Prestige Aerials ( Prestigeaerials .com)

243 E ast Enid Drive Key Biscayne , Florida 331 4 9 Prestigeaerials@gmail .com 305

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Docket Operations, M

- 30 U.S. Departmen t of Transportation Room W12 -14 0, We st Buildin g Groun d Floor 1200 Ne w Jersey Avenue , SE. Washington , DC 205 90- 0001
Re: E xemption Re que st under Se ction 333 of the FAA Reform Act an d Pa rt 11 of the Federal Aviation Regulations Dear Sir or Madam:
Pursuan t to Se ction 33 3 of the FAA Modernization an d Reform Act of 2012 (the “ Reform Act”) an d 14 C. F.R. P art 11 , Videophotog P roductions (Operator) see ks an exemption from Federal Aviation Re gulations (FARs) to allow com mercial operations of their UASs (Unmanne d Aerial Systems) for the p urpose of conducting aerial photogra phy, video, an d survey for v arious industries. Regardi ng the U nmanne d Aircraft Systems
1. The re quested exem ption wou ld support an ap plication for a com mercial Certificate of Authorization (COA) t o use t he b elow d escribed U AS , so lon g a s operations are conducted within an d under t he con ditions outline d herein or as ma y be establishe d by the FAA as required b y S ection 333. Like the FAA, it is t he Operator’s mission to provide the saf e st an d most efficien t means of Civil Commercial implemen tation into the Na tional Airspace Syst em (N AS ). Furthermore , the Operator is comprised of members with the equivalen t of a FAA Com mercial Certificate or higher addin g an ad ditional layer of high regard for saf

e op erations as well as the ne cessary high-level of understandin g of the NAS an d FARs.

 DJI Inspire 1

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Reference Inspire 1 User Manual (EN) v1.0

 The Inspire 1 is a quadcopter UAS capable of capturing 4K video and transmitting an HD video signal to a ground station. Equipped with retractable landing gear, it can capture an unobstructed 360 degree view from its camera. The built-in camera has an integrated gimbal to maximize stability and weight efficiency while minimizing space. When no GPS signal is available, Vision Positioning technology provides hoverin g precision.Docket Operations June 18, 2015 Page 2

2. Reference Inspire 1 Maintenance Manual v1.0 3. Reference Inspire 1 User Manual (EN) v1.0 [FCC Compliance

– Appendix Pg 62] Regarding the Unmanned Aircraft PIC 4. Operator proposes to operate its UASs with a pilot holding, at a minimum, a private pilot certificate.

 The UAS PIC will be trained in advance for the safe operation of the UAS to be operated. This will include operation of the UAS both in normal and emergency modes of operation, and will include familiarization with the user manual published by the UAS manufacturer. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace.

 The PIC must have accumulated a minimum of 100 flight cycles and 25 hours of total time as a UAS pilot and at least 10 hours logged as a UAS’s pilot with a similar UAS type.

 All operations must utilize Visual Observers (VOs). VOs who are not pilots will attend ground training to understand the roles of an observer, communication procedures, and proper visual scan techniques, operations at non-towered airports, and appropriate sections of the Aeronautical Information Manual. 5. The PIC must possess at least a third-class airman medical certificate for all of petitioner’s flight operations. Regarding the Operation of the Unmanned Aircraft 6. Operator proposes Civil Commercial operation of an UAS to operate in the following manner:

o  Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

o  Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.

o  Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.Docket Operations June 18, 2015 Page 3

 Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed (so as long as all other parameters are met contained herein) to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

 The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.

 For additional operator adherence: Reference

– Inspire1SafetyGuidelinesv1.0 7. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s). The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL). The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.

 All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activities.

 Flights will be terminated at 20% battery power. 8. As described fully above, the requested exemption would permit the operation of an UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already 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 s afe operation of such aircraft systems in the national airspace system.”Docket Operations June 18, 2015 Page 4

Given the small size 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 Docket Operations June 18 , 2015 Page 4 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. 9. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with the air port’s management is obtained, and the operation is conducted in accordance with a Notice to Airmen (NOTAM), as required by the operator’s COA. 10. The UAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. 11. Reference

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Inspire 1 Safety Guidelines v1.0
12. Operator’s Point of Contact – Mr. Chris Doherty North Texas FSDO 8700 Freeport Parkway Suite 225 Irving, TX 75063 13. Operator will obtain required COAs once exemption is granted. Exemption Requests and Equivalent Level of Safety
14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 (a)(1) Based on the limited size, weight, operating conditions, design safety features, and the imposed conditions and limitations, Operator has demonstrated that its operations would not adversely affect safety compared to similar operations conducted with aircraft that have been issued an airworthiness certificate under 14 CFR part 21, Subpart H. Therefore, as the FAA found for Astraeus Aerial (http://www.astraeusaerial.com) , Exemption 11062, the requested relief from 14 CFR Part 21, and any associated noise certification and testing requirements of part 36, is not necessary.Docket Operations June 18, 2015 Page 5

