August 27, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of Bardha Air for Grant of Exemption Pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 

FAA Regulatory Docket 

NAME AND ADDRESS OF PETITIONER 

Bardha Air 

ATTN: Ilir Bardha 

3300 Lone Pine Road 

West Bloomfield, MI 48323 

(248) 722-3747 

elebardha@gmail.com 
August 27, 2015 

Page 2 

I. PETITION SUMMARY 

Pursuant to Section 333 of the FAA Modernization and Reform Act 

of 2012, Pub. L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the 

Federal Aviation Administration's ("FAA") general exemption authority 

under 49 U.S.C. § 44701(f), Bardha Air ("Petitioner") hereby petitions 

for exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 61.113(a) and (b), 

61.133(a), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91.151, 

91.203(a) and (b), 91.405(a), 91.407(a)(1) 91.409(a)(2), 91.417(a)-(b). 

The proposed exemptions, if granted, would allow Petitioner to operate 

small, camera-mounted unmanned aircraft systems ("UAS") weighing 

55 pounds or less for the purpose of closed-set filming of motion 

pictures, music videos, web videos, corporate videos,television 

programs and commercials, wedding and entertainment venue videos, 

aerial videography and photography for real estate and still photography. 

Based on the small size of Petitioner's UAS, the qualifications and 

experience of Petitioner's UAS operators, and the restricted, sterile 
August 27, 2015 

Page 3 

enviromnent within which Petitioner will operate, the re quested 

exetnptions fall squarelywithin the zone of safet yenvisioned by 

Congress and set forth in Section 333. Additionall y, the enhanced safet y 

achieved byreplacingsignificantlylarger manned aircraft carryingcrew 

and flammable fuel widi small UAS cart yingno passengers or crew and 

operated under the specific guidelines and procedures proposed b y 

Petitioner gives the FAA good cause to find that the UAS operations 

enabled bythe instant Petition are in the public interest. Because the 

requested exemption would not set precedent, and because an ydelayin 

actingon this Petition would be detrimental to Petitioner, good cause 

exists for grantingthis Petition on an expedited basis pursuant to the 

FAA!s streamlined "SummaryGrant" process. In addition, good cause 

exists for foregoinga published summatyof the petition in the Federal 

Register. Thus, Petitioner respectfWl yrequests that the FAA grant this 

non-precedent settingexemption on an expedited basis. 
August 27, 2015 

Page 4 

H. STATUTORY AUTHORITY 

A. Section 333 

Section 333, titled "Special Rules for Certain Unmanned 

Aircraft Systems," provides a mechanism for seekin gexpedited FAA 

audiorization of safe civil UAS operations in the National Airspace 

System ("NAS"). Section 333(a) states that the FAA "shall determine if 

certain unmanned aircraft s ystems mayoperate safelyin the national 

airspace system before completion of the [comprehensive] plan and rule 

makingrequired bysection 332(b)(1) of this Act or the guidance 

required bysection 334 of this Act." In Section 332(b)(1), Con gress 

made it clear that Section 333 provides a mechanism for "expedited 

operational authorization." The FAA has committed to compl yingwith 

this mandate by grantingseveral petitions almost identical to the one at 

hand. See, e.g., Exemption No. 11062, RegulatoryDocket No. 

FAA-2014-03 52 (grantingregulatoryexemptions to Astraeus Aerial for 
August 27, 2015 

Page 5 

operation of unmanticd aircraft s ystems for the purpose of filmin gfor 

the motion picture and television industry). 

Section 333(b) identifies several factors that the FAA should 

consider in determiningwhether commercial UAS operations should be 

approved. These include UAS that, "as a result of their size, wei ght, 

speed, operational capabilit y, proximityto airports and populated areas, 

and operation within visual line of si ght do not create a hazard to users 

of the (NAS) or the public or pose a direat to national securit y." See 

Section 333(b). 

B. Section 4470 1 (f) 

In addition to the specific authorit yconfeffed bySection 333, 

the FAA Administrator has general authorityto grant exemptions from 

the FAMs safetyregulations and minimum standards when the 

Administrator decides a re quested exemption is in the public interest. 

See U.S.C. § 44701(f). 
August 27, 2015 

Page 6 

III. REQUESTED EXEMPTIONS 

Petitioner requests relief from the followin gregulations: 

Part 21 prescribes, in pertinent part, the procedural re quirements 

for issuingand changingdesign approvals, production approvals, 

airworthiness certificates, and airworthiness approvals. 

