Petition for Exemption filed under section 333

Petitioner: Eagle Eye Media Inc. 164 7 Bridgeview Circle Eagle Eye Media Inc. Orlando, FL 32824 President: Frank B. Maldonado CEO: Jimmy Maldonado EagleEyeMediaGroup@gmail.com
To: Secretary of Transportation/ FAA Docket Operations, M

-30; U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE, Room W12
- 140, West Building Ground Floor Washington, DC 20590

-0001
Dear Sir/ Madam: Eagle Eye Media Inc. is petitioning for 333 exemption from the Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption would allow Eagle Eye Media Inc. to operate the DJI PHANTOM 3 Professional quad

- copter unmanned aircraft system (UAS) to conduct aerial videography and cinematography to enhance academic community awareness for those individuals and companies unfam iliar with the geographical layout of the state of Florida and produce real estate listing videos and photos.
We support our request with the following information: Eagle Eye Media Inc. has provided the following information
– con tained in the petition an d supporting documentation including: 1) Supplemental Response for Petition, 2) PHANTOM Flying Flow Chart V1.0 (Simplified Version), PHANTOM 3 Professional Quick Start Manual v1.0, PHANTOM 3 Professional Safety Guidelines and Disclaimer Advanced Manual v.1 .0, 3) PHANTOM 3 Professional Intelligent Flight Battery Safety Guidelines User Manual 4) restricted areas map, 5) personal protocols and controls, and 6) Safety/Flight Manual (all hereinafter referred to as operating documents).Eagle Eye Media Inc. has organized the FAA petition into four sections: 1) the unmanned aircraft system

(UAS), 2) the UAS Pilot in Command (PIC), 3) the UAS operating parameters and 4) Public Interest.



### Unmanned Aircraft System Eagle Eye Media states that we plan to operate a UAS, the DJI PHANTOM 3 PROFESSIONAL, which is comprised of an unmanned aircraft (UA or PHANTOM) and a transportable ground station.

The PHANTOM 3 PROFESSIONAL is a quad

- copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by a patented Intelligent Flight Battery which gives accurate and constant voltage communication to controls
. The UA has built in integrated flight solutions such as GPS capabilities, GPS

- Enabled Return to Home system which kicks in if communications are ever lost with the PHANTOM 3 PRO. The UA also has built in visual positioning system which stabilizes the UA for further flight safety in/outdoors. The UA has a maximum ai rspeed of 31.1 knots. Phantom 3 Pro has a built in Sony EXMOR 4k camera which is built into the UAS and provides live 720p visual streaming to the control in real time and has a range of 1.25 miles which also demonstrates in real time system controls and flight information such as altitude, vertical/horizontal/ ascending/descending directly to monitor on the control. Camera and built in features are included in gross weight to his UA, and will operate the U A over various areas in Florida to enhance academic community awareness and produce real estate listing videos and photos
. All specifications found in the Quick Start Manual provided with petition. We also have obtained UAS insurance for commercial purposes and will provide proof of that with operational documentation.
Eagle Eye Media Inc. makes the following representations of o pe rational enhancements which we will abide by to ensure the exemption provide s a level of safety at least equal to existing rules:

• We will only operate in reasonably safe envi ronments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and

• We will conduct extensive preflight inspections and protocols, during which safety carries primary importance.
Eagle Eye Media Inc. states that given the size, weight, speed, built in intelligence, and limited operating area of 1.25 miles ( which a spotter will be used at all times, using Celestron SkyMaster 20

- 100x70 Zoom binoculars to keep within sight at all times for further safety) associated with th e aircraft to be utilizedby Eagle Eye Media Inc
. an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §

91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warra nted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112
-95 (Section 333).
Eagle Eye Media Inc
. requests an exemption from § 45.23 Mar king of the aircraft because the UA will not have a cabin, cock pit or pilot station on which to mark certa in words or phrases. Further, we state that two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement . Regardless of this, Eagle Eye Media Inc . state that we will mark his UAS in the largest possible lettering by placing the word “EAGLEEYEMEDIAINC” and gold, blue, and silver stickers on its fuselage as required by § 45.29(f) so that we or anyone assisting as a spotter will see the markings. We w ill never fly in conditions deemed unfit to keep visual line of sight, this includes unfit wind conditions, cloudy weather deemed unfit to keep visual line of sight, rain, nor will we operate at altitudes lower than 20 feet relative to any object or person s.
Eagle Eye Media Inc
. states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness cert ificate. However, we will as a safety precaution always perfo rm a preflight and post flight inspection of the UAS before each flight as outlined in the operating documents.



### UAS Pilot in Command (PIC) Driver’s License of PIC included substituting the need for current medical certificate.

 Eagle Eye Media Inc
. asserts that under § 61.113 (a) and (b) private pilot s are limited to non

commercial operations, however we can achieve an equivalent level of safety as achieved by current regulations because the UAS does not carry any pilots or passengers. Further, he states that, while helpful, a pilot license will not ensure re mote control piloting skills. We further indicate that the risks of operating a UAS are far less than the risk levels inherent in the commerc ial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.

