91.417(a) and (b): Maint enance Records

The approval of this Petition for Exemption would allow for the commercial operation of small Unmanned Aircraft Systems by C2 Collaborative

. These commercial operations would strictly adhere to
all Federal Avi ation Administration rules and regulations not stated herein as rules requested for exemption. The commercial operations flown by C2 Collaborative , if this Petition were granted, wouldPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 12

be flown utilizing one of the following aircraft platforms; the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Specifically, the commercial operations utilizing t hese unmanned aircraft would

center arou nd the following industry applications; Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and Search and Rescue

. Additionally, all the industry applications highlighted above would include one or more of the unmanned
aircraft noted above flying no more than 400 feet Above Ground Level (“AGL”) o r in airspace otherwise

spec ified in a gra nted Certificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to C2 Collaborative because th e operation of
the listed sUAS above will provide for commercial operations while mainta ining an equivalent level of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the small Unmanned Aircraft utilized by C2 Collaborative will provide methods of aerial data col lection far safer
than the alternative of manned aircraft collection of the same data sets. Low altitude data

- collection flights, in close proximity to people and property, are far safer when accomplished using a battery

pow ered sUAS weighing less than 10 lbs., than with a combustion

- engine

- powered, multi

- thousand

pound, manned aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted by the FAA as parameters for successful Section 333 Exemption Petitions, including; Size, Weight, Speed, Operational Capability, Proximity to Airports, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’s

re quest for exemption relating to each operational and aircraft

- specific parameter . Specifically, the aircraft utilized by C2 Collaborative are in the small

- size category, they are below the 55 lbs. weight class, they travel at less than 100 mph, they are proven flight platform s based on previously granted petitions, all operations will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise granted permis sion by the FAA in a granted Certificate of Authorizatio n), and all flights will be
conduc ted within Visual Line of Sight.

In addition, the data collectio n flights provided by the sUAS highlighted in this Petition will promote safer operations for professional service providers in the aforementioned industries.



## Petitioner’s Contact Informat ion

Petitioner:

C2 Collaborative Jack Haden 100 Avenida Miramar San Clemente, CA 92672
949

- 366

- 6624 jhaden@c2collaborative.com



## Document Preparer:

DMZ Marketing, LLC. 1501 Parkview CourtPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 13

Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com



## Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will permit the Petitioner to operate the DJI Phantom 3
Professional

, DJI Inspire 1

, and DJI Matrice 100

. Further operating characteristics, specifications, and other important craft

- specific information on the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI
Matrice 100 are covered in detail starting with Exhibit 5 . Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption
under Sect ion 333. In the aircraft summaries below , please see the references to previously granted petitions for the use of each specific aircraft type in commercial operations within the United States

.



### DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the li ke. The DJI Phantom 3 Professional has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed of 16 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  H over

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phantom 3 Professional

- Specific Exhibits below for more information
on the DJI Phantom 3 Professiona l craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting
documents for the commercial use of the DJI Phantom 3 Professional in the followin g listed Exemption;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587APETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 14



### DJI Inspire 1

The requested exemption will permit the Pet itioner the right to use the DJI Inspire 1 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Inspire 1 has a weight of 2935 grams including the batte ry payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abi lities in every lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the DJI Inspire 1 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of
these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A  Phillip Stiles

– GPS Devel opment, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Matrice 100 has a maximum take

- off weight of 3400 grams including technical payloads and batte ries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Matrice 100

- Specific Exhibits below for more information on the DJI Matrice 100 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous
review of these exh ibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following listed Exemption;

 Dan Pham

– Alert5 International, LLC.

– Exemption Number 11814PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 15



### Unmanned Flight Crew

The unmanned flight crew ope rating C2 Collaborative flight crafts for purposes of commercial operations within the United States under this proposed Exe mption will consist of a Pilot I n Command (“PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously granted Section 333 Exemption s, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U.S. Driver’s License

. 7 Additionally, both the PIC and VO will be trained in the operation of sUAS prior to commercial operations. Furthermore, any new information surrounding the aircraft’s efficient, effective, or safe operations, will be disseminated by C2 Collaborative to both the
PIC and VO to ensure continued safe f lights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight training with the specific sUAS craft they are using for their commercial operation and will be required to receive annual continued educat io n and training moving forward. A specific PIC Training Presentation is contained in the exhibits below and will accompany this Petition for Exemption.

The Visual Observer will also have completed specific trai ning relating to their duties during an

unma nned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.



### Unmanned Flight Conditions

As has been described above, the sUAS use proposed by the Petitioner in this Petition for Exemption
under Section 333 revolves around the following industries; Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and S earch and Rescue

. Each of these industry applications will be
described in further detail below under the “ Unmanned Flight Operations ” Title.

Moving on from the specific use cases, it sh ould also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise permitted in a granted Certificate of Authorization. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model
Aeronautics

. 6 Additionally, the PIC will only operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several standing classifications developed by the Federal Aviation Administration. These include operations being conducted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, C2 Collaborative will strictly adhere to the FAA’s V isual F light R ule s,

an d obviously, to be following Vis ual Flight Rules, C2 Collaborative will have to f irst satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary between Visual Meteorological Conditions, which allow for Visual Flight Rules, andPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 16

Instrument Meteorological Con ditions, which require Instrument use. Specifically, C2 Collaborative will be considering the VMC Minima pertaining to Visibility, Cloud Ceilings, and Cloud Clearances associated with airspace below 400 feet AGL, where the P etitioner’s sUAS will be flying. Thus, the Petitioner will only operate when visibility is at least 3 statute miles from the PIC and at a minimum of 500 feet below and 2,000 feet horizontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the flight crew will always make an assessment of the current situation for each, specific flight. This assessment will conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds that the flight will be too dangerous or that there are too many hazards or risks associated with the flight, the flight crew will not take off. Furthermore, in order to maint ain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permission is granted to the Petitioner by the landowner, property owner, or other controlling representative. All current FAA regulations n ot covered within this petition will be followed as well as all local and state rules surrounding flights near or around people. Additional information on the parameters dictating flights near people can be found below in the “ Proposed Conditions of the Exemption .”



### Unmanned Flight Operations

When conducting commercial flight operations under the pro posed applications in this Petition for Exemption , a commitment to safety will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, it will be vital for all flights to be safe for several reasons, including;

 The safety of the C2 Collaborative Flight Crew will b e necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the aircraft will be necessary for continued commercial endeavors.

Furthermore, in an effort to supply the Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and Search and Rescue industries with valuable data, i t will be imperative for all C2
Collaborative flights to be conducted in a safe and professional manner so as to not risk the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or prope rty operating in the National Airspace System or on the ground below.

To ensure the safe and professional execution of each sUAS flight, all flights will be conducted utilizing at
least a two

- person flight crew. This flight crew will consist of an adequ ately

- trained (“ Unmanned Flight
Crew ” ) PIC and VO. For specifics pertaining to the standard operating procedures utilized by the Petitioner under the proposed Petition for Exemption and for more details on training , please see
Exhibits 1

- 4

. 