Section 61.113 prescribes that "no person who holds a private pilot 

certificate ma yact as a pilot in command of an aircraft that is can ying 

passengers or propertyfor compensation or hire ;nor maythat person, 

for compensation or hire, act as pilot in command of an aircraft," 

(see Section 61.113 (a)), and that "a private pilot ma y, for compensation 

or hire, act as pilot in command of an aircraft in connection with an y 

business or employtnent if: ( 1) The flight is onlyincidental to that 

business or employtnent;and (2)The aircraft does not carr ypassengers 

or propertyfor compensation or hire," (see Section 61.113(b)). 
August 27, 2015 

Page 7 

Section 61.133(a) sets forth privile ges for persons holding 

commercial pilot certificates, includin ga provision impliedlylimitingto 

persons holdinga commercial pilot certificate the abilit yto act as pilot 

in command of an aircraft "[flor compensation or hire." 

Section 91.7(a) prescribes, in pertinent part, that no person ma y 

operate a civil aircraft unless it is in an airworth ycondition. 

Section 91.9(b)(2)prohibits operation of U.S. registered civil 

aircraft unless there is available in the aircraft a current approved 

Airplane or Rotorcraft Fli ght Manual, approved manual material, 

markings, and placards, or anycombination thereof 

Section 91.103 (b)(1) prescribes, in pertinent part, that each pilot in 

command shall, before be ginninga flight, become familiar with all 

available infortnation concernin gthat flight, to include, "For anyflight, 

runwaylengths at airports of intended use, and the followin gtakeoff and 

landingdistance infortnation: ... For civil aircraft for which an approved 

Airplane or Rotorcraft Fli ght Manual containingtakeoff and landing 
August 27, 2015 

Page 8 

distance data is required, the takcoff atid latiditi gdistaticc data cotitaiticd 

therein." 

Section 91.119(c) prescribes that, except when necessar yfor 

takeoff or landing, no person mayoperate an aircraft below the 

followingaltitudes: "Over other than con gested areas. An altitude of 500 

feet above the surface, except over open water or sparsel ypopulated 

areas. In those cases, the aircraft ma ynot be operated closer than 500 

feet to anyperson, vessel, vehicle, or structttre." 

Section 91.121 requires, in pertinent part, each person operatin gan 

aircraft to maintain cruisin galtitude byreference to an altimeter that is 

set 'lo the elevation of the departure airport or an appropriate altimeter 

settingavailable before departure." 

Section 91.151 (a) prescribes that no person ma ybegin a flight in 

an airplane under VFR conditions unless (considerin gwind and forecast 

weadier conditions) there is enou gh fuel to flyto the first point of 

intended landingand, assumingnormal cruisingspeed, (1) duringthe 
August 27, 2015 

Page 9 

day, to fl yafter that for at least 30 miiitites; or (2) at night, to fl yafter 

that for at least 45 minutes. 

Section 91.203 prohibits, in subpart (a), anyperson from operatin g 

a civil aircraft unless it has within it (1 )an appropriate and current 

airworthiness certificate ;and (2)an effective U.S. registration certificate 

issued to its owner or, for operation within the United States, the second 

copyof the Aircraft Re gistration Application as provided for in § 

47.31(c). 

Section 91.203 prescribes, in subpart (b), that no person may 

operate a civil aircraft unless the airworthiness certificate or a special 

flight authorization issued under § 91.715 is displa yed at the cabin or 

cockpit entrance so that it is le gible to passengers or crew. 

Section 91.405(a) requires, in pertinent part, that an aircraft 

operator or owner shall have the aircraft inspected as prescribed in 

subpart E of the same part and shall, between re quired inspections, 

except as provided in para graph (c) of the same section, have 
August 27, 2015 

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discrepancies repaired as prescribed in Part 43 of the chapter. 

