## Peace of Thorn Productions LLC. Anthony W. De La Pena 4237 Arlington Drive Richton Park, IL. 60471 708

- 513

- 5413 ; d elapenaa31@y ahoo.com EI N: 46

- 0740606 ; Illinois LLC. No. 04037715 Illinois Business Authorization # 4095

– 0867 May 20 , 2015 U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave. S.E. Washington, D.C. 20590. RE: Request for Exemption under Section 333 of the FAA Reform and M odernization Act o f 2012 and Part 11 and Part 21 of the Federal Aviation Regulations from: 14 C.F.R. 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.21; 14 C.F.R. 45.23; 14 C.F.R. 45.23(b); 14 C.F.R. 45.25; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 4 7.3(b)(2); 14 C.F.R. 47.31(c); 14 C.F.R. 61.113; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.115; 14 C.F.R. 91.119; 14 C.F.R. 91.119(b)(c); 14 C.F.R. 19.121; 14 C.F.R. 91.151; 14 C.F.R. 91.151(a); 14 C

. F.R. 91. 203(a) and (b); 14 C.F.R. 91. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 19.405(a) and (b) ; 14 C.F.R. 91.407; 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409; 14 C. F.R. 91.409(a)(2) and 14 C.F.R 91.417 ; 14 C.F.R. 91.417(a) and (b). Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11 and Part 21, IAnthony W. De La Pena : President/CEO/CF O/Owner of Peace of Thorn Productions LLC an Entertainment Film and Video Production Corporation an operator of Small Unmanned Aircraft S ys tems or (sUAS) equipped to conduct aerial inspection, photograph y, scripted closed set filming and video graph y for th e motion picture, television, and utility company industries,

ihereb y petitions for an Exemption from the listed Federal Aviation Regulation or (FAR s ) to

permit commercial operation of its sUARs, so long as such operations are conducted within and und er the conditions outlined herein or as may be established by

the FAA as required by

Section 333. The intended utilization of the sUAS operations contemplated b y this petition is in the public interest because it clearl y satisfies the Four D’s of exemplary uses of UAS: to replace work that is Dangerous, Difficult, Dull, or Dirt y, while simultaneously providing an equivalent or greater level of safety

than approved manned aircraft operations.
For your ease in reviewing this petition, please refer to the ta ble of contents which begins on the next page. If I can provide an y additional information to assist your understanding or review of this document, please do not hesitate to contact me at 708

- 513

- 5431 / 708

- 748

- 5856 or via email at delapenaa31@y ahoo.com

. I thank yo u very

much for all that y ou do for the citizens, professionals, and businesses of the United States . Equally

important, Ithank y ou for taking the time away from y ou bus y work schedule to review and streamline m y petition towards a positive outcome

. I look forward to yo ur repl y. Sincerel y
Mr. Anthony

W. De La Pena

ii

### Table of Contents

I. Publishable Summary

........................................................................... ...1 II. Petitioner’s Conta ct Information ............................................................... ...3 III. Peace of Thorn Production s LLC’s Operation(s) ............................................. ...3 A. The sUAS .................................................................................

... 3 B. Flight Conditions ........................................................................ ...4 1. Scripted Closed

- Set Filming and Videograph y .................... ......... ...4 2 . Aerial Photograph y ............................................................ ...4 3 . Aerial Utility Company Inspection

............................. ............ .....5 C. Flight Operations ............................................................... ...5 IV . Privacy

.......................................................................................... ......8 V. Aircraft and Equivalent Level of Safet y ................................................... ......8 VI . Public Interest and Safety

..................................................................... ...10 VII. Re gulations from which Exemption is Requested .......................................... ..11 A. 14 C.F.R. 21(h): Airworthiness Certificates ....................................... ...11 B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, pro pellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration ................................. ...11 C. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted und er parts 91 , 125 , 135.411(a)(1) and 135.419 of this chapter

... ...11 D. 14 C.F.R. 45.11: Marking of products ................................................. 12 E. 14 C.F.R. 45.21: General ............................................................... ..12 F. 14 C.F.R. 45.23: Display of marks; general ....................................... ...12 G. 14 C.F.R. 45.25: L ocation marks on fixed

- wing aircraft ........................ ...13 H. 14 C.F.R. 45.27: L ocation of marks; nonfixed

- wing aircraft ..................... ..13 I. 14 C .F.R. 45.29: Size of marks ......................................................... 13 J

. 14 C.F.R. 47.3(b)(2): Registration required ....................................... ...13 K . 14 C.F.R. 47.31(c): Application ................................................... .....14 L . 14 C.F.R. 61.113: Privat e Pilot Privileges and Limitations: Pilot in Command .14 M . 14 C.F.R. 61.113(a) and (b): Private Pilot Certificate and Act as Pilot in Command ........................................................................... ......16 N . 14 C.F.R. 91.7(a): Civil aircraft airworthin ess .................................... ...19 O . 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, markings, and placard requirements ........................................................................ ......19 P. 14 C.F.R. 91.9(c): Civil aircraft flight manual, markings, and placard requirement s .................................................................. ............20 i iiQ . 14 C.F.R. 91.103: Flight preparation ................................................ ...20

R . 14 C.F.R. 91.103(a)(b)(1)and(2): Preflight procedures and actions ............ ...21 S . 14 C.F.R. 91. 105: Flight crewmembers at stations .............................. ....21 T . 14 C.F.R. 91.109: Flight instruction: Simulated instrument flight and certain flight tests ........................................................................................ .21 U . 14 C.F.R. 91.113(b): Right

- of

- way rules: Except water operations ............ ...22 V . 14 C.F.R. 91.115: Right

- of

- way rules: Water operations ........................... 22 W . 14 C.F.R. 91. 119: Takeoff and Landing ............................................. ..22 X . 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General ............... .....24 Y . 14 C.F.R. 91.121: Altimeter Settings ................................................ ..25 Z . 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions ............... .25 AA . 14 C.F.R. 91. 203(a) and (b): Civil aircraft: Certifications required ............ ...26 BB . 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use ................................................................................. ...28 CC . 14 C.F.R. 91.403: G eneral ............................................................. .28 DD . 14 C.F.R. 91.405(a) and (b): Maintenance Required .............................. ..29 EE . 14 C.F.R. 91. 407: Operation after maintenance, preventive maintenance, rebuilding or alteration ...............................................................

... 29 FF . 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding or alteration .................................................................. 30 GG . 14 C.F.R. 91.409: Inspections ...................................................... ...30 HH . 14 C.F.R. 91.409(a)(2): aircraft issuance of airworthiness certificate inspection .31 II . 14 C.F.R. 91.417: Maintenance records .............................................. .32 JJ . 14 C.F.R. 91.417(a) and (b): Owner/Operator records of maintenance for aircraft .............................................................................. ...33

i v

### Exhibit List

Exhibit 1: Aerial Inspection Procedures ...................................................... ...........35 Exhibit 2: Aerial Photography Procedures ................................................... ...........36 Exhibit 3: Scripted Closed

- Set Fil ming and Videography

.............................. ..............37 Exhibit 4: DJ I Phantom II User Manual ...................................................... ...........39 Exhibit 5: DJ I Phantom II Specs ............................................................ .............40 Exhibit 6: Spreading Wings S800 EVO User Manual .................................... ............41 Exhibit 7: Spreading Wing s S800 Specs ......................................................... ......42 Exhibit 8: A2 Flight Control Sy stem User Manual ................................................ ...43 Exhibit 9: A2 Flight Controller Features ......................................................... ......44 Exhibit 10: A2 A New Standard in Flight Control ............................................. .......45 Exhibit 11 : Barne s, M.J.; Knapp, B.G.; Tillman, B.W.; Walters, B.A. and Veliki, D. (2000).

Crew Systems Analysis of Unmanned Aerial Vehicle (UAV) Future Job and Tasking Environments. Technical Report ARL

- TR

- 2081, Aberdeen Proving Ground, MD.: Army Research Laboratory

. ............ ................................................ ....46 Exhibit 12 : Williams, K.W. (2007). Unmanned Aircraft Pilot Medical Certification

Requirements, Report DOT/FAA/Am

- 07/3, FAA Civil Aerospace Medical Institute

........................................................................ ......47 Exhibit 13 : McCarley , J.S. and Wickens, C.D. (2004). Human Factors Implications of UAV’s in

the National Airspace. In stitute of Aviation, Aviation Human Factors Division. University

of Illinois at Urbana

- Champaign. ....................................... ......48

v**I. Publishable Summary**

Pursuant t o 14 C.F.R. Part 11 and Part 21, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an Exemption from the following Rules: 14 C.F.R. 21(h); 14 C.F.R. 43.7; 14 C.F .R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.21; 14 C.F.R. 45.23; 14 C.F.R. 45.23(b); 14 C.F.R. 45.25; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 47.3(b)(2); 14 C.F.R. 47.31(c); 14 C.F.R. 61.113; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9( b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.115; 14 C.F.R. 91.119; 14 C.F.R. 91.119(b)(c); 14 C.F.R. 19.121; 14 C.F.R. 91.151; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C .F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 19.405(a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409; 14 C.F.R. 91.409(a)(2) and 14 C.F.R 91.417; 14 C.F.R. 91.417(a) and (b) to operate commercially a small unmanned airc raft sy stem (sUAS) (15lbs or less). Approval of exemption for Peace of Thorn Productions will allow commercial operations of sUASs in the open film and v ideo motion picture , photograph y, and utility compan y inspection industr ies , enhancing safety by removing the risk of phy sical harm to personnel on and off scripted closed