## Aircraft and Equivalent Level of SafetyPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

As is stated in the FAA’s Section 333 Exemption Guidelines, Petitioners for Exemption must show that their proposed commercial, sUAS operations provide a level of safety at least equal to that provided by the rule from which the Petitioner seeks an exemption

. 6 As will be highlighted below, the request for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of sUAS by the Petitioner, using the previously stated flight crafts and operating within the above

- stated

use

- cases under the rules, regulations, and limitations stated herein, should be permitted under the proposed exe mption. Reasoning for this can be derived from the strict adherence to existing regulations from the Federal Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the existing rule.


## National Security

In addition to the arguments supporting the Petitioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commercia l sUAS flights, will not present a national security threat. As has been stated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUAS

mus t hold, at minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been subject to a security screening by the Department of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks already provided by the FAA and Department of Homeland Security in ensuring secure aircraft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in order to identify individuals that may pose a threat to transportation security and coordinate countermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement f or all PICs to be at least Recreational or Sport Pilot Certified, it can be assumed that adequate security checks by the TSA and FAA have taken place prior to a sUAS Pilot conducting commercial operations.


## Proposed Conditions of the Exemption

As is no ted by the Federal Aviation Administration in their, “Section 333 Petition Guidance & Checklist” 3 form, Section 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions and
Limitations Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exemption closely follow this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish a framework from which the petitioner, C2 Collaborative , will conduct their commercial sUAS operations under a granted petition for exemption.

1. Proposed oper ations using s mall Unmanned Aircraft Systems in the United States under the granted form of this Petition for Exemption will be limited to the following aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom
3 Professional

, DJI Inspire 1

, and DJI Matrice 100

.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 18

Furthermore, any aircraft outside of this comprehensive list for this Petition for Exemption will
have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new flight platform (s)

.

2. The proposed use

- cases/applications contained within this Petition for Exemption under Section 333 are as follows; Cinematography

, Construction Observation, Land Inspection

, Real Estate

, and Search and Rescue

. All of these flights will take pla ce below 400 feet AGL nationwide unless otherwise advised in an
ATO

- issued Certificate of Waiver or Authorization.

3. All flights conducted by C2 Collaborative will be below 400 feet AGL, operated within Visual Line of Sight, a nd have a live, GPS

- based, read

- out of altitude during the flight. Furthermore, each flight will begin with a “Zero Altitude” start point, thus creating an accurate AGL calculation.

4. All flights conducted by the Petitioner will be controlled by a trai ned flight crew consisting of a licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or equivalent

, valid U.S.A. Driver’s license and a trained Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 knot (100 mph) airspeed maximum, highlighted by the FAA in their guidelines.

6. All flights conducted by C2 Collaborative will be conducted within Visual Line of Sight, during daytime fl ying hours, and adhere to Visual Flight Rules under the Visual Meteorological Conditions associated with 400 foot AGL airspace.

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification standards set by the Federal Av iation Administration (i.e. Minimum

- Sport Pilot’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating to safe sUAS operations, such as;

a. Evasive Maneuvers
b. Emergency Actions

c. Fail

- Safe Know ledge
d. Flight Skills

i. Maintaining adequate distances from;

1. People
2. Property
3. Structures

4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). Additionally, a record of the PIC training will be documented and made a vailable upon request by the Administrator.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 19

9. Training operations will only be conducted during dedicated training sessions. During training, all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distance from nonparticipants in accordance with 14
C.F.R. 91.119.

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace for aircraft, hazards, obstacles, structures, or the like. F or this reason, the VO will not be allowed to operate the camera or other instruments on the sUAS during flight operations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera ope rator.

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this, once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her designation as the PIC through the duration of the flight . Furthermore, the PIC is the Captain of the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by C2 Collaborati ve will be planned for ahead of the flight date. This will be to ensure adequate time for all participants to prepare and to obtain all the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. All flights will be prec eded by a meeting at least one day before the flight at which all participants of the flight will be present. This is to ensure adequate knowledge and preparedness prior to the sUAS flight.

13. Aircraft maintenance is obviously vital for any commercial sUA S operation. It ensures safety and is necessary prior to each flight to maintain safe, efficient, and effective flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight . The PIC will likely have the most experience of anyone on the flight crew and will be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, incl uding the Ground Control System for example, he/she would ground the flight until adequate maintenance is completed and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating them.

14. Relating to the above Condition, anytime a flight

- critical component is replaced or anytime there is mission

- critical maintenance on the craft, the PIC will conduct a flight test of the system be fore completing the intended, commercial mission. Once again this flight test will be logged by the PIC.

15. Routine maintena nce and inspections of the sUAS will be logged by the PIC in accordance with the requirements and suggestions laid out by the aircra ft manufacturer in terms of aircraft component maintenance, overhaul, replacement, inspection, and life limits, which are part of the supporting documents for each aircraft below in the aircraft

- specific exhibits . The logging of these maintenance/inspecti on checks will be included in the aircraft records and include the total time of service and description of work.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 20

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visua l observance unaided by any device other than corrective lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in con stant, verbal communication range. The use of other devices to communicate out of verbal range are not permitted. These devices would include, cell phones, text messaging, walky

- talkies, and the like.

17. No commercial flight missions will be executed unl ess it can be determined that the flight crew can complete their mission from take

- off through landing, with a reserve of 25% battery life. The Petitioner’s newest flight crafts have adaptive battery monitors and

, for this reason

, this condition will be a n automated process as the Petitioner can set the default Advisory and Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted battery and engage him/her to fly home and land with 25% remaining power. For all C2 Collaborative systems without this automated feature, a watch will be used to monitor flight times to ensure a safe return home with adequate battery power. However, due to the revolving adoption of the newest flight platforms a nd the current stock of new generation flight crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize a Smart Battery System.

18. In the case of an unexpected obstacle or in

- flight issue, each sUAS the Petitioner o perates will have the ability to abort a mission and take corrective actions.

19. The sUAS utilized by C2 Collaborative will be programmed so that if the sUAS loses signal with the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS location located within the operating area containing the flight crew. Furthermore, this failsafe can also be used in controlled situations, meaning the failsafe will be able to be engaged should something ha ppen on the ground that disallows the PIC from bringing the sUAS back in a normal fashion. Additionally, in both situations described above, where the failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio

- link sign al loss, the unit will not only fly back to its preprogrammed home point, it also has the ability to land itself. This allows safe operations of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncont rollably or landing in an unknown location.

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. Furthermore, these docu ments will be available for review by the Administrator or other law enforcement officials upon request and are additionally contained in Exhibit 1, with appropriate links to the specific flight manuals of each flight craft requested in this Petition for E xemption.

21. It is always important to specify precedent when determining operating practices. For this reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and the actual Granted Exemption, the conditions laid o ut in the finalized Granted Exemption will take precedent over the conditions laid out in this Petition. Furthermore, if there are no discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Oper ating Documentation below. Additionally, if any changes are made to the Operating Procedures and Documentation contained in this Petition for Exemption,PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 21

the Petitioner will present the updated documents upon request from the Administrator. Also, should t he Petitioner determine that an update or change to the procedures or documentation would affect the basis of the approved version of this Petition for Exemption, the Petitioner will either file for an amendment to the existing Exemption or create a new Pe tition with the
revisions.

22. As has been noted, the Petitioner will obtain written and/or oral permission fr om the landowners, property owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all require d permissions and permits from territorial, state, county or city jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under t he grant of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner aft er receiving their Section 333 Exemption.