Section 91.407(a)(1) prohibits, in pertinent part, an yperson from 

operatingan aircraft that has under gone maintenance, preventative 

maintenance, rebuildin g, or alteration unless it has been approved for 

return to service bya person audiorized under § 43.7 of the same 

chapter. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person 

mayoperate an aircraft unless, within the precedin g12 calendar months, 

it has had an inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that - 

(a) Each registered owner or operator shall keep the 

followingrecords for the periods specified in para graph (b) of 

this section: 

( 1) Records of the maintenance, preventative 
Atigust 27, 2015 

Page 11 

inaintenance, and alteration and records of the 100-hour, annual, 

progressive, and other re quired or approved inspections, as appropriate, 

for each aircraft (includingthe airframe) and each en gine, 

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 

approvingthe aircraft for return to service. 

(2) Records containingthe followinginforination: 

(i) The total time in service of the airframe, each en gine, 

each propeller, and each rotor. 

(ii) The current status of life-limited parts of each 

airframe, engine, propeller, rotor, and appliance. 
August 27, 2015 

Page 12 

(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 cun•ent inspection status of the aircraft, includin g 

the time since the last inspection re quired bythe inspection 

program under which the aircraft and its appliances are 

maintained. 

(v) The current status of applicable airworthiness 

directives (AD) and safet ydirectives including, for 

each, the method of compliance, the AD or safet y 

directive number and revisions date. If the AD or 

safetydirective involves recurrin gaction, the time 

and date when the next action is re quired. 

(vi) Copies of the forms prescribed b y§ 43.9(d) of this 

chapter for each major alteration to the airframe and 

cuffentlyinstalled engines, rotors, propellers, and appliances. 
August 27, 2015 

Page 13 

( b)The owner or operator shall retain the followingrecords 

l'or the periods prescribed: 

(1) The records specified in para graph (a)(1) of this section 

shall be retained until the work is repeated or superseded b y 

other work or for I year after the work is perforined. 

(2) The records specified in para graph (a)(2) of this section 

shall be retained and transferred with aircraft at the time the 

aircraft is sold. 

(3) A list of defects fumished to a re gistered owner or 

operator under § 43.11 of this chapter shall be retained until 

the defects are repaired and the aircraft is approved for return 

IV. PETITIONER'S PROPOSED OPERATIONS SATISFY SECTION 

A. Unmanned Aircraft S ystem 

The UAS to be operated undcr this rc qucst arc Icss than 55 lbs. 
August 27, 2015 

Page 14 

fullyloaded, will be operated at a speed of no more than 50 knots, carr y 

neither a pilot nor passenger, carryno explosive materials or flainmable 

liquids, and operate exclusivel ywithin a secured area. 

Petitioner's UAS use a radio fre quencyspectrum for operation and 

control that complies with Federal Communications Commission 

("FCC") requirements, and Petitioner has inte grated safetyfeatures into 

the UAS, as described in Petitioner's Fli ght Operations and Procedures 

Manual ("FOPM") and Motion Picture and Television Fli ght Operation 

Manual ("MPTFOM") (collectivel y, "operations manuals" ).' 

Petitioner's UAS are e quipped with redundant safet ymechanisms 

allowingthetn to operate safel yafter experiencingcertain in-flight 

failures. If a lost-link event occurs, includin gthe loss of ground 

I The MPTFOM and FOPM will be submitted separatel yand confidentiallyunder 14 

C.F.R. 11.35(b), as the manuals contain proprietar yinformation that the applicant has not 

and will not share with others. The manuals contain operatingconditions and procedures 

that are not available to die public and are protected from release under the Freedom of 

InforFnation Act, 5 U.S.C. §§ 552, et seq. 
August 27, 2015 

Page 15 

communications and/or the loss of a GPS si gnal, Petitioner's UAS have 

the abilityto perform a pre-coordinated, predictable, automated fli ght 

maneuver and return to a predeterinined location within a desi gnated 

securityperimeter for landin g. 

The UAS fi► iher have the abilityto abort a flight in the event of 

unpredieted obstacles or einer gencies. All flights will be terminated after 

a maximum of 30 minutes or with 25% remainin gbatterypower, 

whichever occurs first. Thus, good cause exists for grantingPetitioner's 

requested relief from 14 C.F.R. § 91.151(a) (settin gforth fuel 

requirements for flight in VFR conditions). 