- set environments, and maintenance technicians and professionals of utility

companies, otherwise exposed to dangerous camera angle techniques and equip ment to achieve the aerial affe ct , and high tower s and electric wires and equipment currentl y used to investigate damaged, and worn out material. In reference to filming and videography current operations require a helicopter involving two to four or five persons fly ing at very low alti tude try ing to achieve an aerial visual effect for a scripted scene which is extremely dangerous for all involved including surrounding structures and high power electrical lines with the risk of propert y damage or worst death. In addition, motor vehicles with mounted film cranes which extent 25 to 30 feet over and past the motor vehicle’s center of gravit y requirements to achieve an aerial visual scripted scene effect are currentl y used which is also very dangerous for all involved because of the high risk of the motor vehicle crashing into people, other motor vehicles, and buildings causing property damage, human injury

or death. In reference to utility compan y inspections current operations involve having a crew of 4 or 5 technicians with two or three pe rsons spending hours prepping, mounting and then climbing electrical towers to inspect for damage and worn out material at each tower location under dangerous conditions, and with the risk of life threatening scenarios. 1Moreover, another current practi ce of utility company inspection operations involve the

use of a helicopter with 3 or 4 persons fl yi ng at very low altitude try ing to achieve an aerial visualization of damaged and worn out tower structure and electrical wiring material which is extremely dangerous for all involved including surrounding structures and high power electrical lines with the risk of property damage , human injury or worst death. In contrast, a sUAS weighing less than 15lbs. and is powered b y batteries eliminates virtually

all of the risk for propert y damage, human injury, or death. The operation of small UASs, weighing less than 15lbs., conducted in the strict conditions outlined below will provide an equivalent level of safet y supporting the grant of the Exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to ground, and in a low risk, low to moderate population environment and, as a result, are far safer than conventional operations conducted with helicopters , moving vehicles , or fixed

- wing aircraft operating in close proximity to the ground, buildings, people, and other elevated standing structures. The intended utilization of the sUAS operat ions contemplated by this petition is in the public interest because it clearl y satisfies the Four D’s of exemplary uses of UAS: : to replace work by humans that is Dangerous, Difficult, Dull, or Dirty , while simultaneously providing an equivalent or great er level of safet y. Finally , the petitioner requests Exemption from the requirement of the PIC possessing a private or commercial pilot’s license. Research studies cited by petitioner, sponsored by the FAA and Arm y Research Laboratory, demonstrate that UA S, even those much larger than the sUASs proposed by Peace of Thorn Productions LLC., can be safely flown b y non - certificated pilots with a small amount of training. However, in the alternative, petitioner re quests that if th e agency concludes the PI C qual ifications proposed in the Exemption request do not meet the interim standards it is implementing; it should not deny the application on that ground. Rather, it should grant the Exemption subject to Peace of Thorn Productions LLC meeting whatever interim P IC qualifications the agency has adopted in Section 333 Exemption proceedings, for example, the PI C qualification policies established in any of the pending Exemption petitions of ComEd Energy , Sprint, AT&T, Warner Bros., Paramount Pictures, Fox Television , or any other utility , film and videograph y industry

not listed here.

2**II. Petitioner’s Contact Information**

Peace of Thorn Productions LLC. Anthony W. De La Pena 4237 Arlington Drive Richton Park, IL. 60471 Tel: 708

- 513

- 5431 Email: delapenaa31@ ya hoo.com EI N: 46

- 0740606; Illinois LLC. No. 04037715 Illinois Business Authorization # 4095

– 0867
**III. Peace of Thorn Productions LLC’s Operations A. The sUASs**  The requested Exempti on will permit the operation of small, unmanned multi

- rotor aircraft based on the DJ I Phantom II and DJ I S800, weighing less than Fifteen (15) pounds (inclusive of batteries and technical pay load). These rotorcrafts operate at speeds of no more than thirt y (30) knots, and have the capability to hover and move in the vertical and horizontal planes simultaneously

. The sUASs will have the following specifications or equivalent: Airframe: DJ I Phantom II Dual Frame ; DJIS800 EVO Co ntrol Sy stem (s) : 2.4 GHz I SM; Intelligent Orientation Control (IOC) ; A2 Tx: 5.8G SWR<1.5 ; Futaba 14 SG Rx: 5.8G SWR<1.5 ; Internal in A2 Motors: Tiger (MN2214

- KV920 Anti

- Gravity Series ) ; DJ I 4114 Propellers: Tiger RC 9” (9443) Carbon Fiber ; Tiger RC 15” Carbon Fiber Data Link (s) : D J I 2.4G H z Data Link LK24

- BT ; DJ I Data Link 2.4GHz Data L ink

OSD: iOSD Mark II/iOSD Mini ; iOSD Mark II G imbal: Zenmuse H3

- 2D ; Zenmuse Camera: GoPro Hero 3+ Black Edition ; Canon EOS 70D Batteries: 11.1 V, 5200 mAh 3 S lithium

- poly mer (LiPo) ; Glacier from RC Budd y 6000mA 6

- cell with EC5 main power co nnection Please refer to Exhibits 4 through 10 attached to this petition for further information about the Phantom II , and the 2.4 GHz I SM; Intelligent Orientation Control (IOC) control sy stem ; the S800 EVO , and the A2 Control Sy stem
. 3**B. Fligh t Conditions** 

The sUASs will be flown in airspace between and less than 400 feet above ground level (AGL) and under controlled conditions on restricted, populated, rural, and private property . The sUASs will be used for aerial inspection, photography , scr ipted closed set filming and videograph y for the motion picture, television, and utility company industries.
**1. Scripted Closed** 
**- Set Filming and Videography**  Peace of Tho r

n Productions LLC proposes Exemption under Section 333 to operate commerciall y in private, secured

- entry scripted closed

- set filming and videography operations, including but not limited to , the City of Chicago, the Greater Chicago Metropolitan region, and including Northwestern Indiana ’s Lake and Porter Counties. These areas are ab undant with aerial scenic, photographic, and cinematographic opportunities with many areas providing secured time limited access which greatly reduces hazardous conditions for the public. These areas are over 10 miles away

from an y m ajor or minimal municip ality airport. Peace of Thorn Productions LLC intends to expand its operat ion in other parts, similarly to abundant scenic, photographic, and cinematographic areas in the United States, if permitted. Any scripted closed

- set filming and videograph y operat ions will be guarded and restricted to locations in Class G airspace and at least 10 miles from an y controlled and uncontrolled runway s, to protect the public from hazardous conditions. **2. Aerial Photography** Peace of Thorn Productions LLC proposes Exe mption under Section 333 to operate commerciall y in private and semi

- public, secured

- photograph y operations, including but not limited to, the City

of Chicago, the Greater Chicago Metropolitan region, and including Northwestern Indiana’s Lake and Porter Co unties. These areas are abundant with aerial scenic, photographic, and cinematographic opportunities with many areas providing secured time limited access which greatly reduces hazardous conditions for the public. These areas are over 10 miles away

from an y m ajor or minimal municipality airport. Peace of Thorn Productions LLC intends to expand its operations in other parts, similarly to abundant scenic, photographic, and cinematographic areas in the United States, if permitted. Any aerial photograph y oper ations will be guarded and restricted to locations in Class G airspace and at least 10 miles from any controlled and uncontrolled runway s, to protect the public from hazardous conditions. 4**3. Aerial Utility Inspection**

Peace of Tho r

n Productions LLC p roposes Exemption under Section 333 to operate commerciall y in private, secured

- entry aerial utility company and community municipality site inspection operations, including but not limited to, the City of Chicago, the Greater Chicago Metropolitan region, and including Northwestern Indiana’s Lake and Porter Counties. These areas are abundant with power lines, communication towers and antennas, and municipality water towers with many

areas fenced off and have manned and secured gates and personal which restr ict public access, providing and offering secured time limited access which greatl y reduces hazardous conditions for the public. These areas are over 10 miles away from any major or minimal municipality

airport. Peace of Thorn Productions LLC intends to expand its operation in other parts, similarly to abundant power lines, communication towers and antennas, and municipality water tower areas in the United States, if permitted. An y aerial utility company inspection operations will be guarded and restricte d to locations in Class G airspace and at least 10 miles from an y controlled and uncontrolled runways, to protect the public from hazardous conditions. **C. Flight Operations** The purpose of every

sUAS flight will be to safely , accuratel y, and effi ciently create aerial scenic, photographic, cinematographic, and utility company material inspection imaging. The sUAS will film, video tape , and collect photographs , inspect equipment to determine maintenance and repairs, and use specialized film, video, and photograph y s oftware to process, prepare, and display

the results. The final imaging output will be HD high resolution aerial imaging. Every sUAS flight will use at minimum a one man flight crew, however, an assistant/ spotter will be available for fi lming and videotaping , and a utility company technician/expert will be present for utility company inspections , and will possess the appropriate credentials and licenses

. The Pilot in Command (PI C) will have substantial prior experience with operating the sUASs. The standard pre

