Outlook Entertainment LLC

625 Forest Ave Havertown, PA 19083

Phone: 610

- 952

- 1776

E

- Mail: steve@otlk.com

Web: www.OTLK.com

August 1 7 th 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey A ve., SE Washington, DC 20590

Dear Sir or Madam:

This application is being submitted on my own behalf without legal council or consulting

services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Pa rt 11, Outlook Entertainment, LLC, operator of Small Unmanned Aircraft Systems (“SUASs”) equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial opera tion of its SUASs, 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 333.1

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive SUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Outlook Entertainment , LLC to conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333.

Outlook Entertainment LLC is an image processing company that plans to exploit the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Event Photography /Videography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlif e and forestry monitoring- Educational and research operations

- 3

- Dimensional Mapping

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

U AS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to

p ermit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested:

14 C.F.R. Parts 21 14 C.F.R. 45.23 (b) 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. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

Unmanned Aircraft System

SUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and pe rsonnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. We are petitioning for exemption to enable Outlook Entertainment, LLC to operate a DJI Inspire 1, a DJI Inspire S1000

, and a DJI Phantom 3, all equip ped with three

- axis gimbals a nd using High

- Def. cameras. These

SUAS have built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace inc luding a no fly zone feature. The Inspire 1 also has the failsafe function of the

Naza

- M autopilot system, which means when the communication between the Main Controller and the transmitter is disconnected, the outputs of all command sticks from

controller will go to the center position. If the GPS signal is good enough, the system will automatically trigger Return to Home and will land safely.

The above specifications meet with the Model Aircraft Operating Standards as set

below:• Outlook Entertainment, L LC will only operate its SUAS in line of sight of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations

will insure that the SUAS will "not cre ate a hazard to users of the national airspace system or the public."

• When flying SUAS within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in the proximity of full

scale aircraft.

• Max imum flight time for each operational flight will be 45 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to

the 30 minute limit.

• The SUAS will be programmed so that it will not be operated at an altitude of no

more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the SUAS Pilot, and Visual

Observer.

• The SUAS operated by the petitioner weighs less than 55 pounds, inc luding the payload (i.e. camera, lens, and gimbal).

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size of the SUAS and the restricted sterile environment within which they will operate, our SUAS operations adhere to the Reform Act's safety requirements

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no p eople on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 20 minutes, this offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The applicants in the past have chart ered 2

- seat full

sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyer s and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitat ions cited in this application as we do so.

a. No flight will be made with a Gross weight exceeding 55 pounds;

b. All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;c. All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation;

d. Operations will be restricted to flights over private property with the permissi on of the property owner;

e. All required permits will be obtained from state and local government prior to operation;

f. Outlook Entertainment, LLC will not operate over densely populated

areas;

g. Outlook Entertainment, LLC will not be operating o ver any open

- air assembly of people;

h. Outlook Entertainment, LLC will not be operating over heavily trafficked roads;

i. Outlook Entertainment , LLC will not be operating within 5 NM of an airport or heliport;

We respectfully request exemption under S ection 333 to enable Outlook Entertainment, LLC to operate efficient, limited, low

- risk commercial SAUS operations for the activities stated respecting at all times the space and privacy of citizens and property whilst keeping our skies safe.

Sincerely,

Stephen McWilliams Scott Barnhill Outlook Entertainment, LLC Outlook Entertainment LLC

www.OTLK.com www.OTLK.com steve@otlk.com scott@otlk.com

610.952.1776 410.598.7111EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Outlook Entertainment, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the SUAS System:

14 CFR P art 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While

the F AA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificat e be issued for the DJI Inspire 1 , DJI Inspire S1000+, and DJI Phantom 3 under either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following

purposes:

a. Research and development. Te sting new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new

uses for aircraft.

b. Showing compliance with regulations. Conducting flight tests and other operations to show compliance wi th the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of th e regulations. Since

th e experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. Th e aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be

at leas t as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate

for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requi rement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each ai rcraft must display "N" an d the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The SUAS does not have an e ntrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We p ropose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where thePIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's regist ration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words

"Unmanned Aircraft Ground Station" in letters 3 inches high or grea ter. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Co mmand and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operati ons require that the PIC must hold at least a Recreational Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the i ntent of this application is t o conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in th e form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft fli ght manual, marking, and placard requirements. This regulation provide s that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual inform ation is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight oper ations. To o btain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved SUAS Flight Manual must be available to the

crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruct ion; Simulated instrument flight and certain flight

tests. The regulation states, "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The SUAS System ground

- based con trol station consists of a small hand

- held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having " hands

- on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be o perated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the SUAS would be photography orsurvey of persons, vessels, vehicles or structures it would be necessary to operate closer

than 500 feet to the items l isted. Operations will only be flown over property or persons where permission has been obtained and careful pre

- flight planning has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing witho ut undue hazard to persons or property on the surf ace. Therefore

we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The SUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the launch and recovery point is transmitted via radio from

the SUAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person ma y begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of inte nded landing and to fly after that

for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The SUAV is battery operated and the maximum duration of flight from a single batt ery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly more than 3f4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exe mption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness cer tificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gr oss weight of 5.3 pounds, the SUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed ap propriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration cert ificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance,

Alterations The regulatio n provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and43. Paragraphs 91.407 and91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the

aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections a nd updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, cons truction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS

Outlook Entertainment , LLC will be using the SUAS in a variety of applications that generally req uire expensive full

- size manned air craft to complete. Small, light, unmanned aerial vehicles offer myriad benefits over the use of full

- sized manned aircraft for electric

power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few . Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. By granting Outlook Entertainment , LLC requested exemptions, th e FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Outlook Entertainment , LLC is committed to promoting the UAS research efforts of policymakers including the F AA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this

Petition.

Conclusion As pointed out in this application, all the SUASs whic h our company would use, under authorization by the US DOT

- FAA, are small, lightweight devices operated within the line of sight of the Pilot

- in

- Command (PIC), less than 400 feet above the ground and

outside 5 miles from any airport, heliport, seaplane bas e, spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

All our SUASs have proven capability for controlled flight. They are devices offered for general sale on the market a round the world and have often been used as Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 112

- 95, 2014, have already provided yo u with the assurances on

the airworthiness of SUAs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and

Outlook Entertainment , LLC should be permitted to conduct small UAS operations in

accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. The submission of this application and its contents is the bestdemonstration that indeed it is possible to pursue the authorization process so that some SUASs may be used for legitimate commercial activities and under reasonably safe

conditions.

OUTLOOK ENTERTAINMENT, LLC

625 Forest Ave Havertown, PA 19083

E

- Mail: steve@otlk.com

Web: www.OTLK.com

Phone: 610.952.1776