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference point as noted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s Air Traffic Control i s obtained, and the operation is conducted in accordance with a NOTAM as required by the Operator’s COA.

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as othe rwise advised in an ATO

- issued COA.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number which will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that so l ong as the markings are as large as practicable given the size of a sUAS, an equivalent level of safety can be achieved.

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“ FCC”). For this reason, prior to commercial operations under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agency r ules and regulations.

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC is n ecessary for safe operations. It is for this reason that the Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These vehicles would include things like;

a. Cars/Trucks/SUVs b. Boats

c. Tractors d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all nonparticipating people, vessels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapnel or debris should there be an accident. Furthermore, should a nonparticipant leave this safe

- zone, the PIC will end the flight.

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of these p roperties. In addition to permission, the PIC will also have to perform a risk assessment of the situation and potential obstacles/flight hazards and determine the safety of the flight. If it is determined that the hazards present no risk, the PIC can st art the mission.

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, accident, or flight operation that occurred outside the horizontal and vertical boundaries of the operational area as defined by the COA u nder which the flight was operating. Furthermore, the Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an exempt ion from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, each PIC that is designated as being a potential candidate for flying a sUAS while towing an object will be required to undergo additional training, on top of their required t raining and certifications, that will consist of 10 hours of training flights while towing objects. These objects will be dummy banners that weigh no more than the max weight allowable to satisfy the maxPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

takeoff weight specifications as highlighted by the manufacturer for each flight craft. Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC adequate training time and experience while towing objects with specific flight crafts. This will be necessary to famil iarize each PIC with each specific flight craft in order to learn how specific flight craft respond to towing objects, particularly with regard to downwash and wind. Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by the manufacturer for each flight craft. Training in these conditions will hone the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high win d. When conducting actual commercial flights while towing objects, the Petitioner will not conduct flights in conditions where sustained winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for each aircraft.



## Exemptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 1 4, Chapter 1, prescribes procedural requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting previou s Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R. Furthermore, it is the belief of the Petitioner that a sUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equi valent level of safety to an aircraft operating with an airworthiness certificate not subject to the above conditions or limitations.

Additionally, all the sUAS proposed within this Petition for Exemptio n are small, weigh less than 10 lbs

. , have a flight s peed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are
electric

- powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight of a trained and license d Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the proposed aircraft have safety features equivalent to and superior to conventional aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).



### 14 C.F.R. 27 : Ai rworthiness Standards

- Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft
containe d within this Petition for Exemption are multi

- rotor aircraft, the Petitioner seeks exemption from 14 C.F.R 27 for the same reasons stated in the request for exemption from 14 C.F.R. 21(h).PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 24



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration Personne l

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenanc e, rebuilding, or alteration. Proposed conditions 13 and 14 are applicable to this particular regulation and the FAA has found in favor of previous Exemption #11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or otherwise licensed personnel to sign off on an unconventional flight craft’s maintenance. More clearly,
it would be difficult to find a mechan ic that specializes in Cessna Repair that is also an expert in small
radio

- controlled multi

- rotors.

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mechanic as they likely have past RC flying experience. Particularly, the PICs working for the Petitioner will always have at least 25 hours of RC craft experience, in which time they will likely have to repair a prop for example. Due to the relative ease of rep lacing props on a multirotor (screw the broken one off and replace with a new one) it is not necessary for a certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by authorized personnel working for the Petit ioner so long as the conditions and procedures stated above, are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Sect ion 43.11 of the Code of Federal Regulations pertains to the disposition of Records for Inspections. Proposed condition number 13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11208 which contained this rule. For the reasons stated in Condition 13 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.11.



### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Fede ral Regulations pertains to the manufacturing of aircraft and major aircraft components, including, but not limited, aircraft bodies, aircraft engines, and aircraft propellers. This particular rule requires various procedures for marking each component wi th fireproof markings and, in a manner acceptable to the Federal Aviation Administration, for purposes of
identification. Proposed Condition for Exemption #30 above, pertains to this particular regulation and the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.PETITIONER

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– DMZ Marketing, LLC. 25



### 14 C.F.R. 45.23(b) : Display of Mark s; General

Title 14, Part 45, Section 45.23(b) of the Code of Federal Regulations states that;

 “ When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experi mental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “li ght

- sport,” “experimental,” or “provisional,” as applicable.”

In a previous grant of exemption (Exemption #11062) it was determined by the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identificat ion (N

Number) markings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is stated in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be e xempt from 14 C.F.R. 45.23(b).



### 14 C.F.R. 45.27 : Marking of the Aircraft

– Rotorcraft

According to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both s urfaces of the cabin, fuselage, boom, or tail, the marks required by 14 C.F.R. 45.23.

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Con dition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.27.



### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Sect ion 45.29, of the Code of Federal Regulations, the operator of an aircraft;

 Must display on markings on the aircraft meeting the size requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/ 6 th as thick as the characters are high  Not less than 1/4 th the character width  UniformPETITIONER

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– DMZ Marketing, LLC. 26

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to C ondition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.29.



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authoriz ations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUA S operator to hold a Private Pilot’s License. Clearly, the goal of this particular rule is to ensure the skill of any Pilot In Command matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Priv ate Pilot’s License and the training that went into it is not necessarily connected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trai ned in multi

- thousand pound, manned aircraft, flying at high altitudes in comparison to 7.5 lbs. or less, battery

- powered craft, operated at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as t he requirement of a Private Pilot’s license is unnecessary. Furthermore, it is sta ted as such on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore l ess costly, than a private pilot certificate. ”

The authorization of Recreational and Sport Pilot Certificates as an alternative to a Private License points to a Private License as being a non

- requirement according to the FAA’s integration office. This fur ther evidence shows that the Petitioner should be exempt from the aforementioned regulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or Sport Pilot’s Certificate yields an authorized level of training according to the FAA’s own website and in turn, shows that such a requirement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commitment to safety and arguments for exemption from this rule.



### 14 C.F.R. 61.23(a) and (c) : Medical Certificates

– Requirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of an aircraft is required to hold a Medical Certificate in various Pilot In Command Situations. As is statedPETITIONER

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in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s li cense, which has been ruled by the FAA in previously granted exemptions as a suitable alternative to a valid medical certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and the current FAA Policy displayed below, the Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is con sistent with the agency’s approach for sport pilot certificate holders, who may fly light sport aircraft with a driver’s license and no FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Pa rt 61, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in f urtherance of a business.

As can be seen on the FAA’s website (https://www.faa.gov/news/updates/?newsId=82485);

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions b y people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot ce rtificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn com pensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to fly for compensation.PETITIONER

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– DMZ Marketing, LLC. 28

Furthermore, as is stated on the FAA’s own website and as is highlighted below ;

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highly likely that many potenti al PICs will have these Certificates as they are less costly and easier to obtain than a commercial Pilot’s License as an example. For these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations

– Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.

Clearly this specific regulatio n conflicts with the Petitioner’s desire to provide commercial sUAS flights in the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for compensation or hir e under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, in cluding a private pilot’s license

, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is for the expressed purpose of conducting commercial ope rations of s UAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to prov ide commercial/compensation

- based sUAS flights.

