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Center Stage Videos Attn: Matthew T W ise 7517 Keith Lane Sachse, TX 75048 July 7 , 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington DC 20590 Re : Update to Exemption No. 13730 Regulatory Docket No. FAA

- 2015

- 3926. Included is the original exemption that was approved and on page 2 we have added a third type of drone. The DJI Phantom 4 wh ich provides more safety and stability. No other changes have been made to the previously approved document. Dear Si r or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Center Stage Video s , operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. This request for exemption is similar, i f not identical, to many previously submitted requests that have received exemption. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner: 1. Aerial photography and/or video for public and /or private use in Real Estate sales. 2. Aerial video and/or photography for public and/or private use including public events, and cinematography

. 3. Aerial photography of residential/commercial structures under contract with the owners or local government authority. As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the alre ady safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

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The name and address of the applicant is: Center Stage Videos Attn: Matthew T W ise Ph: 817

-490

- 1599 Email: matt@centerstagevideos.com Address: 7517 Keith Lane Sachse, TX 75048 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.3 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) Center Stage Videos will operate a three models of sUASs, the DJI Phantom 2 Vision +, the DJI Phantom 4 and the Cheerson CX

- 20. Each sUAS will be powered using lithium poly mer batteries and controlled with a remote transmitter operating on 2.4Ghz or 5.8Ghz band. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative. Given the small si ze of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requ ested exemption with minimum delay. **AI RCRA** **FT AN**  **D EQUIVA LENT LEVEL OF SA** **FETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. T he applicant agrees to adhere to the following limitations and conditions when conducting commercial operations under the FAA issued exemption. 1. The UAS will weigh less than 55 lbs.

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2. The UAS will have a maximum operating speed of no more than 50mph. 3. Minimum crew for each operation will consist of the UAS Pilot and the Visual Observer (VO). 4. The UAS pilot will be a designated Pilot in Command (PIC) and hold at least a Commercial Pilot’s Certificate. 5. Flights will be operated within lin e of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 6. Ma ximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. 7. Flights w ill be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 8. A briefing will be performed regarding the planned UAS operations prior to each day’s flig ht consisting of all the days’ production activities. 9. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 10. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport unless the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information and approval is given

. 11. The operator will obtain verbal and/or written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within the flight operation area. 12. The PIC and VO will have been trained in operation of UAS

. 13. The PIC and VO will be able to communicate by voice at all times. 14. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously. 15. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. **14 C.F.R. Part 21, Subpart H: A irw**  **orthiness Certificates 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requiremen ts of an e quivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certi ficate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed

. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates

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issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. **14 C.F.R. § 45.23 (b). Marking of the A** **ircraft** The regulation requires: Wh en marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

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

sport," "experimental," or “provisional ," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lette ring will be impossible. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.” **14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.** Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Center Stage Videos may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots , passengers or p roperty. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The pilots used by Center Stage Videos possess current ATP Certificates and have more than 1 year experience in the operation of sUAS s. Center Stage Videos will not utilize pilots with less than Commercial Certificates at any time during commercial operations

. **14 C.F.R. §91.7(a): Civil A ircraft A** **irw orthiness.**  The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. **14 C.F.R. § 91.9 (b) (2): Civil A** **ircraft Flight Manual in the A ircraft.**  Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is availab le in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

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The UAS, given its size and configuration has no ability or place to carry such a flight manual on t he aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the p ilot flying the UAS will have immediate access to it. **14 C.F.R. § 91.103: Preflight A ction** 

. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will review weather, flight battery requirements, and perform a safety check of the area of intended flight to ensure the flight can be conducted safely. **14 C.F.R. §91.119: Minimum Safe A** **ltitudes**

. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter compli es with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AG L, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. **14 C.F.R. §91.121 A ltimeter Settings.**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting avail able before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An eq uivalent level of safety will be achieved by the operator, pursuant to the safety

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check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 C.F.R. § 91.151(a): Fuel Require ments for Flight in VFR Conditions**  Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small U AS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. **14 C.F.R. §91.203 (a) and (b): Carry ing Civil A** **ircraft Certification and Registration** The regu lation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded we ighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these doc uments at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. **14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.** These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in

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paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most fa miliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Additional Information Matthew T Wi se has been involved in the building and piloting of remote controlled aircraft for more than 5 years. Additionally Mr. W ise holds an ATP and is a 121 Designated Examiner for a large regional jet operation. Center Stage Videos second pilot has been in volved in the building and piloting of remote controlled aircraft for more than 10 years and he also holds an ATP certificate and is a Check Airman at the same regional operation. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of the applicant’s UAS. Sincerely,

Matthew T W ise