- flight and operational procedure will be as follows: 1. Meet with securit y and complete pre

- flight checklist and inspection appropriate to each site (described below). 2. Drive to area to be filmed, videotaped, photographed, and inspected. 3. The Pilot in Command begins to read y sUAS s for flight

. a. Set up hand held weather station on tripod. 5b. Check over airframe, connections, and propellers for an y damage during transport in vehicle. While the airfr ame has the ability to disassemble easily

for transport, the sUASs will remain fully

assembled. The sUASs is transported in the back of a SUV which has straps installed to secure the sUAS in place to minimize electrical connection fatigue , and a customized waterproofed case is also used to transport the sUASs. c. Install and calibrate camera in gimbal. d. Turn on and read y lap top in SUV. e. Connect communication antennae to laptop. f. Open Ground Station software and pull up pre - planned aerial flight path. g. Boot up secondary

GPS for tracking and aerial imaging. h. Attach secondary

GPS to sUAS. i. Remove main flight * Tx from case and power up, verify voltage and settings. j. Remove gimbal Tx from case and power u p, verify voltage and settings. k. Remove dual battery

pack for flight, measure current voltage, log in battery manual. l. Strap or insert batteries securely on and in aUAS, do not attach main power. m. Move sUAS to take off point, approximately 30 f eet from vehicle(s) and crew. n. Attach main power. o. L isten to power up sequence of beeps for ESC and motors. p. Using Flight Tx cy cle through different control modes observing LED lights for good connection and response. q. Using Gimbal Tx cy cl e through all controls making sure the gimbal and camera respond to commands. r. Remove secondary

GPS and hold in front of camera taking picture or video to record a time stamp image. s. Reattach secondary

GPS. t. Set up traffic cones around sUAS w ith approximately a 20 foot radius. This is the “home” area and the operations are not allowed inside this area while the electrical motor(s) are running. u. Walk back to transport vehicle with both Tx. v. Using Flight Tx activate engine power without moving throttle up. This checks that the automatic throttle kill is working and also records the “home” point. w. Using laptop Ground Station now select button connecting laptop to sUAS. x. sUAS should appear on the screen, along with a recorded home po int, battery voltage, current altitude relative to the ground, and current velocity

.

__________________________ * “Tx” represents radio transmitter for command and control. “Rx” represents radio receiver for command and control. 6y. Upload flight path data to sUAS.

z. Verify

good upload and connection aa. Verify

weather from portable weather station, and weather app. bb. Record time and weather in flight log. cc. sUAS is now full y prep and read y to go. dd. Wait for secondary

crew member to return from setting out GCP’s. 4. While Pilot in Command is read yi ng the aircraft the second crew member is preparing the Ground Control Points (GPC’s) and walking the site. a. Power up and calibrates the survey grade GPS equipment. b. Begin setting GCP’s and shooting center of targets with survey GPS. c. While setting out GCP’s secondary crew is also making sure area is clear of all people. 5. Ty pically secondary

crew and pilot finish at about the same time. Upon his return, the secondary crew member set s the survey GPS to the side and sits next to the lap top and camera Tx. 6. Pilot double checks take

- off area is clear. 7. Pilot takes off fly ing to the approximate survey altitude. 8. Pilot instructs secondary crew member to initiate preprogrammed f light path. 9. Secondary

Crew verifies that the Ground Station has good connection and is tracking the sUAS. 10. Secondary

crew then turns on the camera to take pictures at a continuous interval. 11. During entire preprogrammed flight Pilot always has visual line of sight and is prepared to take over flight operations. Pilot’s Tx has a flight count down timer which is set to a minimum of 20% battery reserve (Calculated based on prior field experience to safel y return the sUAS to safe landing w ith ample margin of error). The timer begins from the point the throttle is moved out of its start position. 12. During flight secondary crew vigilantl y monitors the Ground Station data (Voltage, forward velocity , altitude, and estimated remain ing time to complete the mission) and relay s any sudden changes or alerts to the pilot. 13. As the mission completes the Pilot informs the secondary crew he is taking back over control. 14. Secondary

crew turns off the camera. 15. Pilot begin s to land the sUAS. 16. After safel y touching down the Pilot immediately goes and unplugs the main power. He then checks the pictures to verify if the film, video, and pictures are good and the mission was successful. 17. If successful secondary crew leaves to go pick up GCPs. 18. Pilot checks battery

voltage and records in battery log. 19. Pilot records flight time in Flight Log.
720. Pilot turns off both Tx, secondary GPS, and camera. 21. Pilot looks over airframe to see if an y damage or loose connections happened from the flight. 22. Pilot begins to pack all equipment back up for safe transport. The flight crew will follow separate safet y procedures for filming, videotaping, photograph y, and utility compan y , and community municipalit y inspecti on. At the filming, videotaping, and photograph y sites, the flight crew will check in at the designated scripted close d

- set area, and chosen photographic site, and go through a safety inspection. The crew will meet with representative (s) who serve as a l iaison in directing any personn el associated with the surrounding chosen scripted closed

- set area, and will have an y unnecessary

personne l, vehicles, or an y other unidentified items not described within the script clear ed off before the crew begins its fil ming, or videotaping . After the flight, the representative (s) will inform any unnecessary personne l, owner of vehicles that they can begin returning to the area again. (See Exhibit s 2 and 3 ) At the utility compan y and community municipality sites, the fli ght crew will wait for utility company personnel and securit y , and put on personal protection equipment, which includes hard hats, safet y glasses, flame resistant coveralls, and steel toed boots. The crew then drives around the electrical tower site(s), co mmunication tower(s), and water tower(s) site s to inspect the flight area, set out ground control points, and take land based photographs, and parks just outside of the entrance (s)

. (See Exhibit 1 )
**IV. Privacy**  There is little concern that the propo sed flights will cause invasions of privacy because all flights will occur over controlled access propert y with the propert y owner’s prior consent and knowledge. In addition, as the over flight areas will be under controlled designated scripted closed

- set area(s), chosen photographic site(s), and fenced off secured utility compan y rural to semi

- rural sites , there is little to no chance that there will be inhabited houses in the visual area or other people who have not consented to being filmed , videotaped, or photographed or otherwise agreed to be in the area where filming , videotaping, or photographing will take place. No attempt will be made to identify an y individuals filmed , videotaped, or photographed during the flights except in cases where they are tr espassing upon or damaging customer propert y, or interfering with the applicant’s or its customers’ operations.
**V. Aircraft and Equivalent Level of Safety**  8Peace of Thorn Productions LLC proposes that the exemption requested herein appl y to

ci vil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safet y to operations under the current regulatory

structure. These limitations and cond itions to which Peace of Thorn Productions LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include: 1. The sUAS will weigh less than 15 lbs. 2. Flights will be operated within line of sight of a pilot and obs erver. 3. Maximum total flight time for each operational flight will be 3 hours . Flights will be terminated at 20% battery power reserve should that occur prior to the 3 hour limit. 4. Flights will be operated at an altitude of no more than 400 f eet AGL. Despite this limitation, the majority

of flights are anticipated to operate at no more than 270 feet AGL. 5. Minimum crew for each operation will consist of the sUAS pilot and the visual observer. 6. A briefing will be conducted in regard ( s) to the planned sUAS operations prior to each day ’s activities. It will be mandatory that all personnel who will be performing duties in connection with the operations be present for this briefing. 7. The operator will file any necessary

paperwork in light of the exemptions with the appropriate Flight Standards District Office (“FSDO”). 8. The operator will submit a written Plan of Activities to the FSDO at least one day before the proposed operations begin. 9. Pilot and observer will have b een trained in operation of sUAS generally and received up to
- date information on the particular sUAS to be operated. 10. Pilot and observer will at all times be able to communicate by voice and/or text. 11. Written and/or oral permission from the re levant propert y holders will be obtained. 12. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

913. The sUAS will have the capability to abort a flight in case of unexpected obstacles or emergencies. 14. If the multi

- rotor and its controller disconnects during flight, the s ys tem’s failsafe protection will come to the rescue and the multi

- rotor will return to home and land automatically , rather than fly ing off uncontrollably or landing at an unknown location. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabili ties, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUAS in the fi lm, video, photograph y, and utility compan y inspection industries pursuant to Peace of Thorn Production LLC’s rules of operation appended hereto. **VI. Public Interest and Safety**  Use of the sUAS will increase and enhance ground safet y b y eliminating the risk of phy sical harm to personnel on and off scripted closed

- set environments, and maintenance technicians and professionals of utility companies, otherwise exposed to dangerous camera angle techniques and equipment to achieve the aerial affect, and hi gh towers and electric wires and equipment currently

use d to investigate damaged, and worn out utility company material(s). Currently , utility

company ’s use climbers with harness and rope to scale electric towers to inspect and maintain their equipment , other utility companies utilize truck s with lift buckets that only extend 25 to 30 feet above ground to accomplish repairs and maintenance, and then the technicians must clime and scale the rest of the tower(s) to repair and maintain material(s). In referenc e to filming and videoing scripted closed

