Delta Media Corporation

3501 NW Evangeline THWY

Carencro, LA. 70520

March 27, 2015 

Matthew LeBlanc

Delta Media Corporation

3501 NW Evangeline THWY

Carencro, LA. 70520

Dear Sir or Madam

We are requesting that Delta Media Corporation be exempted from the Federal Aviation Regulations 

listed below so that Delta Media Corporation may integrate small unmanned aircraft commercially in 

airspace regulated by the Federal Aviation Administration as long as operations are conducted within 

the conditions established by the FAA as required by section 333. The exemptions are proposed for 

the use of a DJI Inspire 1 (Model T600). 

Specications of UAS

Weight (Battery Included) 

	 	 2935g (6.47lbs)

Hovering Accuracy (Gps Mode) 

	 	 Vertical: 0.5 m 

	 	 Horizontal: 2.5 m 

Max Ascent Speed 

	 	 5 m/s 

Max Descent Speed 

	 	 4 m/s 

Max Speed 

	 	 22 m/s (ATTI mode, no wind) 

Max Flight Altitude 

	 	 4500 m 

Max Wind Speed Resistance 

	 	 10 m/s 

Max Flight Time 

	 	 Approximately 18 minutes 

Motor Model 

	 	 DJI 3510 

Propeller Model 

	 	 DJI 1345

Operating Temperature Range 

	 	 -10° to 40° C 

Diagonal Distance 

	 	 559 to 581 mm 

Dimensions 

	 	 438x451x301 mm
Charles Chatelain, is an experienced and proven Television and Radio broadcaster, HAM operator, 

and Licensed Pilot. His company Delta Media Corporation has provided Television and Radio 

production services to south central Louisiana for over 35 years. 

To date, Delta Media Corporation has rejected all offers for commercial UAS use in order to comply 

with any applicable FAA regulation. We have had many requests for aerial photography/

videography, and are very aware that these UAS’s services are currently being provided in our area 

by amateurs without exemption. We understand that the FAA has been inundated with numerous 

exemption requests, as are we with requests for UAS services. We will not provide these services 

without exemption, but we respectfully request exemption so that we can legally compete in our 

marketplace. 

Delta Media Corporations exemption request would permit it’s operation of lightweight unmanned 

(remotely controlled in line of sight) in a controlled and limited airspace. 

Commercial operation of a UAS would be conducted in the following manner 

- Gathering overhead footage for both public and private interests for 	 	

	 	 Television broadcast purposes 

- Aerial video/photography or live video feed to assist with search and rescue 

	 	 operations in cases of an emergency if requested by local or government authorities

	 	 by contract or donation 

- Pre Flight inspection will be conducted by both the PIC and VO, and all repairs and 

	 	 maintenance will be handled by qualified personnel 

- Two persons will operate the UAS at all times. The flight operator (PIC) will be a 

	 	 licensed pilot and will be assisted by a Visual Observer (VO). 

- Flights will be operated within line of sight of the PIC and VO 

- Flights will only be conducted during daylight hours 

- The PIC and VO will be able to communicate by voice at all times 

- All flights will be conducted at an altitude of no more than 200 feet 

- Flights will be conducted no closer than a 5 mile radius of the geographic center 

	 	 (ARP) of an airport. 

- If necessary to conduct operations within a 5 mile radius of ARP the respective 

	 	 airport will be notified of flight time, flight duration, and elevation of flight 

- The operator will obtain verbal/written consent of all persons involved with the 

	 	 planned operation and ensure that only consenting persons will be allowed within 

	 	 100 feet of the flight operation 
- If the UAS loses communications with the remote controller or GPS signal, the UAS 

	 	 will have the capability to return to a pre-determined location and land 	 	

	 	 autonomously 

- The UAS will have the ability to abort a flight in case of unpredictable obstacles, 

	 	 weather, or emergencies

Exemptions requested from the following regulations 

 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 

C.F.R.§91.203(a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size 

and limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas 

of the particular UAS. In all cases, an analysis of these criteria demonstrates that the 

UAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 6.5 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety 

requirements. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that 

there is no credible threat to national security posed by the UAS, due to its size, speed 

of operation, location of operation, lack of explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental 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," "light-sport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAS will see the 

identification of the UAS as “Experimental.” 	 


14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot 

in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a 

pilot in command of an aircraft that is carrying passengers or property for compensation or hire. 

The applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to 

the operation of UAS is far less than the risk levels inherent in the commercial activities outlined 

in 14 CFR 61. The PIC of the UAS will have a Commercial Pilot’s License along with a current 

Second Class or higher Medical exceeding the current safety levels in relation to 14 CFR 61.113 

(a) & (b).

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given 

the size of the aircraft for maintenance and use of safety check lists prior to each flight an 

equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For 

which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. The UAS, given its size 

and configuration has no ability or place to carry such a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or capacity to carry such an 

item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual 

at the ground control point where the pilot flying the UAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions including but not limited to reviewing 
weather, flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that 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 dual 

controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a UAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 200 AGL, or not more than 200 above an elevated platform from which filming is 

planned, an exemption may be needed to allow such operations. As set forth herein, the UAS 

will never operate at higher than 200 AGL with the exception that in circumstances where the 

UAS is used to survey or photograph a structure whose height exceeds 200 feet AGL, the UAS 

will not be operated more than 200 feet above the highest point on the structure. It will however 

be operated in a restricted area with security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in 

the filming activity, all affected individuals will be aware of the planned flight operations. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 

55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 500 

AGL. In addition, the low-altitude operations of the UAS will ensure separation between these 

UAS operations and the operations of conventional aircraft that must comply with Section 

91.119. 

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “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 intended 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.” 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 

30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 

10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of 

its proposed operations within a predetermined area, a longer time frame for flight in daylight or 

twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended 

to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 

minutes would greatly reduce the utility for which the exemption will be granted. Applicant 

believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 

25% of battery power— whichever happens first. This restriction would be more than adequate 

to return the UAS to its planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration

The regulation provides in pertinent part:

(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 certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this 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. 

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections.
These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided 

in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook. An equivalent level of safety will be 

achieved because the UAS is very limited in size and will carry a small payload and operate only 

in restricted areas for a limited period of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 200 feet AGL. The operator will ensure 

that the UAS is in working order prior to initiating flight, perform required maintenance, and keep 

a log of any maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent 

level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, 

the operator will ensure that the UAS is in working order prior to initiating flight and perform 

required maintenance needed. 

Sincerely yours, 

Matthew A LeBlanc