Petitioner's UAS will be identified b yserial number, registered in 

accordance with 14 C.F.R. Part 47, and have identification (N-Number) 

markings in accordance with 14 C.F.R. Part 45, Subpart C. Markin gs 

will be as large as practicable. 
August 27, 2015 

Page 16 

RegardingPetitioner's requested relief from 14 C.F.R. § 91.121 

(Altimeter Settings), Petitioner seeks such relief because Petitioner will 

not have a typical barometric altimeter onboard the UAS. Instead, 

altitude inforination will be provided to the UAS PIC via a di gitally 

encoded telemetric data feed, which downlinks from the aircraft to a 

ground-based on-screen displa y. The altitude information will be 

generated byequipment installed onboard the UAS, usin gGPS 

txiangulation, digitallyencoded barometric altimeter, radio altimeter, or 

anycombination thereof Prior to each fli ght, a zero altitude initiation 

point will be established and confirmed for accurac ybythe UAS PIC. 

Thus, good cause exists for grantingthe requested relief from 14 C.F.R. 

§ 91.121. 

Given the size, wei ght, speed, and limited operatin garea 

associated with the aircraft to be utilized b ythe applicant, an exemption 
Atigust 24,2015 

Page 17 

from 14 C.F.R. Part 21, Subpart H (Airworthiness Certificates), subject 

to certain conditions and limitations, is waffanted (if necessat y) and 

meets the re quiretnents for an equivalent level of safetyunder 14 C.F.R. 

Part 11 and Section 333. The UAS operated without an airwordliness 

certificate in the restricted environment and under the conditions and 

limitations proposed byPetitioner will be at least as safe, or safer, than a 

conventional aircraft (fixed win gor rotorcraft) operatingwith an 

airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and 

not subject to the proposed limitations and conditions. 

Petitioner will strictlycomplywith safetyand maintenance 

procedures included in all applicable UAS manufacturer's instructions 

and operatingmanuals. To the extent such infortnation is not included in 

the guidelines developed b ythe manufacturers, Petitioners will develop 

and document maintenance, overhaul, replacement, and inspection 

requirements, procedures to document and maintain maintenance 

records with regard to Petitioner's UAS, and UAS technician 
August 27, 2015 

Page 18 

qualification criteria. Petitioner's operations manuals will include 

maintenance requirements for Petitioner's UAS, includin g"onconditiote' maintenance and modifications. In li ght of these mitigating 

factors, exemptions from 14 C.F.R. §§ 91.405(a ), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b) are warranted. 

B. UAS Pilot in Command 

Petitioner's UAS pilot in command ("PIC") shall hold either an 

airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC shall also hold a current FAA airman medical 

certificate or a valid U.S. driver's license issued b ya state, the District of 

Columbia, Puerto Rico, a territor y, a possession, or the Federal 

govemment. 

Since there are no standards for either private or commercial UAS 

pilot certificates, knowled ge of airspace regulations acquired from FAA 

ground school and dexterityin the control and operation 
August 27, 2015 

Page 19 

of the UAS acquired from actual operation of the aircraft will be the 

most important factors in establishin gan equivalent level of safet y. 

Accordingto the FAA, "the FAA considers the overridin gsafetyfactor 

for the limited operations proposed b ythe petitioner to be the airmanship 

skills acquired through UAS- specific flight cycles, flight time, and 

specific make and model experience, culminatin gin verification through 

testing." See Exemption No. 11062, Re gulatoryDocket No. FAA2014-0352, at p. 18. With those factors in mind, Petitioner's UAS PIC 

shall be required to meet several conditions and limitations as outlined in 

the FOPM and MPTOM, includingthe following: 

• The UAS PIC will have accumulated and lo gged a minimum of 

200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and 

at least 10 hours logged as a UAS pilot with a similar UAS type (single 

blade or multirotor). 

• The UAS PIC will have accuinulated and logged a minimum of five 

hours of flight time with the specific make and model of the UAS to 
August 27, 2015 

Page 20 

be utilized for operations under the exemption and three take-offs and 

landings in the preceding90 days. 

• The UAS PIC will have successfullycompleted the qualification 

process as specified in the operations manuals, to include a knowled ge 

and skill test. 2 

RegardingPetitioner's requested relief from 14 C.F.R. § 91.7(a), it 

is Petitioner's understandingthat Petitioner's UAS will not re quire an 

airworthiness ceilificate in accordance with 14 C.F.R. Part 21, Subpart 

H, and that exemption from 14 C.F.R. § 91.7(a) is therefore unnecessar y. 