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

 The flight is only incidental to that business or employment; and  The aircraft does not carry passengers or property for compensation or hire.PETITIONER

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– DMZ Marketing, LLC. 29

The Petitioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Add itionally, the specific provision pertaining to not flying aircraft that carry property for compensation or hire is something the Petitioner would like to be exempt from as well

. Various forms of property may be carried on a s UAS, including; Camera System s, Digital Imagery,
Sensors , and the like.

For all these reasons

, the Petition er seeks exemption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.

(2) For compensation or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A air space.

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in §61.325.

(8) Outside the United Stat es, unless you have prior authorization from the country in which you seek to operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an a ircraft salesperson.

(10) In a passenger

- carrying airlift sponsored by a charitable organization.

(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute mil es.PETITIONER

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– DMZ Marketing, LLC. 30

(13) Without visual reference to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §6 1.327(a) or have logged flight time as pilot in command of an airplane with a VH less than or equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.

(16) Co ntrary to any limit on your pilot certificate or airman medical certificate, or any other limit or endorsement from an authorized instructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation impo sed by judicial or administrative order when using your driver's license to satisfy a requirement of this part.

(18) While towing any object.

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type certificat e of the aircraft or the regulations under which the flight is conducted.

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). Particularly, the Petitioner requests exemption from the following subparts of 14 C .F.R. 61.315 (c); 1, 2, 3, 9, and 18. Furthermore, the Petitioner believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditions of the Exemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.

Additionally, pertai ning to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both unnecessary burdens on the Petitioner as well as an equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each sub part are contained below.

Subpart (1) of 14 C.F.R. 61.315 (c) states that a Sport

- Certified Pilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. Th ey will not be carrying any pass e ngers as they are flying Unmanned Systems, and;
2. There will be situations in which the Petitioner carries property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or m easurement tool owned by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the actual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, th e Petitioner will be flying with property for compensation. ThisPETITIONER

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– DMZ Marketing, LLC. 31

compensation is related to the risk of loss while the camera is operating on the Unmanned System as well as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be im possible to obtain if th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) are utilized on unmanned systems. Without exemption from this rule the Petitioner would have to either purcha se the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the information the client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned by the
Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if exempt from this rule because of the exte nsive trai ning the PIC would have on the s UAS prior to flying commercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’s or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and u nmanned aircraft
traini ng to successfully operate the s UAS without endangering the public. The training procedures and training materials for the PIC can b e found in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Peti tioner also requests exemption from subpart (2) which states that an operator with a Sport Pilot’s License may not operate an aircraft for compensation. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Moderniz ation and Reform Act of 2012 was to integrate commercial UAV operations into the National Airspace System. Furthermore, in numerous previously filed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate.

This statement, combined with the initiative behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System ) shows that the FAA has found in favor of the idea that commercial UAV operations can be conducted by people who hold a recreational or sport pilot certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 61.315 (a) (c), which states that a Sport

- Certified Pilot may not operate an aircraft in furtherance of a business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not require d by your business or employment, would be considered “in furtherance of a business.” 10

Clearly, based on this description, an aerial operation that is “in furtherance of a business” would be considered a lesser form of com mercialization than flights for hire or compensation as these types of flights are incidental to a business as opposed to directly related to the business, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitio ner that they be exempt from this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).

On top of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certified Pilot may not operate an aircraft to demonstrate that aircraft for sale. The Petitioner seeks exemption from this rule as they will be carrying an inventory/stock/fleet ofPETITIONER

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– DMZ Marketing, LLC. 32

UAV aircraft in an effort to operate a commercial service bus iness. Furthermore, this inventory/stock/fleet will turnover from time to time as new aircraft are added and old aircraft are released by the company. In this event it will be important for the Petitioner to have the capability of showing off the aircraf t to prospective buyers so that they can get the best price for their used systems. Plus, with PICs already being heavily trained and experienced with commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for s ale to prospective buyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC already performs on a frequent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport

- Certified Pilot may not operate an aircraft while towing an object. It is the belief of the Petitioner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never e xceed the max takeoff weight specifications highlighted by the manufacturer. These max takeoff weights are the maximum weight these aircraft can carry (including themselves) and still fly effectively. Thus, any object being towed by the aircraft will hav e to weigh equal to or less than the maximum allowable weight in order to maintain or come under the max takeoff weight specifications highlighted by the manufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which objects are towed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and additional training necessary for a PIC to become an Object Towing PIC shows the skills that would be required to tow objects.

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the
Petitioner to be able to tow objects, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might measure air quality , capture imagery, or perform various other data collection methods. Competing vehicles for these tow

- b ehind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered by combustion engines, and carry flammable fuel. Additionally, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).



### 14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may operate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particu lar regulation and the FAA has found in favor of previous Exemption #11062, 11063, and 11064, which contained this rule. For the reasons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it i s the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed condition offers an equivalent level of safety as is currently provided by the existing rule.



### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight ManualPETITIONER

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Title 14, Part 91 , Section 91.9 (b) (2) of the Code of Federal Regulations states;

No person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the airc raft, a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any
combination thereof

. Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemptio n s #11062, 11063, and 11064, which contained a request for exemption from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the
Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the Operating manuals about which this rule pertains are available to the operator at all times on the ground, just as they would be if the aircraft was carrying the operator. Thus, any information the operator desires about the aircraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digi tal device, such as a Smart Phone or tablet , easily accessible to the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Placards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition 30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitio ner that they be exempt from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the FAA has previously determined that exemption from these requirements is warrante d provided that the aircraft “have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart c, if the markings are as large as practicable.” 11



### 14 C.F.R. 91.103 : Preflight Action

Title 14, Part 91 , Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

—

(a) For a flight under IFR or a fligh t not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight , runway lengths at airports of intended use, and the following takeoff and landing distance information:PETITIONER

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– DMZ Marketing, LLC. 34 (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeo ff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of air port elevation and runway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.103. Furthermore, the proposed conditions offer an equivalent level of safety as is currently provided by the existing rule as Preflight Planning is integral to the
Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather, power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations states;

(a) During ta keoff and landing, and while en route, each required flight crewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in
connection with the operation of the aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and land ing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perfo rm required duties with the shoulder harness fastened.

Proposed Condition #4 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For the reason stated in Condition #4 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really

ap ply to the Petitioner ’s aircraft as all the aircraft requested b y the Petitioner weigh below 10 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehiclePETITIONER

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where a prospective crewmember would harness the mselves in. Instead, all operations of the sUAS are executed from the ground from a designated operating area, in which, each crewmember has an assigned position at which they will stand during the operation. Generally, this standing area would be

near t he ground station for the PIC and in a pre

- designated area (which is determined by the PIC) for the VO. Utilizing pre

- determined standing areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Fl ight Instruction

Title 14, Part 91, Section 91.109 of the Code of Federal Regulations states;

(a) 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 d ual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has de termined that the flight can be conducted safely; and

(2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control whe el that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by§ 61.56 of this chapter, or to ob tain recent flight experience or an instrument proficiency check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The p ilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b) , and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be condu cted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless

—
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraf t, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- enginePETITIONER

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– DMZ Marketing, LLC. 36

airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual
controls of the elev ator and ailerons, when

—
(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(d) No person may o perate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in
command of the aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor of pr evious Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 14 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permi t, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another air craft the right

of

- way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well
clear.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of previous Exemptions whic h contained a request for exemption from this rule, including Exemption #11238. For the reasons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner th at they be exempt from 14 C.F.R. 91.113(b). Due to the fact that all the Petitioner’s sUAS operations will take place under the guidance of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operation s offer an equivalent level of safety as is provided by the existing rule.