 Regarding UAS operational training, we have flown numerous practi ce flights in remote areas as hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of the UAS’ performance under different temperature and weather conditions. We further state that we practice computerized simulated flights daily to maintai n adequate skills and response reflex time. We have over 6 years of experience flying as hobbyist and are capable of flying nitro copters which are for the highly skilled and are much more complex than the PHANTOM 3 PROFESSIONAL. The (PIC) has had 6 months experience with the current PHANTOM 3 PRO model.In a supplemental re quest to the FAA, Eagle Eye Media Inc
. requests consideration of a 120 day

temporary airman certificate in accordance with § 63.13, to allow us time to obtain a private pilot certifica te or to allow the FAA time to establish minimum UAS airman certification standards.



### Public Interest Eagle Eye Media is dedicated to the safety of the public first and foremost, we have acquired the latest and safest in DJI technology in the PHANTOM 3 PRO and will take every precaution as listed in this petition to provide the highest levels of safety. Eagle Eye Media Inc. will provide services to Realtors and other industry professionals to further the integration of technology into small business firm s . We will also help those not familiar with certain geographic aspects of Florida to safely exp lore and advance scientific / academic research within our state. All while providing the highest standards of safety combining flight experience and the techno logy the DJI PHANTOM 3 PRO has already integrated. Eagle Eye Media Inc. states that aerial videography and photography for geographical familiarization and for real estate marketing purposes has been around for a long time through manned fixed wing aircraft and helicopters. F or small business owners though, the expense s have been cost

- prohibiting . Granting t his exemption would allow Eagle Eye Media Inc. to provide this service at a much lower cost. Eagle Eye Media Inc. indicates our small UAS will pose no t hreat to the public given its small size and lack of combustible fue l when compared to larger aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economic growth by providing information to compani es looking to relocate o r build in the Central Florida area.


### UAS Operating Parameters Eagle Eye Media Inc. will abide by the following additional operating conditions under this exemption: We shall abide by all procedures contained in the operating docume nts and will actively analyze flight data and other sources of information to constantly upda te and enhance safety protocols • operate our UAS below 300 feet and within a radius distance of 1000 feet from the controller to both aid in direct l ine of sight visual observation • operate our UAS for 5

-8 minutes per flight; • land UAS prior to the manufacturer’s recommended minimum level of battery power; • operate UAS only within visual line of sight (VLOS); • use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;
• conduct all operations under our own personal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress
– Remain Back 150 feet”)• Contact respective airports if operations will be with in 5 miles to advise them of estimated flight time,

flight duration, elevation of flight and other pertinent information;
• Always obtain all necessary permi ssions before any operation; and • have safety protocols in place to abort flights in the event of safety breaches or potential danger. • operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas away from public and traffic; • We will not operate within the 4 mile proximity of any airport as required by FAA regulations. Included in the operations manual are the NO FLY ZONES listed by DJI which Eagle Eye Media states we will strictly adhere to. Florida is a flat geographical area for the most part, our goal to keep a direct line of sight will include the help of at least 1 spotter at all times (driver’s license substituted for medical certificate) who will use h igh powered binoculars to keep the UAS in sight at all times. Eagle Eye Media Inc. does not plan to fly above the 400ft restriction already set in place. The UAS has a failsafe which enables GPS to safely guide the UAS back to the pilot to regain full cont rol if radio communications are ever lost.
• Preflight safety risks assessment will be conducted prior to every UA flight. This will comprise of research done days in advanced of location to be flown, including weather conditions, highest point of trees and property, geographically familiarizing ourselves with the area using technologies such as google earth and google maps, making sure no powerlines are around, research of the population of the area through public records, are all part of the preflight s afety risk assessment but is not limited to these processes. Preflight inspection on the UA and intelligent batteries as detailed in the operations manual are always conducted, as well as post flight.
Eagle Eye Media Inc. states that § 91.7(a) prohibits t he operation of an aircraft without an airworthi ness certificate. Eagle Eye Media Inc. asserts that since there is currently no certificate applicable to our operation s, this regulation is inapplicable. Eagle Eye Media Inc. also states that § 91.9(b)(2) re quires an aircraft flight manual in the aircraft, however since there are no p ilots or passengers on board the aircraft and given its size, this regulation is inapplicable. Eagle Eye Media Inc. further indicates an equivalent level of safety will be achieved by maintaining a hand written flight log for all operations as well as flight manuals at ground station at all times
. Also for exemption from; Each registered owner or operator shall keep the following 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 appropriate, 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 of 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 engine, 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 applicable airworthiness directives (AD) and safety directives including, for e ach, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapte r 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 for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the ai rcraft 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 a pproved for return to service.

 Safety/flight manual s shall stay with the U AS ground station at all times
.  Proof of insurance will be provided upon receiving exemption.