To the extent such an exemption is deemed necessar y, Petitioner asserts 

that it should be granted in light of the safetyprocedures proposed 

herein. In accordance with the pertinent part of 14 C.F.R. § 913 (b), the 

operator in command of Petitioner's UAS shall be responsible for 

2 Prior to operating, the PIC will be required to pass the knowled ge and airmanship test 

qualifications developed by Petitioner for the UAS (which are included in Petitioner's operations 

manuals). There are no established practical test standards that support a jurisdictional FAA 

FSDO ("Flight Standards District Office") evaluation and approval ofcompan y designated 

examiners. Petitioner will conduct these tests in accordance with its operations manuals. Given 

the oonstraints ofthe proposed operations, this procedure for testin g will not adversel y affect the 

safety ofthe NAS. 
August 27,2015 

Page 21 

determiningwhether the aircraft is in a safe condition for fli ght. 

Petitioner's manuals for maintenance and operations shall include safet y 

checklists to be used bythe operator in command prior to each fli ght. 

RegardingPetitioner's requested relief from 14 C.F.R. § 91.9(b)(2) 

(Civil aircraft flight manual, marking, and placard requirements) and § 

91.203(a) and (b), (Civil aircraft: certifications re quired), it is 

Petitioner's understandin gthat relief from these for operations under the 

exeinption and three take-offs and landin gs in the regulations is no 

longer necessaryin light of the FAA Memorandtan "Interpretation 

regardingwhether certain re quired documents maybe kept at an 

unmanned aircraft's control station," dated Au gust 8, 2014. To the extent 

the FAA deems an exetnption from this section necessar yfor Petitioner's 

proposed operations, such exemption should be granted in light of the 

mitigatingfact that Petitioner will maintain the documents re quired 

under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control station 

duringflights. 
August 27, 2015 

Page 22 

Additionally, 100% of Petitioner's operations will utilize a visual 

observer ("VO"). The VO may be used to satisfy the VLOS requirement 

as long as the PIC always maintains VLOS capability. The VO and the 

PIC will be able to communicate verbally at all times during operational 

flights. 

Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b) 

(1), Petitioner will comply with the other applicable procedures and 

requirements stated in § 91.103(a) and (b). Specifically, the PIC will 

take all actions including reviewing weather, flight battery requirements, 

aircraft performance data, and landing and takeoff distances before 

initiation of a flight. The PIC will also account for all relevant sitespecific conditions in their preflight procedures. Risks presented by sun 

glare will be mitigated by the PIC's and VO's ability to see other air 

traffic and initiate a return-to-home sequence if needed. 

The PIC's UAS operation will be limited to a unique and restricted 

environment. Given the (1) separation of closed-set filming operations 

from other manned operations, (2) parallel nature of aeronautical 
August 27, 2015 

Page 23 

knowledge requirements incumbent in obtainin ga private, recreational, 

or sport pilot certificate versus a commercial pilot's license, and (3) the 

proposed UAS airmanship skills of Petitioner's PICs, the additional 

manned airmanship experience of a commercial pilot would not 

coffelate to the airinanship skills necessar yfor Petitioner's proposed 

unmanned operations. Thus, Petitioner's re quest for relief from 14 

C.F.R. § 61.113(a) and (b) and § 61.133(a) should be granted. 

C. OperatingParameters of Petitioner's UAS 

Petitioner's UAS operations will be conducted within a sterile 

environinent of closed-set filmin g. In this controlled environment, 

Petitioner's operations will remain within VLOS of the PIC and VO, 

below 400 feet AOL, and at speeds below 87 knots. Onl yparticipating 

persons will be permitted within the operatin garea.3 
August 27, 2015 

Page 24 

Consistent with the relief t ypicallyprovided to manned operations 

under FAA Order 8900. 1, Volume 3, Chapter 8, Section 1, Petitioner 

requests relief from 14 C.F.R. § 91.119 (c) with respect to those 

participatingpersons, vehicles, and structures directl yinvolved in the 

perforinance of the actual filmin g. Regardingdistance from participatin g 

persons, the operations manuals set forth safet yfactors for authorized 

and consentingproduction personnel. Because those procedures are 

specific to participatingpersons, no fiirther FSDO or aviation safet y 

inspector approval is necessar yfor reductions to the distances specified 

in Petitioner's manuals. 