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

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 37

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a ci ty, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surfa ce, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the ope ration is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any route s or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Conditions #3, 6, 25, 26, 28 , 29, and 34 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Conditions #3, 6, 25, 26, 28, 29, and 34 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with equivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousands of pounds, carries flammable fuel, an d is powered by a combustion engine. Clearly, carrying out a mission utilizing a sUAS would provide for a safer operation than would a
conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Settings

Title 14, Part 91, Section 91.121 o f the Code of Federal Regulations states;

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL , to

—
(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 38 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter set ting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to th e current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 2 6.92 3,000

Proposed Condition #3 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft wasPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 39

operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altitude
read

- out. For the reasons stated in Condition #3 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,
GPS

- Altitude, read

- out on each flight, they are operating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3, each flight conducted by the Petitioner will begin with a zero

- altitude start point.



### 14 C.F.R. 91.151(a) : Fuel Requirements for VFR Flight Conditions

Title 1 4, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may begin 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 inten ded 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.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clea rly, a percent battery life remaining is a better measure for safety when using a sUAS because the current battery capacities achieved by these types of v ehicles (including all the sUAS proposed in this Petition for Exemption) often do not allow for flight times of over 25 minutes, which is
far less than even the reserve time limits mandated by 14 C.F.R. 91.151(a). For the reasons stated in Condition #17 (“ Proposed Conditions of the Exemption ”) above, it is the be lief of the Petitioner that they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of safety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Requir ed

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness cert ificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appropriate sections of the air
carrier manual r equired by parts 121 and 135 of this chapter containing that portion of thePETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 40

operations specifications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapt er

. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in§ 47.31(c) , or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a)
of t his section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of p revious Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a request for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed t o manned aircraft. This paperwork may be in
hard

- copy form or available through a link on the internet, such as a Google Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipment and Use

Title 14, Part 91, Section 91.2 15 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter , ATC transponder equipment installed must meet the performance and environmental requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74c (Mode A with altitude reporting capabilit y) as appropriate, or the appropriate class of TSO

- C112 (Mode S).

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless tha t aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the cod e specified by ATC and intermode and Mode S interrogations in accordance with the applicable provisions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100

- foot increments. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical mile s of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 feet MSL;PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 41

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally certificated with an engine

- driven electrical system or wh ich has not subsequently been certified with such a system installed, balloon or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceil ing and within the lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or whic h has not subsequently been certified with such a system installed, balloon, or glider

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the sur face; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- nautical

- mile radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder
maint ained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating trans ponder but without operating automatic pressure altitude repo rting equipment having a Mode C apability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be
made at least one hour before t he proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements contained in an
ATO

- Issued COA, the Petitio ner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with reporting standards as set forth in the rule.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 42



### 14 C.F.R. 91.403 : General

Title 14, Part 91, Section 91.403 of the Code of Federal Reg ulations states;

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions
for continued a irworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set fo rth in an operations specification approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supple mental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by fol lowing the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.405(a) : Mainten ance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, ex cept as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditio ns the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 43



### 14 C.F.R. 91.407(a)(1) : Operation after Maintenance or Alteration

Titl e 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—
(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is

pr ovided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) E xcept as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for

return to serv ice by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, Part 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;

(a) Except for work performed in accordance with§§ 91.411 and 91.413 , each registered owner or operator shall keep t he following records for the periods specified in paragraph (b) of this section:PETITIONER

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– DMZ Marketing, LLC. 44

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as approp riate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft.
The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return
to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engin e, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required
to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable ai rworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is require d.

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section s hall be retained and transferred
with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approv ed for return to service.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 45



## Privacy

When discussing the use of s mall Unmanned Aerial Vehicles, the question of privacy frequently comes up. The reason for this is clear as small unmanned aircra ft, despite their incredible uses as a tool, also have the potential to be used for nefarious activities, such as spying for example. This presents a risk to the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that would comprise someone’s privacy. Due to these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft responsibly and focus on mitigating any of the potential privacy risks their aircraft creates. The Petitioner is particularly aware of the privacy concerns of individuals and due to this is extremely focused on providing privacy not only for individuals, but also for customers.



## Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exemptions there are three main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must submit a request for exemption from a rule o r set of rules contained in 14

C

. F

. R

. that the Petitioner believe s will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from which the Petitioner is seeking a n exemption, and;

3. Th e Petitioner’s request must be in the Public Interest.

To satisfy these main guidelines, the following information will cover the justification of the proposed commercial operations under Section 333 requested by this Petition. More clearly, the following arguments will show how each of the proposed applications/use

- cases are in the public interest and promote safety.

Specifically, the sUAS flights proposed in this petition will increase safety for the following applications; Cinematography, Construction Observation, Land Inspection, Real Estate, and Search and Rescue. Furthermore, it wi ll be seen that the use of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved because of the lo wer risks associated with a small, plastic, battery

- powered sUAS, as compa red to a manned, multi

- thousand

- pound, combustion

engine

- powered, flammable

- fuel

- carrying aircraft. Plus, with most sUAS data capture happening at low altitudes, because of the enha nced da ta resolution possible at low altitudes, customers of sUAS services are getting better, more accurate data, while at the same time the public is avoiding the potentially hazardous practice of ultra

- low

- flying manned aircraft. Clearly, the combinati on of better, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable commercial operation that promotes the public interest. Evidence of this can be found in the industry

specific examples below

.PETITIONER

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– DMZ Marketing, LLC. 46

In addition to the aforementioned safety benefits and promotion of public interest s, it should also be noted that all the sUAS aircraft utilized by the Petitioner satisfy the directives passed to the Federal
Aviation Administratio n by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabilities, proximity to airports, proximity to populated areas, and visual line of sight rules and requirements laid out by Congress. Furthermore, due to the FAA precedent of requiring, at minimum, a Sport Pilot’s Certificate, the FAA can be assured that all commercial flights proposed in this Petition do not pose a threat to National Security as all PIC’s will have already been vetted by the Department of Homeland Security. For these reasons and for the numerous arguments contained herein, this Petition for Exemption provides strong justification for approval of commercial operations for the above

- stated sUAS in the above

- stated applications and use

cases under Section 333, pursuant to the operating procedures and requirements described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUA S flights into the National Airspace System. With this initiative it is definitive that Congress believ es that the integration of commercial sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representativ es of the public assigned with the duty of driving policy that promotes the Public Interest. Thus, in addition to the industry

specific examples below, it should also be considered t hat the integration of all sUAS , pursuant to their safe integration to th e NAS and providing of at least an equivalent level of safety as is provided by the current FAA rules, is inherently within the public interest.

Please look below to find more detailed descriptions as to why each of the applications highlighted

a bove can provide a benefit to the public as a whole and r easons why the exemption would not adversely affect safe ty

.