14 CFR § 45.23 (b) –Display of marks Since Operator’s UAShas no entrance to the cabin, cockpit, or pilot station on which the markings can be placed, two inch lettering will be impossible. Official marking systems for small UAS have not yet been established for operations inside the NAS. Operator is prepared to mark the UAS with the name of the organization and location nor origin and fulfill any other request by the FAA to this topic in accordance with 45.29 (f) where the pilot, observer, and others working with the sUAS will see the identification of the sUAS. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. 14 CFR § 61.113 (a) & (b) - Private pilot privileges and limitations This regulation provides: (a) This regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. (b) This 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. All the requirements of a private pilot certificate will prepare the UAS operator for the environment that they will be operating in. *Please reference Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating a UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. 14 CFR § 91.7 (a) & (b) - Civil aircraft airworthiness
This regulation provides:
(a) No person may operate a civil aircraft unless it is in an airworthy condition. (b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. While the operator’s UAS will not require an airworthiness certificate, operator is required to ensure that its aircraft is in an airworthy condition

– based on compliance with the operating documents prior to every flight. As previously determined withDocket Operations June 18, 2015 Page 6

Astraeus Aerial, Exemption 11062, relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. 14 CFR § 91.9 (b)(2) - Civil Aircraft Flight Manual, marking, and placard requirements

14 CFR § 91.203 (a) & (b) - Civil aircraft: Certifications required As previously determined with Astraeus Aerial, Exemption 11062, relief from these sections are not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. 14 CFR § 91.109 - Flight instruction: Simulated instrument flight and certain flight tests This regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The controls for a UAS do not currently have a set of fully functioning dual controls. If a UAS’s pilot is being trained, the pilot performing the training would be directly supervising and could take over the controls from the pilot in training if the need arose. This would be similar to the technique of a "throw-over type" control wheel in some fixed wing aircraft. We feel that this technique meets the intent 91 .109 and provides an equivalent level of safety. 14 CFR § 91.119 - Minimum safe altitudes
This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this UAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained, and careful pre-planning has been performed. Further, UAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely,as outlined in 91.119. We believe the slower speed, smaller mass and careful preplanning would provide an equivalent level of safety. Furthermore, Operator can place barriers and/or structures to sufficiently protect nonparticipating person from the UA or debris in the event of an accident. 14 CFR § 9l.l21 - Altimeter settingsDocket Operations June 18, 2015 Page 7

This regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The UAS will normally be flying close to the ground, and in line of sight of the PIC or an observer. This line of sight operation will provide separation from other aircraft, obstructions and terrain providing an equivalent level of safety. Additionally, the altitude information generated by onboard GPS equipment installed on the aircraft will aid in estimating the altitude.

14 CFR § 91.151 - Fuel requirements for flight in VFR conditions This regulation provides that no person may begin a flight in an airplane under day- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph it to provide a reasonable reserve of energy to plan for a safe landing should there be a delay in landing. Given the close proximity to the ground station, the ability for the UAS to land in a very small space and the built in energy level monitoring of the UAS there is a resulting equivalent level of safety if the flight is planned to be completed with 20% battery energy remaining. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR § 91.205 (b) – Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements Since the Operator’s UAS does not have a standard category U.S. airworthiness certificate, relief from 14 CFR § 91.205 is not necessary. 14 CFR § 91.215 - ATC transponder and altitude reporting equipment and use Section 91.215 (b)(3) includes provision for aircraft not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed. For UAS not equipped with a transponder, sub-paragraph (d)(3) authorizes requests for ATC authorized deviations made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified. For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation.Docket Operations Ju ne 18, 2015 P age 8

14 C FR § 91.401 – 91.417 – Maintenance, preventive m aintenance, and alterations This regulation p rovides tha t the o perator is p rimarily responsible f or maintainin g the aircraft in an airworthy condition, inc ludin g compliance with part 39 an d 4 3. Operator believes tha t adherence to their documen ts containing prefligh t and p ost- fligh t checks for t he UAS is sufficien t to ensure t ha t safety is not adver sely af fected.

Respectfully, Alexander Mandiola CEO Prestige Aerials Phone: 305

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- 2654 Prestigeaerials @ gmail .com