Regardingthe distance from nonparticipatin gpersons, Petitioner 

will ensure that all operations are conducted at least 500 feet from all 

nonparticipatingpersons, vessels, vehicles, and structures unless: 

(a) Barriers or struetttres are present that sufficientl yprotect 

nonparticipatingpersons from the UAS and/or debris in the event 
August 27, 2015 

Page 25 

of an accident. Petitioner will ensure that nonparticipatin gpersons 

remain under such protection. If a situation arises where 

nonparticipatingpersons leave such protection and are within 500 

feet of the UAS, fli ght operations must cease immediatel yin a 

manncr ensuringthe safetyof nonparticipatin gpersons;and 

(b)The owner/controller of anyvessels, vehicles, or structures has 

granted permission for operatin gcloser to those objects and the 

PIC has made a safetyassessment of the risk of operatin gcloser to 

those objects and has detertnined that it does not present an undue 

hazard. 

Unless a letter of agreeinent with an aitport's mana gement is obtained or 

the operations are otherwise permitted b ya Certificate of Waiver or 

Authorization ("COA"), Petitioner will not conduct UAS operations 

widiin 5 nautical miles of an airport reference point ("ARP") as denoted 

in the current FAA Airport/FacilityDirectory('AFD"). For airports not 

denoted with an ARP, Petitioner will not conduct UAS operations within 
August 27,2015 

Page 26 

5 nautical miles of the center of the airport s ytnbol as denoted on the 

current FAA- published aeronautical chart, without the aforementioned 

letter of agreement or COA in place. The letter of a greement with airport 

management will be made available to the FAA and anylaw 

enforcement official upon re quest. 

All operations will be conducted in accordance with a Notice to 

Airmen ("NOTAM'). Additionally, Petitioner will not operate in Class 

B, C, or D airspace without written approval from the FAA. Nor will 

Petitioner operate the UAS less than 500 feet below or less than 2,000 

feet horizontall yfrom a cloud or when visibilityis less than 3 statute 

miles from the PIC. 

Petitioner's UAS will remain clear and yield the right of wayto all 

manned operations and activities at all times (includin g, but not limited 

to, ultralight vehicles, parachute activities, parasailin gactivities, and 

hanggliders). 
August 27, 2015 

Page 27 

Although Petitioner seeks to compl ywith the waiver process as 

described in FAA Order 8900. 1, Volume 3, Chapter 8, Section I (Issue a 

Certificate of Waiver for Motion Picture and Television Filmin g), the 

cuffent section of Order 8900.1 has specific processes that preclude a 

jurisdictional FAA FSDO from issuin gthe required Certificate of 

Waiver, because the section did not ori ginallyprovide for UAS 

operations. Thus, Petitioner seeks exemption from the applicable 

regulations nortnallywaived duringthat process. Petitioner proposes that 

the FAA include the required notifications and coordination with 

jurisdictional FSDOs through the conditions and limitations 

accompanyingthe requested exemption, and that the exemption sou ght 

herein will take the place of the Certificate of Waiver nortnall yissued by 

a jurisdictional FSDO under 8900.1. Under this rubric, Petitioner will 

notifyeveryFSDO with jurisdiction over the area that Petitioner plans to 

operate, just as with manned filmin goperations, and those FSDOs will 

liave the abilityto coordinate further conditions and limitations with the 

[JAS Integration Office to address anylocal concems. 
August 27, 2015 

Page 28 

Petitioner requests a "blanket" COA permittin gcommercial UAS 

operations at or below 200 feet AGL. For all other operations, Petitioner 

will obtain an Air Traffic Or ganization ("ATO") issued COA prior to 

conductinganyoperations under this grant of exeinption. In fulfillingits 

requirements under the COA, Petitioner will be re quired to request a 

NOTAM not more than 72 hours in advance, but not less than 24 liours 

prior to the operation. 

When applicable, all UAS operations will be cotidtictcd in 

accordance with anystate or local privacylaws. 

D. The Requested Exeinption Promotes the Public Interest 

The enhanced safetyachieved byreplacingsignificantlylarger 

manned aircraft cart yingcrew and flammable fuel with small UAS 

carryingno passengers or crew and operated under the specific 

guidelines and procedures proposed b yPetitioner gives the FAA good 

cause to find that the UAS operations enabled b ythe instant Petition are 
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