### Cinematography

The Aerial Cinematogr aphy Industry is an industry that has been operating for many years to capture
cinema

- quality footage from low altitudes. Initially

, this type of cinematography was captured using fixed wings and helicopters, but in more recent years, the busines s has sta rted to utilize UAVs. The reason the industry has transitioned to these small aircraft is because newer UAV systems have been able to capture the quality video the industry is looking for but at a much lower cost and with significantly lower risks.

One of the reasons manned aircraft cinematography is so expensive is because of the dangers associated with flying a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes and over people. The insurance costs alone for these types of activities are high and accidents have happened in the industry. Some of these accidents have even lead t o casualties. Recently, 10 people died when two helicopters crashed while filming the French Realty Show, “Dropped.” 13 Whenever y ou have manned aircraft operating at low altitudes there are added risks. These risks include ground structures, confined spaces, and more. Additionally, when you have manned aircraft, any accidents are much more catastrophic than if you had the same sit uation with unmanned aircraft. Once again, this is because of the size and flammable fuel carried on

- board manned aircraft. APETITIONER

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small Unmanned Aircraft does not have these attributes, plus, because there are no people on board,
the chances of causa lities i s lower because there are no pilot s

. It is important to remember that the weight of the UAVs utilized by the Petiti oner will be no more than
10 pounds and contain no crew, flammable fuel, or combustion engine. This limited weight and size will significa ntly reduce the potential for casualties or mass property damage in the case of a crash. Furthermore, the use of electric power by the Petitioner’s UAVs is much more environmentally

- friendly than that of a manned aircraft, which is carrying a significant amount of unnecessary weight using
carbon

- based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performing aerial cinematography, there is also the added public benefit of a healthier environment.

Furthermore, while tra ditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and property, it should be pointed out that a UAV is even safer than the traditional methods because of the limited size, weight, speed, operating condi tions, and safety features included on the proposed aircraft within this petition. Additionally, as is highlighted in the FAA Modernization and Reform Act of 2012, the integration of UAS into the National Airspace System is inherently in the public intere st so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the utilization of sUAS in the Aerial Cinematography Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– Aerial Cinematography is an industry that requires repetitive flights. There are often multiple takes of the same s cene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to occur several times in a short time period. This isn’t necessarily efficient for a manned aircraft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in between shots and use significantly less power. Plus, because of the inherent risks of flying at low altitudes for manned aircraft (structures, people, ob stacles, etc.), repetitive shots require repetitive risky flight operations.

 Dangerous

– Aerial Cinematography is almost always done at very low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consid er at low altitudes and less margin for error. Therefore

, aerial cinematography flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned cra ft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a
crash.

 Dirty

– Some aerial cinematography is extreme in nature and may include things like airborne obstacles. While the Petitioner’s UAV syst em would be maintaining a safe distance from this hazardous environment and remaining within line of sight, it is important to consider that unpredictable accidents can happen in which a bird might fly into a prop as anPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 48 example. In this situation it would obviously be better to have a small unmanned craft than a large, manned aircraft, carrying a pilot and flammable fuel. As was seen in the Miracle on the Hudson Incident, birds can have a devastating effect on an aircraft if they damage a prop or get suck ed into an engine.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned aircraft can perform, such as flying in extremely close proximity to structures or other obstacles at low speeds. This type of application would be im possible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in
the Aerial Cinemat ography Industry as being within the public interest.

 Exemption Numbers:

o 11540

o 11153

o 12031



### Construction Observation

Construction Observation is a vital part of an overall construction job, particularly for a busines s like C2 Collaborative which provides services throughout the construction process from design to completion.
Construction Obs ervation involves onsite visits by architects and engineers to ensure construction
materials and installations are in accordance with the construction documents and specifications developed by the Petitioner. The advantage a UAV can provide in this application is giving the Petitioner an aerial vantage point fr om which to observe a construction job

- site. This elevated view can help put the entirety of the pr oject into perspective and h elp show progress as the project continues.

Furthermore, with more advanced features of their UAV system, the Petitioner may conduct aerial mapping of their job

- sites in order to further document the site and how it is coming along. Plus, with the ability to 3D map and georeference all the imagery, the Petitioner can utilize their UAV system to
h elp better observe the job

- site and use too l s t o analyze if the project is being developed as planned.

As an example, stitch ed, georeferenced imagery from the Petitioner ’ s UAV cou ld be used to develop an
orthomosaic of the jo b

- site. This could be a powerful asset because the finalized image could be utilized in construction software as a Shap e File and i t could be measured using v arious measuring tools. So, for example, if the Petitioner wanted to double check the dimensions of a particular feature within their job

- site, they could simply measure the area using t heir georeferenced image because the image resolution could be as accurate as 1 inch to the pixel. This ab ility really shows the power of aerialPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 49

mapping with a UAV system because the Petitioner could create these georeferenced maps quickly and

on

- demand using a UAV system.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to use UAV technologies in the Construction Observation Industry. Due to the fact th e Petitioner currently provides Construction Observation Services, the utilization of a UAV system would com plement their curre nt services and
serve as an additional tool in their observation toolbox. The Petitioner seeks this exemption because they believe the use of unmanned aircraft in this industry will provide a public good while maintaining the safety of the National Airspace System.

Furthermore, utilizing a UAV for this type of work is a sa fer alternative when compared to manned aircraft. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like are greatest. A manned aircraft is not as well
suit ed for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide va lue in terms of cost savings and enhanced safety to the Construction Observation Industry.

On top of this, the utilization of sUAS in this Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Construction Observation Industry is an industry that requires dull flights. Often, especially w hen doing any mapping, a pilot must fly his plane over a specific area of interest in a very specific and straight line pattern. This is to ensure comp lete coverage of the job

- site . This
causes the pilot to fly the same straight

- line routes, one next to the other, over and over. The sUAS used by the Petitioner however has the ability to utilize preprogrammed flight routes, which can automate the process and allow for safer operations.

 Dangerous

– Aerial Construction Observation Imagery is of ten captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for err or. Therefore, Construction Observation flights using manned aircraft are more dangerous tha n if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs signifi cantly less and doesn’t carry a crew or flammable fuel.

 Deep

– Some Construction Observation imaging may require capabilities that only an unmanned aircraft can perform, such as flying in clo se proximity to construction equipment or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of s UAS use in the Construction Observation/Monitor ing Industry as being within the public interest.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 50

 Exemption Number:

o 14068



### Land Inspection

The Land Information Industry is an industry poised to gain a lot from the utilization of sUAS aircraft. The aerial perspecti ve these units can provide to an architech, designer, landscaper, land surveyor

, or developer, is enormous. Land Information covers a broad range of land evaluation applications. One of the main applications that is currently being used is stitched, 3D mapping, which allows for operators to visualize a landscape in highly accurate 3D form. This allows for accuracy in the centimeter range, which can help land manage rs determine tile lines in agriculture, engineers develop drainage ditches for streams, planning commissions create plat maps for new developments, and architects design new building construction.

All of these applications are in the public interest. A la nd manager putting in tile lines in his agricultural fields helps quell runoff and erosion issues, which leads to higher yields, a healthier environment, and less pollution in our waterways. Additionally, the engineer who is developing drainage paths and ditches based on 3D mapping from a sUAS is going to prevent large

- scale flooding, which reduces damages to surrounding communities and, in turn, lowers insurance premiums for the country as a whole. In much the same way, planning commissions creating maps and running lines into a new development helps foster community growth and ensures the right amount of infrastructure for the community. Finally, the architect designing a new building will be better able to place that building on solid ground and allow it to better fit in the surrounding landscape. This helps ensure the safety of the building while also ensuring the community looks nice.