- set environments, the current practice to achieve aerial scenic photographic and cinematographic opportunities are by using trucks with mounted camera extension equipment that reaches 20 to 25 feet past the center of gravit y of the vehicle which can lead to overturning the vehicle . Also, helicopters are used to achieve aerial scenic photographic and cinematographic opportunities which can cause air crashes because they need to fl y at low altitudes which can harm pe ople, propert y, and cause death. By fl yi ng the sUASs over scripted closed

- set environments and utility company ’s high towers and electric wires, rather than putting pilots in helicopters fl yi ng at low altitude and people in a vehicle with a mounted camer a extension, or having utility company climbers scale electrical towers to inspection equipment and material, the hazards stemming from these extreme conditions will be removed. 10Additionally , a sUAS can complete all these tasks in less than 20 to 30 minutes, a drastic

reduction in the time it takes the workers, who may otherwise spend three or more hours at a time in these conditions. Scenic aerial photographic and cinematographic scripted closed

- set environments and utility

company ’s high towers and electric wire inspections made possible by the sUASs will reveal dangerous conditions, including possible being electrocuted, crashing vehicles into people and buildings, causing great harm, injury , or death to all involved in the process. **VII. Reg ulations from Which Exemption is Requested**  **A. 14 C.F.R. 21(h): Airworthiness Certificates** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 21(h). This exemption meets the requirements for an equivalent level of safet y pursuant to Section 333 based on the small size, light weight, relativel y slow speed, and use in controlled environments on private land, as described previously in this petition.
**B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraf**  **t engines, propellers, appliances, or component parts for return to service after maintenance,**  **preventive maintenance, rebuilding, or alteration.** Peace of Thorn Productions LLC r equests an exemption from 14 C.F.R. 43.7. This part p rovides, inter alia, that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service. The nature of the sUAS is that of a model airc raft and the operator (s) of Peace of Thorn Productions LLC who will maintain and when necessary will seek certified and licensed repair personnel. The operator ( s ) will conduct inspections and maintenance based on maintenance guidelines provided b y the manu facturer of the sUAS s , DJ I. (See Exhibits 4

- 10 ). The capabilities of these operator ( s ) to maintain and repair the sUAS will meet the requirements for an equivalent level of safet y pursuant to Section 333 for the t ype of sUAS s , its intended use, and the ope rating environment.
**C. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted**  **under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.** Peace of Thorn Productions LLC requests an exemption fr om 14 C.F.R. 43.11. This part provides, inter alia, that maintenance record entries be maintained and for the listing of discrepancies and placards by inspectors.
11The sUAS, due to its small size, does not have room for placards to be placed in or on i t and no

inspections for sUAS have been certified b y FAA at the present time. However, as a condition to the approval of exemption, Peace of Thorn Productions LL C is willing to keep log books of all maintenance and repairs.
**D. 14 C.F.R. 45.11: Mark**  **ing of products.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or propellers with an approved fireproof identification plate. The sUAS, due to its small size, does not have room for fireproof placards to be placed in it. An y required placards could become hazardous, due to the additional weight and strain placed on the sUAS.
**E. 14 C.F.R. 45.21: General.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 45.21. This part provides, inter alia, that except as provided in §45.22, no person may operate a U.S.

- registered aircraft unless that aircraft display s nationalit y and registration marks in accordance with the requirements of this section and §§45.23 through 45.33. There are no current procedures for obtaining a registration mark for sUASs b y the FAA. However, as a condition to the approval of exemption, Peace of Thorn Productions LLC is willing to be assigned a registration number and to display it where practicable as addressed in this petition relative to Parts 23, 27, and 29, below. **F. 14 C.F.R. 45.23: Display of marks; general.**  Peace of Thorn Productions LLC requests an exemp tion from 14 C.F.R. 45.11. This part provides, inter alia, that each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the air craft. Moreover, 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 th an 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. The sUAS, due to its small size, does not have room to display aircraft marks in a conventional size. However, as a condition to the approval of exemption, Peace of Thorn Productions LLC is willing to affix an aircraft mark to one or more of the "arms" of the sUAS. The size of the marking will be determined by the size of the "arm" being used and may be less than 1 inc h in size. 12The word “Experimental” will be placed on the fuselage in compliance with §45.29(f).

However, a partial exemption from this display regulation 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 sUAS, two

- inch lettering will be impossible. The equivalent level of safet y will be provided b y having the sUAS marked on its fuselage as required b y §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the UAS as “Experimental.” The requested exemption is consistent with the following exemptions to this regulation that the FAA has issued: Exemptions Nos. 10700, 8738, 10167 and 10167A. **G. 14 C.F**  **.R. 45.25: Location of marks on fixed**
**- wing aircraft**  The sUAS is a multirotor model aircraft and is not fixed

- wing. Therefore, 14 C.F.R. 45.25 is inapplicable.
**H. 14 C.F.R. 45.27: Location of marks; nonfixed** 
**- wing aircraft**  Peace of Thorn Production s LLC requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y §45.23. The sUAS, due to its small size, does not have a cabin, fuselage, boom or tail to display the marks required by §45.23.
**I. 14 C.F.R. 45.29: Size of marks**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, at subpart (3) that the registration marks for rotorcraft must be at least 12 inches high. The sUAS, due to its small size, does not have an y surface area large enough to display marks an ywhere near 12 inches high. However, as a condition to the appr oval of exemption, Peace of Thorn Productions LLC is willing to affix an aircraft mark to one or more of the "arms" of the sUAS. The size of the marking will be determined by the size of the "arm" being used and may

be less than 1 inch in size.
**J. 14 C.F.R. 47.3(b)(2): Registration required**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 47.3(b)(2). This part provides "(b) No person may operate an aircraft that is eligible for registration under 49 U.S.C. 1344101

- 44104, unles s the aircraft

— (1) Has been registered b y its owner; [or] (2) I s carrying aboard the temporary

authorization required by §47.31(c)." There are no current procedures for obtaining a registration mark for sUASs by the FAA. However, as a condition to the app roval of exemption, Peace of Thorn Productions LLC is willing to be assigned a registration number provided by FAA and to display

it where practicable as addressed in this petition relative to Parts 23, 27, and 29, above.
**K. 14 C.F.R. 47.31(c): Appl**  **ication** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R.47.31 (c). This part provides "(c) After compliance with paragraph (a) of this section, the applicant for registration of an aircraft last previously registered in the United States must carry the second copy of the Aircraft Registration Application in the aircraft as temporary authority to operate without registration." Because FAA currently

has no process for registering sUAS, it is impossible to comply with Part 47.31(a), whic h states, inter alia: "(a) Each applicant for a Certificate of Aircraft Registration, AC Form 8050

- 3 must submit the following to the Registry : (1) An Aircraft Registration Application, AC Form 8050

- 1, signed by the applicant in the manner prescribed by § 47.13; (2) The original Aircraft Bill of Sale, AC Form 8050

- 2, or other evidence of ownership authorized by

§47.33, §47.35, or §47.37 (unless already recorded at the Registry).”
**L. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: Pilo**  **t in Command.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 61.113. The PI C (pilot in command) of the sUAS does not possess either a private or commercial license. However, because (i) the sUAS is essentially a model aircraft, weighs less than 15 lbs. including pay load, and will not carry any pilot or passengers, (ii) the area of operation is controlled and restricted, (iii) all flights will be planned and coordinated in advance, and (iv) the maximum altitude of the sUAS will not exce ed 400 feet AGL, the proposed operations will achieve the equivalent level of safet y of current operations by manned aircraft with a private or commercial pilot ’ s license. The level of safet y provided by Peace of Thorn Productions LLC meets or exceeds that provided b y an individual possessing a private or commercial pilot's license operating a manned aircraft. For conducting safe sUAS operations it is more important for the PIC of the sUAS be experienced, particularl y with the sUAS at issue, than for the P IC to have a pilot’s license.
14T he PI Cs operating under this exemption will be experienced. Peace of Thorn

Productions LLC will have an operator (PIC) who has 1.5 y ears of radio control aircraft experience and has flown nearl y 150 flights on th ese part icular sUAS s , and therefore meets or exceeds the present level of safet y envisioned under this Section. Stated another way , the skill set needed to successfully and safel y operate the UAS is very different from the set of skills needed by a pilot of manne d aircraft. Both FAA and Arm y Research Laboratory

research demonstrate that UAS, even those much larger than the sUAS proposed b y Peace of Thorn Productions LLC , can be safel y flown b y non - certificated pilots with a small amount of training. As one Arm y Research Laboratory study stated: **"[T]he specific motor skills needed to control the radio**
**- controlled UAV would**  **have to be learned by aviators independently of the motor skills learned in flying an aircraft. In particular, the somatic and visual cues that**  **pilots use during aircraft landings would not be useful (and perhaps even counterproductive)**  **for the different skill sets and perceptual viewpoint necessary for radio** 
**- controlled landings."**  Michael J. Barnes, Beverl y G. Knapp, Barry W. Tillman, Brett A. Wa lters & Darlene Veliki, Crew systems analysis of unmanned aerial vehicle (UAV) future job and tasking environments , Technical Report ARL TR

2081, Aberdeen Proving Ground, MD: Arm y Research Laboratory, page 12 (2000). (See Exhibit 11 ) In addition to the ab ove research b y the Arm y Research Laboratory , additional research reports lend further support for the exclusion requested, including one sponsored by the FAA and the other sponsored b y the Institute of Aviation, Aviation Human Factors Division, at the Uni versity

of Illinois at Urbana

- Champaign: 1. Kevin W. Williams, Unmanned Aircraft Pilot Medical Certification Requirements, Report DOT/FAA/AM

- 07/3, FAA Civil Aerospace Medical Institute, page 2, (2007), available at http://fas.org/irp/program/collect/ua

- pilot.pdf

. **"We know that certain systems, like the U.S. Army Hunter and Shadow systems, are successfully flown by pilots with no manned aircraft experience."**  2 (See Exhibit 12 ).

152. Jason S. McCarley & Christopher D. Wickens, Human Factors Implications of UAVs in the National Airspace , Institute of Aviation, Aviation Human Factors Division, University of Illinois at Urbana

- Champaign, 13 (2004), available at http://www.tc.faa.gov/ logistics/grants/pdf/2004/04

- G

- 032.pdf , citing Barnes, supra . **"Using the Army’s Job Assessment Software System (JASS), Barnes, et al (2000) elicited Hunter UAV operators ratings of the relative importance of**  **various cognitive skills in UAV air vehicle ope rators. Ratings indicated that**  **outside of communication skills, raters did not consider flight**
**- related skills of**  **great importance to UAV operations, leading the authors to conclude that selection of rated aviators as air vehicle operators would be of littl**  **e value."** (See Exhibit 13 ). Finally , if the agency

concludes that the PI C qualifications proposed in this exemption request do not meet the interim standards it is implementing, it should not deny the application on that ground. Rather, it should grant th e exemption subject to Peace of Thorn Productions LLC meeting whatever interim PI C qualifications the agency has adopted in other Section 333 exemption proceedings. For example, the pending exemption petitions of NextEra Energy , Inc., San Diego Gas & Electric Company , Southern Company Services LLC., Utility

Aerial Services In c., MicroCopter Professional Services Inc., Montico, Inc., Aerius Flight LLC., Saratoga Aerial Photo and Video, Aerial Production Services Inc., NextEra Energy I nc., Oceaneering International, Inc., and Aery on Labs, Inc., has already raised the PIC qualification issue. Applicant would be willing to adhere to the PI C qualification policies established in any of those proceedings.

**M. 14 C.F.R. 61.113(a) and (b): Private Pilot Ce**  **rtificate and Act as Pilot in Command** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 61.113 (a) and (b)

. Section 61.113(a) and (b) prescribes that (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may , for compensation or hire, act as pilot in command of an aircraft in c onnection with any business or employment if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. Sections 61.113 (a) & (b) limit private pilots to non

- comm ercial operations **.** 16Because the s UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safet y of current operations b y requiring the PI C operating the aircraft to have a private pilot’s license rather tha n a commercial pilot’s license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotel y controlled with no living thing on board. The area of operation is controlled and restricted, and all flights ar e planned and coordinated in advance as set forth in the Manual. The level of safet y provided b y Peace of Thorn Productions LLC meets or exceeds the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot ’s certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PI C exceeds the present level of safet y achieved b y 14 C.F.R. §61.113 (a) & (b). In addition, there are no standards for either Private or Commercial sUAS pilot certificates. The safe operation and control of the UAS as described in the Exemption Applications does not depend on the ty pe of FAA license held by the PIC. Given the restricted and controlled airspace within which operations will take place, the key factors needed b y the PI C are knowledge of the airspace within which the “closed set filming” operation will take place and how that airspace fits into the National Airspace S ys tem (NAS). That knowledge can be and is gained primarily through ground school and not through flight training in fixed wing or rotor a ircraft, nor is it dependent on the acquisition of a commercial or private pilot’s certificate. Those certificates demonstrate knowledge of the factors and skills needed for the safe operation of those ty

pes of aircraft (fixed wing or rotorcraft). It canno t be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safel y operate a small unmanned aerial vehicle, operating at 400 AGL or lower, within strictly controlled pre

approved airspace. Besi des knowledge of airspace regulations, dexterity in the control and operation of the sUAS acquired from actual operation of the aircraft is the most important factor in establishing an equivalent level of safet y. If the PI C has acquired the necessary kno wledge of airspace requirements, the relevant issues are (1) where the aircraft will be flown, (2) the size of the aircraft relative to what is being used today

to accomplish the same mission, and (3) what precautions will be taken to ensure the safet y of those in the area of operation. As set forth in the Exemption Application, Applicants, to address those issues, have proposed that the PIC has at least an FAA Private Pilots Certificate and a Class III medical; the aircraft be operated within a secure envi ronment; and that no one be allowed to enter the secure environment unless they are part of the production, have been fully briefed of the risks prior to operation of the sUAS, and have consented to the risks associated with being in the operating area. 17Should there be a mishap, the sUAS being flown pose significantly less of a threat than the helicopters and fixed wing aircraft now being employ ed because they are a fraction of the size, carr y no flammable fuel, do not carry crew or passengers, and pos e an infinitesimal risk to others. This is in stark contrast to conventional aircraft that are flown to the site, carry explosive fuel, carry

passengers and crew, and operate in a much larger area. From a practical standpoint, there are relatively few lic ensed full

- scale aircraft pilots who are also qualified to fl y the type of sUAS that are utilized for motion picture industry image

capture operations. There are even fewer commercial pilots that can fly these sUAS

– to the point that to do both is conside red rare. Assuming that it is unlikely for a company

to find a pilot that has both qualifications, that company would either have to source a qualified sUAS pilot to train and obtain a commercial certificate, or find a commercial certificated pilot who wou ld be willing to learn to fl y a sUAS to the competency level required for professional motion picture industry use *

. As set forth in the Operations Manual the minimum requirements for the PIC include: 1) Private Pilot’s license and a Class III medica l; 2) A minimum of 200 flight cy cles and 25 hours of total time as a sUAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS ty pe (single blade or multirotor); 3) A minimum of 5 hours as sUAS pilot with the make and mod el of sUAS to be utilized for operations under the exemption and 3 take offs and landings in the preceding 90 day s; 4) Have undergone a qualification process consisting of a knowledge test of the aircraft to be used and a flight demonstration to be admi nistered b y a FSDO

- approved compan y pilot.

_________________________________ Requiring a sUAS pilot to obtain a commercial certificate, as opposed to just a private pilot certificate, creates a significant financial burden and provides little or no ad ded benefit. For example, consider a company that has financed its employ ee’s private pilot’s license (PPL) and that the employ ee accrued 100 hours of flight time as part of his or her PPL training. To obtain a commercial certificate, he or she now needs a n additional 150 hours to qualify for the commercial rating. 18This additional training

— assuming that an instrument rating is not needed because the proposed

sUAS operations would be strictly VFR

— would cost, at a minimum, approximately $21,000. The cos ts breakdown as follows: 140 flight hours in a basic fixed wing aircraft (i.e. C172) @ $125 per hour = $17,500 10 flight hours in a complex fixed

- wing aircraft @ $200 per hour = $ 2,000 20 hours flight instructor (part 61) @ $ 75 per hour = $ 1,500 Total Cost = $21,000 However, the reality

is that oftentimes the cost is much greater. Based upon this analy sis, combined with all factors, including the lack of qualified commercial p ilots; it is hard to envision a cost benefit to the requirement that commercial pilots must operate the sUAS.
**N. 14 C.F.R. 91.7(a): Civil aircraft airworthiness.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.7(a). The r egulation 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 standard will exist for determining airworthiness . Given the size and weight of the aircraft and the requirements contained in Peace of Thorn Productions LL C ‘s rules of operations, described above, for maintenance and use of safety check lists prior to each flight, an equivalent level of safet y will be provided. **O. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and placard**  **requirements.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.9(b)(2). This part provides : "(b) No person may operate a U.S.

- registered civil aircraft... (2) For which an Airplane or Rotorcraft Flight Manual is not required b y §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." First, there does not currently exist a method of approving manuals for sUAS. Second, given the size and configuration of the sUAS, there is no space to carry such a flight manual on the aircraft. In addition, carrying the manual on the aircraft would be pointless, since there is no pilot or other person on board who could read or use it. 19The equivalent

– and in fact a greater

- level of safety will be maintained b y k eeping the flight manual at the ground control point where the pilot fly ing the sUAS will have immediate access to it. The FAA has issued the following similar exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.
**P. 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard requirements.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter." As stated above, there is no current registration process for sUAS; and the sUAS, due to its small size, does not have room to contain fireproof placard or to display aircraft marks in a conventional size. However, as a condition to the approval of exemption, Peace of Thorn Productions LLC is willing to affix an aircraft mark to one or more of the "arms" of the sUAS. The size of the marking will b e determined b y the size of the "arm" being used and may be less than 1 inch in size. **Q 14 C.F.R. 91.103: Flight p**  **reparation.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91. 103

. Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight, to include : (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fu el requirements, alternatives available if the planned flight cannot be completed, and an y known traffic delays of which the pilot in command has been advised b y ATC; (b) For an y flight, runway lengths at airports of intended use, and the following takeo ff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil a ircraft 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 airport elevation and runway slope, aircraft gross weight, and wind an d temperature. 20This 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. An equival ent level of safet y will be provided by Peace of Thorn Productions LLC ‘s rules of operations, described above, for maintenance and use of safet y check lists prior to each flight, which will allow for an equivalent level of public safet y . The PI C will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
**R .**  **14 C.F.R. 91.103 (a)**  **(b) (1) and**  **(2): Preflight procedures and a**  **ction.** Peace of Thor

n Productions LLC requests an exemption from 14 C.F.R. 91.103 (a) (b) (1) (2). This part provides: "Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— .. . (b) For an y flight, runway

lengths at airports of intended use, and the following takeoff and landing distance information: ... (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 airport elevation and runway

slope, aircraft gross weight, and wind and temperature." The Peace of Thorn Productions LLC pilot in command in fact will, before beginning a flight, bec ome familiar with all available information concerning that flight. However, as the flights of the sUAS will not be at airports the information required of Part 91.103(b)(2) does not apply . However, as a condition to the approval of exemption, Peace of Tho rn Productions LLC shall perform preflight operations as outlined previously in this Petition. **S. 14 C.F.R. 91.105: Flight crewmembers at stations.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to the sUAS carry ing no flight crewmembers. However, to achieve an equivalent level of safet y, Peace of Thorn Productions LLC will not operate the aircraft unless someone is at the controls at all times.
**T. 14 C.F.R. 91.109: Flight**  **instruction; Simulated instrument flight and certain flight tests.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.109.
21This part 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 full y functioning dual controls. Remotely

piloted aircraft, including the sUAS here, are designed and constructed without dual controls. Flight control will be 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. See Exemption Nos.577 8K & 9862A. The equivalent level of safet y is provided b y t he very limited size and speed of the aircraft and by the fact that neither a pilot nor passengers will be carried in the aircraft.
**U. 14 C.F.R. 91.113(b): Right** 
**- of** 
**- way rules: Except water**  **operations.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 113(b) to the extent that it applies to overhead aircraft operating at or above 6 00 feet AGLas the sUAS will be operating no higher than 400 feet AGL. This part provides: “( b): General. When weather conditions permit, 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. Whe n a rule of this section gives another aircraft 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." For example, if another aircraft is operating overhead at 10,000 feet AGL there is no danger posed to that other aircraft if the sUAS is operating under it or ahead of it at or beneath 400 feet AGL. However, as a condition to the approval of exemption, Peace of Thorn Productions LLC will operate its sUAS to see and avoid and give way to other aircraft that should enter airspace at or below 400 feet AGL.
**V .**  **14 C.F.R. 91.115: Right**
**- of** 
**- way rules: water operations.**  This Part does not apply

as Peace of Thorn Productions LLC does not plan on operations on or over bodies of water in the near future.
**W. 14 C.F.R. 91.119: Takeoff and Landing.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.119. Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft b elow the following altitudes: 22(a) An ywh ere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or propert y on the surface. (b) Over congested areas. Over an y congested area of a cit y, 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 surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation 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 routes or altitudes specific all y prescribed for helicopters b y 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. Peace of Thorn Productions LLC will not operate the sUAS s an y higher than 400 feet AGL. Furthermore, while Peace of Thorn Productions LLC will not be operating over an y congested areas, the sUAS s will necessarily be flown closer to 500 feet to the structures it will be examining (as well as closer than 500 feet to the ground). The operations by Peace of Thorn Productions LLC of the sUAS s as set out previously provide for at least an equivalent level of safet y of manned aircraft maintaining a distance of at least "500 feet to an y person, vessel, vehicle, or structure" due to the small size and relatively light weight of the sUAS; and the close monitoring of the flight b y both the pilot in command and the secondary

ground crewmember. Peace of Thorn Productions LLC will however be operated in a restricted area with securit y perimeter, where buildings and people will not be exposed to operations without their pre - obtained consent . Also, n o flight will be taken without the permission of the propert y owner or local officials. Because of the advance notice to the propert y owner and participants in the filming activity , all affected individuals will be aware of the planned flight operations as set forth here in

.

23Compared to flight operations with aircraft or rotorcraft weighting far more than the

maximum 55lbs. propos ed herein and the lack of flammable fuel, an y risk associated with these operations is far less than those presentl y presented with conventional aircraft operating at or below 500 AGL in the movie industry . In addition, the low

- altitude operations of the s UAS s will ensure separation between these small

- UAS s operations and the operations of conventional aircraft that must comply with Section 91.119.
**X . 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General.**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.119 subparts (b) and (c). This regulation provides: "Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes:... (b) Over congested areas. Over an y congested area of a cit y, town, or settlement, or over an y 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 surface , except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure.” Peace of Thorn Productions LLC will not operate the sUAS an y higher than 400 feet AG L. Furthermore, while Peace of Thorn Productions LLC will not be operating over an y congested areas, the sUAS will necessarily be flown closer to 500 feet to the structures it will be examining (as well as closer than 500 feet to the ground). The operatio ns by Peace of Thorn Productions LLC of the sUAS as set out previously provide for at least an equivalent level of safet y of manned aircraft maintaining a distance of at least "500 feet to an y person, vessel, vehicle, or structure" due to the small size an d relatively light weight of the sUAS; and the close monitoring of the flight b y both the pilot in command and the secondary

ground crewmember. Peace of Thorn Productions LLC will however be operated in a restricted area with securit y perimeter, where bui ldings and people will not be exposed to operations without their pre - obtained consent . Also, n o flight will be taken without the permission of the propert y owner or local officials.
24Because of the advance notice to the propert y owner and participants in the filming

activity , all affected individuals will be aware of the planned flight operations as set forth here in

. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, an y risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry . I n addition, the low

- altitude operations of the sUAS s will ensure separation be tween these small

- UAS s operations and the operations of conventional aircraft that must comply

with Section 91.119.
**Y .**  **14 C.F.R. 91.121: Altimeter Settings .**  Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.121. This Part pr ovides guidelines for altimeter use below 18,000 feet mean sea level (“MSL ”) in maintaining the cruising altitude or flight level of the aircraft. Peace of Thorn Productions LLC 's operation of the sUAS will not exceed 400 feet AGL and will be operated in a fashion that is not a sustained cruising flight such as a manned aircraft will t ypically fly. The laptop used in the ground station has live feedback information about the sUAS, including but not limited to the height of the sUAS, its forward velocity, an d compass heading. The operator will be able to observe and control the maximum height of the sUAS. Additionally , the sUAS will be operated within the line of sight. Therefore, the equivalent level of safety provided by

Section 91.121 will be met.
**Z .**  **14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. Part 91.151. This Part provides that: “(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 intended landing and, assuming normal cruising speed

— (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that fo r at least 45 minutes (b) No person may

begin a flight in a rotorcraft 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, t o fly after that for at least 20 minutes.”
25The sUAS s Peace of Thorn Productions LLC will fly is electric in nature, using lithium poly mer batteries that currentl y have a flight limit of approximately no more than 15 minutes. Therefore, due to the li mitations of the batteries it is currentl y impossible to comply with Part 91.151. However, the sUAS will be operated in a manner with at least the same equivalent of safet y as that of a manned aircraft compl yi ng with Part 91.151 because the short distances the sUAS s will be operated in, far less than one mile, will allow the sUAS s to be flown to a safe landing point within the area of operation within a short period of time and well within the minimum level of reserve capacit y of the batteries. During the entire preprogrammed flight, the operator will alway s have a visual line of sight and be prepared to take over. Pilot’s radio transmitter ("Tx") has a flight count down timer which is set to a minimum of 20% battery reserve defined as allowing an additiona l 3 minutes of flight time

- more than enough to safel y fl y the sUAS s back to the roped off “home” area. This operation procedure adequately complies with ASTM standard F3005 − 14 4.3.1 (Standard Specification for Batteries for Use in Small Unmanned Aircra ft S ys tems (sUAS)). The timer begins from the point the throttle is moved out of its start position. The battery

powering the sUAS provides approximately 15 minutes of powered flight. As a result, the sUAS would never meet the 30 minute reserve requirement. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in day light VFR conditions is reasonable. Peace of Thorn productions LLC believes that an ex emption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with Section 91.151 (a)). Given the limited size and speed of the sUAS, its ability to land s afel y almost anywhere, that it will be under the operator and the observer’s visual observation at all times, and that it will be operating in a tightly controlled area, where all people, other than the operator and the observer, will be removed before fli ght, permitting its operation with less than 30 minutes of reserve fuel does not engender the ty pe of risks that Section 91.151(a) was intended to alleviate. Peace of Thorn Productions LLC believes that an equivalent level of safety can be achieved b y lim iting flights to 12 minutes or the time when 20% of battery power remains, whichever happens first. This restriction would be more than adequate to allow the sUAS to reach its planned landing zone. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.
**AA .**  **14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required.**

26Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.203(a) and

(b). This section provides in 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... (2) An effective U.S. registration certificate issued to its owner... (b) No pers on may

operate a civil aircraft unless the airworthiness certificate required b y 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 .” First, there are currently

no procedures by

the FAA for providing airworthiness certificates for sUAS. However, as a condition to the approval of exemption, Peace of Thorn Productions LLC will display on the sUAS a registration certificate or equivalen t that is issued by FAA pursuant to this petition at the ground point control, where the operator will have immediate access to them. Second, the sUAS Peace of Thorn Productions LLC will use the DJIS800 EVO or Phantom II or similar, which has an equivale nt level of safet y as manned aircraft with an airworthiness certificate. Both the DJ I A2 and the DJI2.4 GHz I SM; Intelligent Orientation Control (I OC) flight controller provides a number of safet y features in addition to acting as the command and control Rx bound to the Futaba brand Tx, including automatic return to home if the radio control link is broken, referred to as a failsafe. Because of the use of GPS with the sUAS, the operator will set the initial location of flight takeoff ("home position") and if the radio control link is broken, both the DJ I A2 and the DJI2.4 GHz I SM; Intelligent Orientation Control (IOC) flight controller will recognize this broken control link and cause the sUAS to automatically return to the home position as recorded by th e GPS instrumentation. Additionally , because the sUAS team will mark off an area with traffic cones that has a 20 ft. radius, approximately 30 ft. from the operators that will be used as the “home position” for the sUAS to return, no one will be standing i n the way of the path. (See Exhibits 1, 2). In the restricted environment and under the conditions proposed, operation of the sUAS s 27will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certific ate without the restrictions and conditions proposed. Peace of Thorn Productions LLC will not accept assignments from clients who are within 5 miles of controlled airspace without first gaining written and/or oral permission from air traffic control. The sUAS to be operated hereunder is less than 15 pounds inclusive of batteries and technical pay load, carries neither a pilot nor passengers, and carries no explosive materials or flammable liquid fuels. The sUASs operating under this exemption will be tight ly controlled and monitored by

the operator and the observer, and under the requirements and in compliance with local public safet y requirements, to provide security for the area of operation. The FAA will have advance notice of all operations. These safet y enhancements provide a greater degree of safet y to the public and property

owners than conventional operations conducted with airworthiness certificates issued under Subpart H. Lastly , application of these same criteria demonstrates that there is no cred ible threat to national securit y 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 pay load.
**BB. 14 C.F.R. 91.215: ATC Transponder**  **and Altitude Reporting Equipment and Use .**  This section requires that installed Air Traffic Control (ATC) transponder equipment must meet specific performance and environmental requirements, and aircraft must be equipped with an operable coded radar beacon transponder. There are presentl y no known commerciall y available ATC transponders that meet the pay load requirements of a sUAS and are available at reasonable cost. However, because the sUASs used by Peace of Thorn Productions LLC will not be fly ing into or near airports, and will fly no higher than 400 feet AGL, there is very low risk of collision with any manned aircraft. In addition, because there will be no need to have contemporaneous communication with Air Traffic Control, due to the short distances , short flight times, and restricted altitude the sUASs will operate within, Peace of Thorn Productions LLC requests an exemption from this section. Additionally , the sUAS is too small to contain ATC transponder equipment in any form factor that is known t o be available commercially.
**CC .**  **14 C.F.R. 91.403: General .**  This section requires that the owner or operator of an aircraft is primaril y responsible for maintaining that aircraft in an airworth y condition. Peace of Thorn Productions LLC will adhere t o this requirement. 28However, this Section also limits maintenance to that “prescribed in this subpart and

other applicable regulations, including part 43 of this chapter.” Because of this limitation, and because of the exemptions under Part 43 request ed above, Peace of Thorn Productions LLC requests an exemption from this Section. This exemption meets the requirements for an equivalent level of safet y pursuant to Section 333 based on the small size, light weight, relativel y slow speed, and use in controlled rural environments on private, secured land, as described previously in this petition.
**DD .**  **14 C.F.R. 91.405 (a) and (d): Maintenance Required .**  This section requires that aircraft be inspected as proscribed b y Section E, 14 C.F.R. §§91.401

- 91.4 21. As shown below, Peace of Thorn Productions LLC is apply ing for an exemption for these sections, due to the fact that its operators will inspect the sUAS prior to each flight and keep maintenance records of all parts that are replaced. Because the Secti ons discussed below are concerned with manned aircraft, and as such have inspection requirements designed for the safet y of passengers, they are inapplicable to Peace of Thorn Productions LLC

. Peace of Thorn Productions LLC is also appl yi ng for an exempt ion to subpart (d) of this section, which requires a placard to be installed and references §43.11. As noted previously , Peace of Thorn Productions LLC requests an exemption to the placard requirement, because, due to the small size of the sUAS, there is n o room to place the placard. As an alternative and to achieve an equivalent level of safet y, Peace of Thorn Productions LLC will keep logbooks detailing all repairs. Despite the requested exemption from subparts (a) and (d) of this section, Peace of Thorn Productions LLC will follow subparts (b) and (c) of this subpart.
**EE. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding,**  **or alteration .**  This section requires that any aircra ft which “has undergone maintenance, preventative maintenance, rebuilding, or alteration unless . . . [i]t has been approved for return to service b y a person authorized under § 43.7 of this chapter . . ..” However, Peace of Thorn Productions LLC has re quested an exemption from §§ 43.7 and 43.11 as described previously

.

29The capability of the operators to maintain and repair the sUAS meets the requirements for an equivalent level of safet y pursuant to Section 333 for both type s of sUAS s , its intende d use, and the operating environment. Additionally , due to the small size of the sUAS, there is no room to place inspection placards. Therefore, because Peace of Thorn Productions LLC has requested an exemption from 43.7 and 43.11, Peace of Thorn Producti ons LLC respectfull y requests an exemption from 91.407. To achieve an equivalent level of safet y, Peace of Thorn Productions LLC will regularly inspect and maintain its sUASs in accordance with the DJ I operator manual, and keep detailed inspection records as described above. **FF. 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding or alteration**  **.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. Part 91. 407(a)(1) . This Part provides that:
A ny aircra ft which “has undergone maintenance, preventative maintenance, rebuilding, or alteration unless . . . [i]t has been approved for return to service b y a person authorized under § 43.7 of this chapter . . ..” However, Peace of Thorn Productions LLC has re quested an exemption from §§ 43.7 and 43.11 as described previously

. The capabilit y of the operators to maintain and repair the sUAS meets the requirements for an equivalent level of safet y pursuant to Section 333 for both type s of sUAS s , its intended use, and the operating environment. Additionally , due to the small size of the sUAS s , there is no room to place inspection placards. Therefore, because Peace of Thorn Productions LLC has requested an exemption from 43.7 and 43.11, Peace of Thorn Productions L LC respectfull y requests an exemption from 91.407. To achieve an equivalent level of safet y, Peace of Thorn Productions LLC will regularly inspect and maintain its sUASs in accordance with the DJ I operator manual, and keep detailed inspection records as de scribed above. **GG .**  **14 C.F.R. 91.409: Inspections .**  This section lay s out the requirements for inspections of aircraft. Peace of Thorn Productions LLC respectfully requests an exemption from these requirements because they are intended to maintain the safet y of manned aircraft significantl y larger and capable of significantl y longer flights than the Phantom II and the DJ I S800. 30Peace of Thorn Productions LLC does have an inspection procedure. Prior to each flight,

the operator will conduct an inspec tion of the sUAS. The steps of this pre

- flight inspection include: a). Check the following proponents for damage during transport: Airframe; Connections; and Propellers. b) Calibrate the camera. c) Verify

voltage and settings for main flight Tx and the gimbal Tx. d) Measure voltage for dual battery

. e) Cy cle through different control modes of the Flight Tx observing LED lights for good connection and response. f) Cy cle through all controls of the Gimbal Tx making sure the gimbal and camera r espond to commands. g) Activate engine power without moving throttle up to check that the automatic throttle kill works. After each flight, Peace of Thorn Productions LL C will conduct the following post

- flight inspection: a) Blow sUAS with compresse d air to remove dirt and dust. b) Wipe down sUAS with a cloth to remove dirt and dust. c) Check each electrical connection to make sure it is still intact. The pre

- flight and post

- flight inspections meet or exceed the level of safet y achieved b y adher ence to 14 C.F.R. 91.409

. **HH. 14 C.F.R. 91.409(a)(2): aircraft issuance of airworthiness certificate inspection**  **.** Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.203(a) and (b). This section provides in part:
T hat no person ma y operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. This section lay s out the requirements for inspections of aircra ft. 31Peace of Thorn Productions LLC respectfull y requests an exemption from these requirements

because they

are intended to maintain the safet y of manned aircraft significantly larger and capable of significantl y longer flights than the Phantom II and the DJ I S800. Peace of Thorn Productions LLC does have an inspection procedure. Prior to each flight, the operator will conduct an inspection of the sUAS. The steps of this pre

- flight inspection include: a). Check the following proponents for damage during transport: Airframe; Connections; and Propellers. b) Calibrate the camera. c) Verify

voltage and settings for main flight Tx and the gimbal Tx. d) Measure voltage for dual battery

. e) Cy cle through different control modes of the Flight Tx observing LED lights for good connection and response. f) Cy cle through all controls of the Gimbal Tx making sure the gimbal and camera respond to commands. g) Activate engine power without moving throttle up to check that the automatic throttle kill w orks. After each flight, Peace of Thorn Productions LL C will conduct the following post

- flight inspection: a) Blow sUAS with compressed air to remove dirt and dust. b) Wipe down sUAS with a cloth to remove dirt and dust. c) Check each electrical connection to make sure it is still intact. The pre

- flight and post

- flight inspections meet or exceed the level of safet y achieved b y adherence to 14 C.F.R. 91.409