Referring back to the 4

- D analysis of UAV use, it is clear that the Land Information Services Industry has many appli cations of data capture that point to the use of UAV systems over manned aircraft because;

 Dull

– Land Information Flights may require a lot of repetition and/or rapid deployment of a data capture device to ensure data is captured at the right time. As an example, pertaining to construction observation, the Petitioner may image and map a particular project multiple times over a project's construction timeline

. This would be to ensure construction is moving along as planned and the designs are being follow ed. Rather than renting a plane over and over, the Petitioner may fly their UAV system over their project sites, which would be much more efficient
from a cost

- standpoint and allow for more detailed site observation.

 Dangerous

– Many of the flights conducted by the Petitioner may take place in or around active construction sites. Construction sites can be dangerous and it is for this reason that hardhats are often required and other safety regulations are in place. In order to get high definition imagery of the site, the Petitioner will be flying low to the ground and potentially around structures and in confined spaces, which is dangerous airspace for a manned aircraft.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 51

 Dirty

– Land Information flights by nature may occur in hazardous environm ents. A lot of the 3D mapping missions conducted in this in dustry are done in areas of topography, which can be
hazardous for manned aircraft at low altitudes.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes

. This is true in the Land Information Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas can be impossible for manned aircra ft as their maneuverability is such that the confined area is too small for safe flight.

Therefore, the promotion of the public interest described above coupled with the enhanced safety provided by sUAS flights in the Land Information Industry, strongl y supports the granting of this petition.

Furthermore, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in Land Information/Management Industry as being within the public interest.

 Exemption Numbers:

o 11109

o 11204

o 11286



### Real Estate

The Real Estate Industry was one of the first industries to be granted an Exemption under Section 333.
One of the reasons for this is the obvious benefit the utilization of a small unmanned aircraft can provide for the purposes of property and home sales. The ability to gain an aerial perspective of a property or house allows potential buyers a way of seeing the property in its enti rety. When thinking about traditional real estate listings, there are often a series of photographs of the house or property, and its surroundings. However, these pictures are not necessarily congruent, meaning, you, as a buyer, can’t put one picture wit h the next picture and get a walk around of the property.

Furthermore, aerial cinematography for real estate has existed for many years, however it has previously been accomplished using manned fixed wing or helicopter aircraft. The expense of utilizing this form of cinematography is extremely costly and prices many realtors , architechs, designers, and homeowners out of this form of marketing. However, this form of marketing is very valuable and would
like ly be used by more people if the economics made sense

. Additionally, utilizing manned aircraft to capture the type of aerial marketing possible with a sUAS poses significant threats and problems to a community. Obviously

, a low flying plane or helicopter would supply significant noise and annoyance a mong neighbors of a home being videoed from a plane or helicopter. It is for this reason that there are noise ordinances across the country pertaining to manned aircraft. Obviously, a light

- weight sUAS will produce much less noise than a helicopter or pl ane operating at low altitudes. Furthermore, there is also substantially less risk associated with a sUASPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 52

performing a low

- altitude real estate flight, especially in populated neighborhoods. This is the case because if a manned aircraft goes down in a po pulated neighborhood there will likely be fatalities or significant damage to the plane and crash site. A sUAS on the other hand would likely cause little damage in the case of a catastrophic crash. Plus, because the sUAS proposed in this petition do not carry combustible fuel, the after

- effect damage is far less as well because there isn’t a risk of a fuel tank exploding or starting on fire.

Furthermore, when looking back at the 4D’s of UAV Use, it is clear that Real Estate photography and cinematograph y using small unmanned aircraft fits the 4D’s.

 Dull

– Real Estate flights for aerial cinematography are a sUAS use

- case marked by repetition
and on

- demand access. More clearly, homes and commercial property may need to be flown multiple times and on

- dem and. The key to a good real estate video is that it nicely highlights the features of the real estate being filmed and does so in good lighting conditions. Lighting conditions change constantly and it is best if you can adapt to the lighting and fly at t he perfect time in the perfect weather to get the best footage. This may mean waiting for 5 or 10 minutes for a cloud to pass through. With a manned aircraft

, this is expensive to do. Plus, with many private pilots renting their aircraft, it would be ha rd to anticipate what time to rent the plane in order to have it in position at the perfect time.

 Dangerous

– Real Estate flights using manned aircraft would be highly dangerous in comparison
to unmanned aircraft. The reason for this is because mo st flights take place low to the ground, right above houses and many times above highly populated neighborhoods. An accident with a manned aircraft in these conditions could be catastrophic, with potentially many casualties and a lot of property damage. An unmanned craft, like the ones described in this petition, would cause much less damage in the case of an accid ent, as they are small, battery

- powered, and weigh under 10 lbs.

 Dirty

– Commercial UAV flights in the real estate industry can also be d irty, in that they can take place in potentially hazardous environments. Commercial real estate in particular, in which large factories or plants may be being sold, could pose hazardous environments that are best filmed by sUAS aircraft so as to not expos e humans to hazardous waste, gases, or materials for example. Furthermore, decrepit or abandoned buildings that are dangerous to walk through or near, may be best flown using an unmanned aircraft.

 Deep

– Once again, sUAS allow for operators to capture h igh resolution data at low altitudes. This is true in the Real Estate Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas, suc h as in neighborhoods as an example, can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 53

Finally, because the proposed sUAS contained in this Petition are battery

- powered, they do not release environmentally hazardous emissions. Thus, utilizing these micro

- UAVs in place of manned aircraft benefits the public by promoting a healthier environment.

By granting this Petition for Exemption and allowing commercial sUAS flights in the Real Estate Industry, the FAA will be contributing to economic growth by supporting the housing industry and commercial real estate industry, thereby strengthening the economy. Furthermore, all of this can be done by maintaining the safety of the National Airspace and people & property on the ground.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Real Estate Industry as being within the public interest.

 Exemption Numbers:

o 11062

o 11109

o 11112

o 11213

o 11364



### Search and Rescue

The Search and Rescue Industry is an industry in which small unmanned aircraft will play a vital role moving forw ard. This industry is known for its rapid response times which are needed in order to save lives. Furthermore, the situations and environments common in this industry require documented visual observance over broad areas. Currently, much of this is done using aerial imaging from a manned aircraft. The imagery captured on these flights is vital not only when it comes to finding lost people but also in documenting areas that have already been searched. In a searching effort this is important
because sea rchers don’t want to waste time looking in areas that have already been searched. Utilizing a UAV allows for searchers to get an aerial vantage point as well as document areas that have been searched accurately. For instance, a search crew could map the areas of interest using their UAV, stitching the images they get from the camera and have a georeferenced map of the area in question. In most cases this map is laid over Google Earth and can clearly mark an area that has already been
searched. Additiona lly, because the map is georeferenced, the user can pinpoint locations or objects of interest and pull a latitude and longitude for a more detailed search. This is a highly valuable attribute of stitched imagery from a UAV.