. **II . 14 C.F.R. 91.417: Maintenance records**  **.** Peace of Thorn Productions LLC respectfull y requests an exemption from this Section, as it is only

applicable for aircraft with an airworthiness certificate. Because Peace of Thorn Productions LLC will not have an airworthiness certificate, this Section is inapplicable. As an alternative and to ach ieve an equivalent level of safet y, Peace of Thorn Productions LLC will keep detailed maintenance on every part as it is replaced, including but not limited to propellers, batteries, and electrical components. 32**JJ. 14 C.F.R. 91.417(a) and (b): Owne r/Operator records of maintenance for aircraft**  **.**

Peace of Thorn Productions LLC requests an exemption from 14 C.F.R. 91.417(a) and (b)

. S ection 91.417(a) and (b) prescribes, in pertinent part, that : (a) Each registered owner or operator shall keep the fo llowing records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriat e, 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 o f 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 engi ne, 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 applic able airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety 33directive number and revision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 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 f or the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) o f this section shall 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 approved for return to service. Peace of Thorn Productions LLC respectfull y requests an exemption from this Section, as it is only

applicable for aircraft with an airworthiness certificate. Because Peace of Thorn Productions LLC will not have an airworthiness certificate, this Section is inapplicable. As an alternative and to achieve an equivalent level of safet y, Peace of Thorn Productions LLC will keep detailed maintenance on every part as it is replaced, including but not limited to propell ers, batteries, and electrical components.

34**Exhibit 1: Aerial Inspection Procedures** 

**Location:** Under contract with a utility company , community

municipalit y within and surrounding the vicinity

of Chicago , Illinois and Northwest Indiana co unties of Lake and Porter activities of commercial utilization of sUASs infrastructure inspection will commence. The utility companies , community

municipalities properties are privately owned with some located in rural and semi

rural areas. Vast majorities of the properties owned by the utility

companies and community municipalities are fenced off and host some sort of securit y presence which restricts public access and which also provides safet y for the public. All of the utility companies’ and community

municipalities’ properties are in Class G airspace. **Purpose of Flight:** The primary

purpose of work is to safel y, accurately, and efficientl y create aerial utility compan y and communit y municipality material inspection imaging. The sUAS will video tape, an d collect video photographs, which will allow for the inspect ion of equipment to determine maintenance and repairs, and use specialized video, and photograph y software to process, prepare, and display

the results. The final imaging output will be HD high r esolution aerial imaging. **Flight Crew, Equipment and Typical Flight:** For information regarding the flight crew, equipment, and ty pical flight, please refer to pages three through ten of the petition, above. **Current Methods:** Currently these utility company

inspection operations involve having a crew of 4 or 5 technicians with two or three persons spending hours prepping, mounting and then climbing electrical towers to inspect for damage and worn out material at each tower location under dangerous con ditions, and with the risk of life threatening scenarios. Moreover, another current practice of utility

company inspection operations involve the use of a helicopter with 3 or 4 persons fl yi ng at very

low altitude try ing to achieve an aerial visualization of damaged and worn out tower structure and electrical wiring material which is extremely dangerous for all involved including surrounding structures and high power electrical lines with the risk of propert y damage, human injury

or worst death. In contrast , a sUAS weighing less than 15lbs. and is powered b y batteries eliminates virtually all of the risk for propert y damage, human injury, or death. 35**Exhibit 2: Aerial Photography Procedures** 

**Locations:** These locations are spread across the Chicago metropolitan area, encompassing portions of Northwest Indian counties of Porter and Lake. The photograph y areas will be accessed with the permission and consent of those owning and willing to be p hotographed. Many if not all areas are in Class G airspace. Finall y, man y of these photograph y areas host secured boundaries with limited public access and others exist in public areas. **Purpose of Flight:** The primary

purpose of the work is to safel y, a ccuratel y, and efficientl y create aerial scenic photographic, and cinematographic pictures for public viewing via art gallery , Flicker Website, YouTube, film and videograph y display

. This is comprised of HD high resolution aerial imaging. The work is done using a sUAS to collect photos or pictures, and specialized photo and video software to process the data. **Flight Crew, Equipment and Typical Flight:** For information regarding the flight crew, equipment, and ty pical flight, please refer to pages three and ten o f the petition, above. **Current Methods:** Currently these ty pes of aerial scenic photographic and cinematographic pictures are taken and require a helicopter involving two to four or five persons fl yi ng at very low altitude try ing to achieve an aeria l photo or picture which is extremely dangerous for all involved including surrounding structures and high power electrical lines with the risk of propert y damage or worst death. In addition, motor vehicles with mounted film cranes which extent 25 to 30 fe et over and past the motor vehicle’s center of gravit y requirements to achieve an aerial photo or picture effect are currently used which is also very dangerous for all involved because of the high risk of the motor vehicle crashing into people, other moto r vehicles, and buildings causing propert y damage, human injury or death. By flying over a scene using a sUAS these hazards are removed. Further the sUAS can do the work in under 15 minutes which previously took two too four men multiple hours to do

.

36**Exhibit 3: Scripted Closed**
**- Set Filming and Videography** 

**Location:** These locations are spread across the Chicago metropolitan area, and encompassing portions of Northwest Indian counties of Porter and L ake. The secured scripted closed

- set filming and videotaping areas will be accessed only with permission , and consent of those in the film and video. These areas are abundant with aerial scenic, photographic, and cinematographic opportunities with many

areas providing secured time limited access which gr eatl y reduces hazardous conditions for the public. These areas are over 10 miles away from any major or minimal municipality

airport , and are in Class G airspace to protect the public from hazardous conditions. **Purpose of Flight:** The primary

purpose of the work is to safel y, accuratel y, and efficientl y create aerial scenic, photographic, cinematographic imaging. The sUAS will film, video tape, and collect photographs of scripted closed

- set scenes acted out by actors and actresses , and use specialized fil m, video, and photography software to process, prepare, and display the results. The final imaging output will be HD high resolution aerial imaging. **Flight Crew, Equipment and Typical Flight:** For information regarding the flight crew, equipment, and ty p ical flight, please refer to pages three and ten of the petition, above. **Current Methods:** Currently these t ypes of scripted closed

- set aerial scenic photographic and cinematographic pictures are taken and require a helicopter involving two to four or f ive persons fly ing at very

low altitude try ing to achieve an aerial scene which is extremely dangerous for all involved including surrounding structures and high power electrical lines with the risk of propert y damage or worst death. In addition, motor veh icles with mounted film cranes which extent 25 to 30 feet over and past the motor vehicle’s center of gravity requirements to achieve an aerial scenic effect are currentl y used which is also very dangerous for all involved because of the high risk of the m otor vehicle crashing into people, other motor vehicles, and buildings causing property

damage, human injury

or death. 37By

fl yi ng over a scene using a sUAS these hazards are removed. By fl yi ng over a scene using a sUAS these hazards are removed. Furthe r the sUAS can do the work in under 15 minutes which previously

took two to four men multiple hours to do

.

38

## Exhibit 4:

**DJI Phantom II User Manual Please see attachment Title:**  **Phantom II_ U**  **ser_Manual_v1.2_en.pdf**

39

## Exhibit 5
**DJI Phantom II Specs Please see attachment Title:**  **Phantom II Specs.pdf**

40

## Exhibit 6

**Spreading Wings S800 EVO User Manual Please see attachment Title:**  **S800_EVO_User_Manual_v1.10_en.pdf**

41

## Exhibit 7
**Spreading Wings S800 Specs Please see attachment Title:**  **Spreading Wings S800 EVO Specs.pdf**

42

## Exhibit 8

**A2 Flight Control System User Manual Please see attachment Title:**  **A2_Quick_Start_Guide_v1.2_en.pdf A2_Quic**  **k_Start_Guide_v1.04_en.pdf**

43

## Exhibit 9
**A2 Flight Controller Features Please see attachment Title:**  **A2_Quick_Start_Guide_v1.04_en.pdf**

44

## Exhibit 10

**A2 A New Standard in Flight Control Please see attachment Title:**  **A 2 A New Standard in Flight Control.pdf** 

45

## Exhibit **11**

**Michael J ,**  **Barnes, Beverly G Knapp, Barry W.**  **Tillman, Brett A. Walters & Darlene**  **Veliki, Crew systems analysis of unmanned**  **aerial vehicle (UAV) future job and tasking en**  **vironments , Technical Report ARL** 
**- TR** **- 2081, Aberdeen Proving Ground, MD: Army**  **Research Laboratory (2000) Please see attachment Title:**  **ADA374230.pdf**

46

# Exhibit **12**

**W illiams, K.W. (2007).**  **Unmanned Aircraft Pilot Medical**  **Certifica tion Requirements,**  **Report DOT/FAA/Am**
**- 07/3,**  **FAA Civil Aerospace Medical Institute**  **Please see attachment Title: ua**  **- pilot.pdf** 

47

## Exhibit **13**

**McCarley, J.S. and Wickens, C.D. (2004). Human Factors**  **Implications of UAV’s in the Nat ional Airspace.**  **Institute of Aviation, Aviation Human Factors Division. University of**  **Illinois at Urbana**
**- Champaign.** 

**Please see attachment Title: uavPlanFinal.pdf** 

48