In addition, a UAV can provide a superior vantage point for searchers operating on the ground. The UAV utilized by the Petitioner offers long

- range, high definition FPV which can be used by a team leader to relay to his ground searchers where to move next and if he sees anything of in terest from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Search and Rescue Industry in order to help in situations where a visual inspection from the air isPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 54

necessary. The Petitioner seeks this exemption because they believe the use of unmanned aircraft in this industry will provide a public good while maintaining the safety of the National Airspace System.

The Petitioner’s UAV is rapidly deployable meaning it can help in time

- sensi tive rescue efforts. Additionally, with its ability to take high definition video and pictures while georeferencing all of its images, the Petitioner’s UAV can be a valuable asset to a Search and Rescue Team. Plus, with the aerial perspective this type o f UAV can provide, the chances of finding a lost or periled individual increase. Clearly, finding and saving lost people is a public good and one that can be bolstered through the use of

a UAV.

Furthermore, utilizing a UAV for this type of work is a sa fer alternative when compared to manned aircraft. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like are greatest. A manned aircraft is not as well
suit ed for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide va lue in terms of cost savings and enhanced safety to the Search and Rescue Industry.

On top of this, the utilization of sUAS in the Search and Rescue Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Search and Rescue Industry is an industry that requires dull flights. Often, especially
with fixed

- wing aircraft, a pilot must fly his plane over a specific area of interest in a very specific and straight line pattern. This is to ensure complete coverage of the search zone. This causes
the pilot to fly the same straight

- line routes, one next to the other, over and over. The “dullness” of this flight might cause a pilot’s m ind to wander which can lead to accidents. The sUAS used by the Petitioner however has the ability to utilize preprogrammed flight routes, which can automate the process and allow for safer operations.

 Dangerous

– Aerial Search and Rescue Imagery is of ten captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Search and Rescue flights using manned aircraft are more dangerous tha n if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs signifi cantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Aerial Search and Rescue Imagery is sometimes captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential
hazards and r emaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. For instance, if a UAV is being used to provide a live

- feed view of a rescue situation, there may be a host of unpredictable hazards such as r ock

- falls, crashingPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 55

waves, avalanches, or the like. In each of these situations it would be better to have an expendable UAV system rather than a manned aircraft with lives onboard.

 Deep

– Some Search and Rescue imaging may require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Search and Rescue Industry as being within the public interest.

 Exemption Number:

o 11419


## Regulations Requested for Exemption

Appendix 1: Regulations Requested for Ex emption

– List

https://drive.google.com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1: C2 Collabora tive Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMVG00Tkt6XzB2TVk/view?usp=sharing



### Exhibit 2: C2 Collaborat ive Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The specific flight logs pictured are just an example and not specific to the Petitioner’s prior flights. In addition to the logb ook, please see the linked video ( https://www.youtube.com/watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utilizing the same logging app for each flight.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 56



### Exhibit 3: C2 Collaborative Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/file/d/0B8skn t2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Visual Observer Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMbElBZTcwUi02aHM/view?usp=sharing



### Exhi bit 4: C2 Collaborative Pilot In Command Training Guide

Pilot In Command Training Procedures

https://drive.google.com/file/d/0B8sk nt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Pilot in Command Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMREF0OHZLZ25Jc2M/view?usp=sharingPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 57



### Exhi bit 5: DJI Phantom 3 Professional

http://www.dji.com/product/phantom

- 3



### Exhibit 6: DJI Phantom 3 Professional User Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf



### Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf



### Exhibit 8: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom

- 3/feature



### Exhibit 9: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 1 0: DJI P hantom 3 Professional Flight Controller System

http://www.dji.com/product/phantom

- 3/flight

- system



### Exhibit 1 1: DJI Phantom 3 Professional Smart Battery Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdfPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 58



### Exhibit 1 2: DJI Phantom 3 Professional Safety /Preflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Exh ibit 1 3: DJI Inspire 1

http://www.dji.com/product/inspire

- 1



### Exhibit 1 4: DJI Inspire 1 User Manual

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf



### Exhibit 1 5: DJI Inspire 1 Quick Start Guide

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf



### Exhibit 1 6: DJI Inspire 1 Features

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 1 7: DJI Inspire 1 Specifications

http://www.dji.com/product/inspire

- 1/spec



### Exhibit 1 8: DJI Inspire 1 Flight Controller System

http://w ww.dji.com/product/inspire

- 1/flight

- control



### Exhibit 1 9: DJI Inspire 1 Smart Battery ManualPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 59

http://download.dji

innovations.com/ downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### E xhibit 2 0: DJI Matrice 100

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 2 1: DJI Matrice 100 User Manual

http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 22 : DJI Matrice 100 F eatures

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/features



### Exhibit 23 : DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/specs



### Exhibit 24 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads/dev/Matrice/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



## References

1.) 

### NTSB. Michael P. Huerta, Administrator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC : National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft Definition.

2.) 

### Administration, Federal Aviation. "FAA Streamlines UAS COAs for Section 333." FAA.gov

.

Federal Aviation Administration, 24 Mar. 2015. Web. 5 Nov. 2015.

3.) 

### Administration, Federa l Aviation. "Section 333 Petition Guidance & Checklist." (n.d.): n.PETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 60 

### pag. FAA.gov . Federal Aviation Administration. Web. Conditions for a successful Exemption.

4.) 

### Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft

Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland:

w ww.mdpi.com/journal/remotesensing, 8 June 2012. PDF. "D's" of Unmanned
Aircraft Use.

5.) 

### SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety. N.p., n .d. Web.

20 July 2015.

6.) 

### Administration, Federal Aviation. "Public Guidance for Petitions for Exemption under

Section 333." FAA.gov . Federal Av iation Administration, n.d. Web.

7.) 

### "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptio ns. Federal Aviation Administration, n.d. Web. 20 July 2015. Permitting Recreational and Sport Pilot Certificates.

8.) 

### FAR Part 91

- Basic VFR Weather Minimums, Code of Federal Regulations § 91.155

(2004). Print.

9.) 

### Administration, Transportation Security. "Ve tting of Airmen Certificates and General

Aviation Airport Access and Security Procedures." Department of Homeland Security . Office of Inspector General, 7 July 2011. Web. 5 Nov. 2015.

10.) 

### MacPherson, Rebecca B. "U.S. DOT / FAA

- Office of the Chief Counsel." Letter to Mr.

Timothy John Gilbert. 25 Feb. 2011. MS. 800 Independence Ave. S.W., Washington, DC, Maryland. Clarification on "Furtherance of a business."

11.) 

### Federal Aviation Administration . "Exemption No. 11062A Regulatory Docket No. FAA

2014

- 0352." Depar tment of T ransportation, 23 July 2015. PDF

.

12.) 

### Jensen, Warren, PhD. Ground

- Based Visual Observer/Crewmember Training for UAS

.

New York, NY: Slideserve.com, 9 July 2008. PPT. Visual Observer and Pilot In Command Training Guidance and Format.

13.) 

### "Olympic Medal ists among 10 Dead as Reality TV Choppers Collide." NBC News . NBC,

n.d. Web. 20 July 2015.


## Exemption ReferencesPETITIONER

– C2 Collaborative DOCUMENT PREPARER

– DMZ Marketing, LLC. 61



### Exemption # 11467

Exemption # 11905

Exemption # 11797

Exemption # 12031

Exemption # 11865

Exemption # 11364

Exemption # 11587

Exemption # 11857

Exemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 11345